Overview

Assets Under Management: $116 million
Headquarters: PENNINGTON, NJ
High-Net-Worth Clients: 34
Average Client Assets: $2.6 million

Frequently Asked Questions

PALANTE WEALTH ADVISORS, LLC charges 1.25% on the first $2 million, 1.00% on the next $4 million, 0.75% on the next $8 million, 0.70% on the next $10 million according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #175298), PALANTE WEALTH ADVISORS, LLC is subject to fiduciary duty under federal law.

PALANTE WEALTH ADVISORS, LLC is headquartered in PENNINGTON, NJ.

PALANTE WEALTH ADVISORS, LLC serves 34 high-net-worth clients according to their SEC filing dated April 27, 2026. View client details ↓

According to their SEC Form ADV, PALANTE WEALTH ADVISORS, LLC offers financial planning, portfolio management for individuals, portfolio management for institutional clients, and educational seminars and workshops. View all service details ↓

PALANTE WEALTH ADVISORS, LLC manages $116 million in client assets according to their SEC filing dated April 27, 2026.

According to their SEC Form ADV, PALANTE WEALTH ADVISORS, LLC serves high-net-worth individuals and institutional clients. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Educational Seminars

Fee Structure

Primary Fee Schedule (FORM ADV PART 2A - FIRM BROCHURE)

MinMaxMarginal Fee Rate
$0 $2,000,000 1.25%
$2,000,001 $4,000,000 1.00%
$4,000,001 $7,500,000 0.75%
$7,500,001 $10,000,000 0.70%
$10,000,001 and above 0.67%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $12,500 1.25%
$5 million $52,500 1.05%
$10 million $88,750 0.89%
$50 million $356,750 0.71%
$100 million $691,750 0.69%

Clients

Number of High-Net-Worth Clients: 34
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 76.98%
Average Client Assets: $2.6 million
Total Client Accounts: 335
Discretionary Accounts: 335
Minimum Account Size: None

Regulatory Filings

CRD Number: 175298
Filing ID: 2099141
Last Filing Date: 2026-04-27 12:32:05

Form ADV Documents

Primary Brochure: FORM ADV PART 2A - FIRM BROCHURE (2026-04-27)

View Document Text
Item 1 - Cover Page Part 2A of Form ADV: Firm Brochure Palante Wealth Advisors, LLC 230 West Delaware Ave Pennington, NJ 08534 Telephone: 609-476-9269 Email: compliance@palantewealth.com Web Address: www.palantewealth.com March 2026 This brochure provides information about the qualifications and business practices of Palante Wealth Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at 609-476-9269 or info@palantewealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration does not imply a certain level of skill or training. Additional information about Palante Wealth Advisors, LLC also is available on the SEC's website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 175298. Page 1 of 19 Item 2 – Material Changes In February 2026, based upon its current AUM, Palante Wealth Advisors applied for registration with the Securities and Exchange Commission. Palante Wealth Advisors has amended its advisory fee schedule. Please refer to Item 5 of this Brochure for further information. There are no other material changes to Palante Wealth Advisors advisory business or personnel to disclose. Page 2 of 19 Item 3 – Table of Contents Contents Item 1 - Cover Page ............................................................................................................................. 1 Item 2 – Material Changes ............................................................................................................. 2 Item 3 – Table of Contents ............................................................................................................. 3 Item 4 - Advisory Business ............................................................................................................ 4 Item 5 - Fees and Compensation .............................................................................................. 7 Item 6 - Performance-Based Fees and Side-By-Side Management .................... 9 Item 7 - Types of Clients .................................................................................................................. 9 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............. 9 Item 9 - Disciplinary Information ............................................................................................. 13 Item 10 - Other Financial Industry Activities and Affiliations .................................. 13 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................................................................................................................... 14 Item 12 - Brokerage Practices ..................................................................................................... 15 Item 13 - Review of Accounts ..................................................................................................... 17 Item 14 - Client Referrals and Other Compensation .................................................... 17 Item 15 - Custody ............................................................................................................................... 18 Item 16 - Investment Discretion ............................................................................................... 18 Item 17 - Voting Client Securities ............................................................................................ 18 Item 18 - Financial Information ................................................................................................. 19 Page 3 of 19 Item 4 - Advisory Business Palante Wealth Advisors, LLC is a registered investment adviser, registered with the Securities and Exchange Commission (“SEC”) with its principal place of business located in New Jersey. Palante Wealth Advisors began conducting business in 2015. Victor J. Medina, President, is the firm’s only principal shareholder (i.e., those individuals and/or entities controlling 10% or more of this company). Types of Advisory Services Palante Wealth Advisors offers the following advisory services to our clients: Investment Management Services We are in the business of managing individually tailored investment portfolios. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation target. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as family composition and background. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Fees for this service are outlined in Item 5 of this brochure. Sub-Advisors. As part of our investment management services, we may use one or more sub- advisors to manage your account on a discretionary basis. The sub-advisor(s) may use one or more of their model portfolios to manage your account. We regularly monitor the performance of your accounts management by sub-advisor(s) and may hire and fire any sub- advisor without your prior approval. The sub-advisor charges a fee for their service; however, you will not pay our firm a higher advisory fee as a result of any sub-advisory relationships. As part of our Investment Management services, we provide financial planning on topics such as retirement planning, risk management, college savings, cash flow, debt management, work benefits, and estate and incapacity planning. In general, our financial planning will address any or all of the following areas of concern. The client and advisor will work together to select the specific areas to cover. These areas may include, but are not limited to, the following: Page 4 of 19 • Business Planning: We provide consulting services for clients who currently operate their own business, are considering starting a business, or are planning for an exit from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan. • Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus saving strategies. • College Savings: Includes projecting the amount that will be needed to achieve college or other post-secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if appropriate). • Employee Benefits Optimization: We will provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. • Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. • Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. • Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. Page 5 of 19 • Investment Analysis: This may involve developing an asset allocation strategy to meet clients ’financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. • Retirement Planning: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (i.e., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. • Risk Management: A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self-insuring”). • Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with consideration that there is always a possibility of future changes to federal, state, or local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. Educational Workshops and Seminars We offer educational workshops to our clients and their family members. We do not charge any fees for these educational workshops. Wrap Fee Programs We do not participate in wrap fee programs. Page 6 of 19 Assets Under Management As of December 31, 2025, we provide continuous management services for approximately $115 Million in client assets on a discretionary basis, and $0 in client assets on a non-discretionary basis. Item 5 - Fees and Compensation How we are paid depends on the type of advisory service we are performing. Please review the fee and compensation information below. Investment Management Services Our standard advisory fee is based on the market value of the assets under management and is calculated as follows: Assets Under Management Annual Fee $0-$2,000,000 1.25% $2,000,001-$4,000,000 1.00% $4,000,001-$7,500,000 0.75% $7,500,001-$10,000,000 0.70% Over $10,000,000 0.67% Advisory fees are directly debited from client accounts, or the client may choose to pay by check. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time remaining in the billing period. Upon termination of the account, any unearned fee will be refunded to the client. Limited Negotiability of Advisory Fees Although Palante Wealth Advisors has established the above-referenced fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances, and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets, related accounts, portfolio style, account composition, and reports, among other factors. The specific annual fee schedule is identified in the contract between the adviser and each client. Page 7 of 19 We may group certain related client accounts for the purposes of achieving the minimum account size requirements and determining the annualized fee. Discounts, not generally available to our advisory clients, may be offered to family members and friends of associated persons of our firm. Fees Billed in Arrears Our advisory fees are charged in arrears as set forth below. In arrears: Advisory fees are billed in arrears at the end of each calendar quarter based upon the average daily asset value (market or fair market value in the absence of market value), of the client's account at quarter-end. When authorized by the client, fees are debited from the account in accordance with the terms set forth in the Investment Advisory Agreement. GENERAL INFORMATION Termination of the Advisory Relationship A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days written notice. As disclosed above, certain fees are paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In calculating a client's reimbursement of fees, we will pro rate the reimbursement according to the number of days remaining in the billing period. Other Types of Fees and Expenses When implementing an investment recommendation, the client may incur additional fees such as brokerage commissions, transaction fees, and other related costs and expenses. Clients may incur certain charges imposed by broker-dealers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that we consider in selecting or recommending broker- dealers and custodians for client’s transactions and determining the reasonableness of their compensation (e.g., commissions). We do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. We do not charge fees for any educational workshops provided to clients or their family members. Page 8 of 19 Advisory Fees in General Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Limited Prepayment of Fees Under no circumstances do we require or solicit payment of fees in excess of $500 more than six (6) months in advance of services rendered. Item 6 - Performance-Based Fees and Side-By-Side Management Palante Wealth Advisors does not charge or offer performance-based fees. Item 7 - Types of Clients Palante Wealth Advisors provides advisory services to individuals, trusts, estates. Our firm does not have a minimum account size requirement. However, we reserve the right to select only those clients who we believe will benefit from our planning. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS Our investment strategies and advice may vary depending upon each client’s specific financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. We may use one or more of the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis. Fundamental Analysis involves analyzing asset classes and/or individual companies and their industry groups, such as company’s financial statements, details regarding the company’s product line, the experience and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. Modern Portfolio Theory (MPT). MPT is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be Page 9 of 19 incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. INVESTMENT STRATEGIES We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Passive Investment Management We primarily practice passive investment management. Passive investing involves building portfolios that are comprised of various distinct asset classes. The asset classes are weighted in a manner to achieve a desired relationship between correlation, risk and return. Funds that passively capture the returns of the desired asset classes are placed in the portfolio. The funds that are used to build passive portfolios are typically mutual funds or exchange traded funds. Passive investment management is characterized by low portfolio expenses (i.e. the funds inside the portfolio have low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency (because the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal). In contrast, active management involves a single manager or managers who employ some method, strategy, or technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a designated benchmark. Academic research indicates most active managers underperform the market. Material Risks Involved All investing strategies we offer involve risk and may result in a loss of your original investment, which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other investment or security. Material risks associated with our investment strategies are listed below. Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the client’s portfolio. Page 10 of 19 Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance. Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions we may be unable to sell or liquidate investments at prices we consider reasonable or favorable or find buyers at any price. Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities ’claim on the issuer’s assets and finances. Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your investments remains the same. Risks Associated With Securities Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer may default. Common Stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks. Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, Page 11 of 19 and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations. Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which clients invest. Risk of Loss. Securities investments are not guaranteed, and you may lose money on your investments. We ask that you work with us to help us understand your tolerance for risk. Investing in securities involves risk of loss that clients should be prepared to bear. Page 12 of 19 Item 9 - Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose. Item 10 - Other Financial Industry Activities and Affiliations Victor J. Medina is the managing attorney of the Medina Law Group, LLC — a law firm focusing exclusively in the areas of estate planning, elder law planning, and estate administration. Mr. Medina is actively engaged in the practice of law. Recommendations of Additional Professional Services Palante Wealth Advisors, LLC refers clients to Medina Law Group, LLC for estate planning and other related legal services. Medina Law Group, LLC and Palante Wealth Advisors, LLC are wholly owned by Victor J. Medina. Because the referral to Medina Law Group, LLC for legal services may lead to legal fees paid by a client, this situation creates a conflict of interest because Palante Wealth Advisors, LLC has a financial incentive to recommend the services of Medina Law Group, LLC since fees paid to either would ultimately benefit Victor J. Medina. You are not obligated, contractually or otherwise, to use the services of Medina Law Group, LLC. It should also be noted that both Palante Wealth Advisors, LLC and Medina Law Group, LLC are bound to a fiduciary standard, which means that a client’s best interest must be the main determining factors of any recommendation. This relationship is disclosed to the client at the commencement of the advisory relationship. Victor J. Medina is licensed to sell life and health insurance and may engage in product sales with our clients, through Medina Financial, LLC, for which he will receive additional compensation. Any commissions received through life or health insurance sales do not offset advisory fees the client may pay for advisory services through Palante Wealth Advisors, LLC. Use of Third-Party Service Provider Forum Financial Management, LLC. We have engaged Forum Financial Management, LLC (“Forum”) as a third-party service provider for the provision of back office services for the benefit of Clients ’accounts. We pay Forum a fee for its services, which include, but are not limited to, account administration, technology, and trading. Clients are not charged any additional fees for Forum’s services. We share relevant Client information with Forum. Forum maintains a privacy policy whereby Forum does not disclosure non-public information obtained from us to any non-affiliated third parties, except as required to process transactions on Client’s behalf. On last filing, Forum Financial Management manages over $9 billion for clients on a discretionary and non-discretionary basis. Page 13 of 19 Retirement Account Rollovers/Transfers (e.g., 401(k) and IRAs) When recommending that a client rollover his or her account from current retirement plan to an IRA, Palante Wealth Advisors, LLC and its financial advisors have a conflict of interest. Palante Wealth Advisors, LLC and its financial advisors can earn investment advisory fees by recommending that a client rollover his or her account at the retirement plan to an IRA; however, Palante Wealth Advisors, LLC and its investment adviser representatives will not earn any investment advisory fee if client does not rollover the funds in the retirement plan. Thus, Palante Wealth Advisors, LLC and its financial advisors have an economic incentive to recommend a rollover of the retirement plan account, which is a conflict of interest. Palante Wealth Advisors, LLC has taken steps to manage this conflict of interest arising from rolling over funds from an ERISA covered retirement plan to an IRA and has adopted written policies and procedures whereby Palante Wealth Advisors, LLC and its financial advisors will disclose the advantages/disadvantages of the retirement plan/IRA rollover options available to the client and will only recommend rollover if in the best interest of the client. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of each client. Our clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. Palante Wealth Advisors and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Palante Wealth Advisors’s Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any particular access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy at any time, and one will be delivered to you promptly. Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and its “related persons” (associates, their immediate family members, etc.) may buy or sell securities the same as, similar to, or different from, those we recommend to clients for their accounts. A recommendation made to one client may be different in nature or in timing from a recommendation made to a different client. Clients often have different objectives and risk tolerances. At no time, however, will our firm or any related party receive preferential treatment over our clients. Page 14 of 19 In an effort to reduce or eliminate certain conflicts of interest involving the firm or personal trading, our policy may require that we restrict or prohibit associates ’transactions in specific securities transactions. Any exceptions or trading pre-clearance must be approved by our Chief Compliance Officer in advance of the transaction in an account, and we maintain the required personal securities transaction records per regulation. Item 12 - Brokerage Practices FACTORS USED TO SELECT CUSTODIANS AND/OR BROKER-DEALERS Palante Wealth Advisors does not have any affiliation with Broker-Dealers. Specific custodian recommendations are made to client based on their need for such services. We recommend custodians based on the reputation and services provided by that company. We endeavor to select brokers or dealers that provide quality services at reasonable commission rates and fees. We believe that recommended broker-dealers provide quality execution services for our clients at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by recommended broker-dealers including the value of research provided, the firm’s reputation and financial stability, execution capabilities, commission rates, and responsiveness to our clients and our firm. We recommend a specific custodian for clients to use, however clients may custody their assets at a custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By allowing clients to choose a specific custodian, we may be unable to achieve most favorable execution of client transaction, and this may cost clients ’money over using a lower-cost custodian. We typically recommend that you establish brokerage accounts with Charles Schwab & Co., Inc., member FINRA/SIPC (“Schwab”) to maintain custody of the client’s assets and to effect trades for your accounts. We participate with the Schwab Advisor Services division of Schwab, a registered broker-dealer, member SIPC, to maintain custody of clients ’assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at your discretion. We are independently owned and operated, and not affiliated with Schwab. Schwab provides us with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them, so long as a total of at least $10 million of the advisor’s clients ’assets are maintained in accounts at Schwab Advisor Services. Our relationship with Forum Financial Management grants us access to all of Schwab’s services regardless of our assets under management. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Page 15 of 19 For client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to us other products and services that benefit us but may not benefit our clients' accounts. These benefits may include national, regional or advisor specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of ours by Schwab Advisor Services personnel, including meals and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist us in managing and administering clients' accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of our fees from clients' accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of our accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to us other services intended to help us manage and further develop our business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to us by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to us. While, as a fiduciary, we endeavor to act in our clients' best interests, our recommendation that clients maintain their assets in accounts at Schwab may be based in part on the benefit to us of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Research and Other Soft-Dollar Benefits We currently do not receive soft dollar benefits. Brokerage for Client Referrals We receive no referrals from a broker-dealer or third party in exchange for using that broker- dealer or third party. Page 16 of 19 Aggregating (Block) Trading Multiple Accounts Investment advisors may elect to purchase or sell the same securities for several clients at approximately the same time when they believe such action may prove advantageous to clients. This process is referred to as aggregating orders, batch trading, or block trading. We do not engage in block trading. It should be noted that implementing trades on a block or aggregate basis may be less expensive for client accounts; however, it is our trading policy to implement all client orders on an individual basis. Therefore, we do not aggregate or “block” client transactions. Considering the types of investments we hold in advisory client accounts, we do not believe clients are hindered in any way because we trade accounts individually. This is because we develop individualized investment strategies for clients and holdings will vary. Our strategies are primarily developed for the long-term and minor differences in price executions are not material to our overall investment strategy. Item 13 - Review of Accounts Account Reviews Victor J. Medina, CEO and CCO, typically recommends formal in-person meetings 1-4 times per year with our clients who live in the area, based upon each client's preference and needs. For our clients who live outside of our area, we suggest regular updates via email, phone, web- conferencing, typically 1 to 4 times a year, and in-person meetings as appropriate. Additional reviews may be conducted based on various circumstances, including, but not limited to: contributions and withdrawals, year-end tax planning, changes in your goals, security specific events, and/or changes in your risk/return objectives. A detailed performance report each quarter that compares your portfolio's performance to a series of relevant benchmarks is prepared and available for your review. You will also receive trade confirmations and monthly or quarterly statements from your account custodian(s). We urge clients to compare these reports against the account statements they receive from their custodian. Item 14 - Client Referrals and Other Compensation Currently it is Palante Wealth Advisors's policy not to engage solicitors or to pay related or non-related persons for referring potential clients to our firm. It is Palante Wealth Advisors's policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. Recommendation of Professional Services As disclosed in Item 10, Victor J. Medina is the sole owner of both Palante Wealth Advisors, LLC and Medina Law Group, LLC. Recommendations to engage either or both of the services of Palante Wealth Advisors and Medina Law Group, LLC will result in compensation paid to one or both of those entities. Both entities are bound by the fiduciary Page 17 of 19 standard, which means that recommendations to engage the services of either entity must be in the client’s best interest. Fees paid for services to either entity are not directly shared between the two entities. Item 15 - Custody We do not accept custody of client funds. Clients should receive at least quarterly statements from the broker dealer, bank, or other qualified custodian that holds and maintains client’s investment assets. We urge you to review carefully such statements and compare such official custodial records to the account statements or reports that we may provide to you. Our statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Palante Wealth Advisors effects third party asset transfers in client accounts using a Standing Letter of Authorization (“SLOA”). Pursuant to the SEC No Action Letter Investment Adviser Association, February 21, 2017 (sec.gov), Palante Wealth Advisors is deemed to have Custody over these accounts. Palante Wealth Advisors has instituted procedures to comply with the seven representations noted in the SEC No-Action letter and avoid the annual surprise audit requirement. Item 16 - Investment Discretion For those client accounts where we provide investment management services, we maintain discretion over client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold. Investment discretion is explained to clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the client will execute a Limited Power of Attorney which will grant our firm discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the client. Item 17 - Voting Client Securities We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies. Page 18 of 19 Item 18 - Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to clients, and we have not been the subject of a bankruptcy proceeding. We do not have custody of client funds or securities or require or solicit prepayment of more than $500 in fees per client six months in advance. Palante Wealth Advisors has no additional financial circumstances to report. Palante Wealth Advisors has not been the subject of a bankruptcy petition at any time during the past ten years. Page 19 of 19