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ITEM 1 – COVER PAGE
FORM ADV PART 2A
FEBRUARY 24, 2026
PALATINE HILL WEALTH MANAGEMENT
OFFICE: 313-570-8084
148 PIERCE STREET
SUITE 200
BIRMINGHAM, MI 48009
INFO@PALATINEHILLWEALTH.COM
WWW.PALATINEHILLWEALTH.COM
This brochure provides information about the qualifications and business practices of Palatine Hill Wealth
Management (“Palatine Hill”). If you have any questions about the contents of this brochure, please contact
us at 313-570-8084. 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. Palatine Hill is a Registered
Investment Adviser. Registration as an Investment Adviser with the United States Securities and Exchange
Commission or any state securities authority does not imply a certain level of skill or training.
Additional information about Palatine Hill 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 IARD number. The IARD number for Palatine
Hill is 305619.
ITEM 2 – MATERIAL CHANGES
SUMMARY OF MATERIAL CHANGES
This section of the Brochure will address only those “material changes” that have been incorporated since
our
last delivery or posting of this document on the SEC’s public disclosure website (IAPD)
www.adviserinfo.sec.gov.
Since our last ADV Annual Amendment filing made on March 6, 2025, the following materials changes have
occurred:
•
There are no material changes to disclose.
Currently, a free copy of our Brochure may be requested by contacting Charles Dabrowski, Chief Compliance
Officer of Palatine Hill at 313-570-8084 or cdabrowski@palatinehillwealth.com. It is also available on our
web site www.palatinehillwealth.com.
We encourage you to read this document in its entirety.
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 1
ITEM 3 – TABLE OF CONTENTS
ITEM 1 – COVER PAGE
0
ITEM 2 – MATERIAL CHANGES
1
ITEM 3 – TABLE OF CONTENTS
2
ITEM 4 – ADVISORY BUSINESS
3
ITEM 5 - FEES AND COMPENSATION
8
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
10
ITEM 7 - TYPES OF CLIENTS
10
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
10
ITEM 9 - DISCIPLINARY INFORMATION
17
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
17
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
19
TRADING
ITEM 12 - BROKERAGE PRACTICES
20
ITEM 13 - REVIEW OF ACCOUNTS
22
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
23
ITEM 15 – CUSTODY
23
ITEM 16 – INVESTMENT DISCRETION
24
ITEM 17 – VOTING CLIENT SECURITIES
24
ITEM 18 – FINANCIAL INFORMATION
25
PRIVACY POLICY
25
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 2
ITEM 4 – ADVISORY BUSINESS
This Disclosure document is being offered to you by Palatine Hill Wealth Management (“Palatine Hill” or
“Firm”) about the investment advisory services we provide. It discloses information about our services and
the way those services are made available to you, the client.
We are an investment management firm located in Ann Arbor, MI and Birmingham, MI. We specialize in
investment advisory services for individuals, high net worth individuals, foundations, employee sponsored
retirement plans, charitable organizations, trusts, and corporations. Our Firm became a registered
investment adviser in September 2019 and is owned by Charles Dabrowski, Jeff Cheek, and Thomas Lozser
Revocable Trust. Charles Dabrowski is the Chief Compliance Officer.
We are committed to helping clients build, manage and preserve their wealth, and to provide assistance
that helps clients to achieve their stated financial goals. We will offer an initial complimentary meeting upon
our discretion; however, investment advisory services are initiated only after you and Palatine Hill execute
an Investment Management Agreement.
INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary and non-discretionary basis. For discretionary accounts,
once we have determined a profile and investment plan with a client, we will execute the day to day
transactions without seeking prior client consent. Account supervision is guided by the written profile and
investment plan of the client. We may accept accounts with certain restrictions, if circumstances warrant.
We primarily allocate client assets among various equities, Exchanged Traded Funds (“ETFs”), no-load or
load-waived mutual funds, or alternative investments in accordance with their stated investment
objectives.
During personal discussions with clients, we determine the client’s objectives, time horizons, risk tolerance,
and liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family
composition and background. Based on client needs, we develop a client’s personal profile and investment
plan. We then create and manage the client’s investments based on that policy and plan. It is the client’s
obligation to notify us immediately if circumstances have changed with respect to their goals.
Once we have determined the types of investments to be included in your portfolio and allocated them, we
will provide ongoing investment review and management services. This approach requires us to
periodically review your portfolio.
With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to
meet your financial objectives. We trade these portfolios based on the combination of our market views
and your objectives, using our investment process. We tailor our advisory services to meet the needs of our
clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and
objectives. You will have the ability to leave standing instructions with us to refrain from investing in
particular industries or invest in limited amounts of securities.
If a non-discretionary relationship is in place, calls will be placed presenting the recommendation made and
only upon your authorization will any action be taken on your behalf.
In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in
a pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory
fees from your accounts, but only with the appropriate written authorization from you.
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 3
Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically,
these are assets that are ineligible to be custodied at our primary custodian. Clients will engage us to advise
on certain investment products that are not maintained at their primary custodian, such as variable life
insurance, annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition
plans (i.e., 529 plans).
You are advised and are expected to understand that our past performance is not a guarantee of future
results. Certain market and economic risks exist that adversely affect an account’s performance. This could
result in capital losses in your account.
Periods of Inactivity
Palatine Hill has a fiduciary duty to provide services consistent with the client’s best interest. As part of its
investment advisory services, [Firm Name] will review client portfolios on an ongoing basis to determine if
any changes are necessary based upon various factors, including, but not limited to, investment
performance, fund manager tenure, style drift, and/or a change in the client’s investment objective. Based
upon these factors, there may be extended periods of time when Palatine Hill determines that changes to
a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no
assurance that investment decisions made by Palatine Hill will be profitable or equal any specific
performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during
periods of account inactivity.
FINANCIAL PLANNING
Through the financial planning process, our team strives to engage our clients in conversations around the
family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future
generations. With the unique goals and circumstances of each family in mind, our team will offer financial
planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax,
charitable, cash flow, wealth transfer, and family legacy objectives. Our team partners with our client’s
other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated
effort of all parties toward the client’s stated goals. Such services include various reports on specific goals
and objectives or general investment and/or planning recommendations, guidance to outside assets, and
periodic updates.
Our specific services in preparing your plan may include:
▪ Review and clarification of your financial goals
▪ Assessment of your overall financial position including cash flow, balance sheet, investment
strategy, risk management, and estate planning
▪ Creation of a unique plan for each goal you have, including personal and business real estate,
education, retirement or financial independence, charitable giving, estate planning, business
succession, and other personal goals
▪ Development of a goal-oriented investment plan, with input from various advisors to our clients
around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This
includes IRA and qualified plans, taxable, and trust accounts that require special attention
▪ Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer,
including liquidity as well as various insurance and possible company benefits; and
▪ Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax
advisor, an estate plan to provide for you and/or your heirs in the event of an incapacity or death
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 4
A written evaluation of each client's initial situation or Financial Plan is provided to the client. An annual
review will be provided by the Advisor, if indicated by the Client and Advisor per the Agreement. More
frequent reviews occur, but are not necessarily communicated to the client unless immediate changes are
recommended.
PARTICIPANT ACCOUNT MANAGEMENT (DISCRETIONARY)
We use a third-party platform to facilitate management of held away assets such as defined contribution
plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody
of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not
affiliated with the platform in any way and receive no compensation from them for using their platform. A
link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client
account(s) is connected to the platform, Adviser will review the current account allocations. When deemed
necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and
any change in allocations will consider current economic and market trends. The goal is to improve account
performance over time, minimize loss during difficult markets, and manage internal fees that harm account
performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as
deemed necessary.
RETIREMENT PLAN CONSULTING SERVICES
Retirement Plan Consulting Services consist of acting as a service provider liaison, providing participant
enrollment meetings, and assisting with participant education. While the primary clients for these services
will be pension, profit sharing and 401(k) plans, we offer these services, where appropriate, to individuals
and trusts and organizations. Pension Consulting Services are comprised of four distinct services listed
below. Clients may choose to use any or all of these services.
INVESTMENT POLICY STATEMENT PREPARATION (“IPS”)
We will meet with the client (in person or over the telephone) to determine an appropriate
investment strategy that reflects the plan sponsor's stated investment objectives for management
of the overall plan. Our Firm then prepares a written IPS detailing those needs and goals, including
an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria
for selection of investment vehicles as well as the procedures and timing interval for monitoring
of investment performance.
SELECTION OF INVESTMENT VEHICLES
We assist plan sponsors in constructing appropriate asset allocation models. We will then review
various mutual funds (both index and managed) to determine which investments are appropriate
to implement the client's IPS. The number of investments to be recommended will be determined
by the client, based on the IPS.
PARTICIPANT ENROLLMENT
We will assist Plan Sponsor in enrolling Plan participants in the Plan, including conducting an
agreed upon number of enrollment meetings. As part of such meetings, we will provide
participants with information about the Plan, which may include information on the benefits of
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 5
Plan participation, the benefits of increasing Plan contributions, the impact of preretirement
withdrawals on retirement income, the terms of the Plan, and the operation of the Plan.
PLAN EDUCATION
We will assist participant education, which may include preparation of education materials and/or
conducting investment education seminars and meeting for Plan Participants. Such meetings may
be on a group and/or individual basis. Such meetings shall not include specific investment advice
about investment options under the Plan as being appropriate for a particular participant, but may
include the use of education investment models.
Plan participants have the ability to exercise control over the assets in their account, and we have
no authority or discretion to direct the investment of assets of any participant’s account under the
Retirement Plan Consulting services offered by our Firm.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
A client or prospect leaving an employer typically has four options regarding an existing retirement plan
(and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted,
(iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an inves-
tor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our
Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or
prospective client leave their plan assets with their previous employer or roll over the assets to a plan spon-
sored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an
economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which
presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm
will consider before recommending a rollover, including but not limited to: (i) the investment options avail-
able in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus
the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals
versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum
distributions and age considerations, and (vi) employer stock tax consequences, if any. All rollover recom-
mendations are also reviewed by our Firm’s Chief Compliance Officer in a best effort to determine that the
recommendation to a client was reasonable or that the client has determined to make the rollover after
being provided ample information about their options. No client is under any obligation to roll over plan
assets to an IRA advised by our Firm or to engage our Firm to monitor and/or advise on the account while
maintained with the client's employer. Our Firm’s Chief Compliance Officer remains available to address
any questions that a client or prospective client has regarding this disclosure.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to
you regarding your retirement plan account or individual retirement account, we are also fiduciaries within
the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code,
as applicable, which are laws governing retirement accounts. We have to act in your best interest and not
put our interest ahead of yours. At the same time, the way we make money creates some conflicts with
your interests.
SUB ADVISOR/THIRD PARTY MONEY MANAGERS (“TPMM”)
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 6
Occasionally our Firm utilizes the services of a TPMM for the management of client accounts. Investment
advice and trading of securities will only be offered by or through the chosen TPMM. Our Firm will not offer
advice on any specific securities or other investments in connection with this service. Prior to referring
clients, our Firm will provide initial due diligence on TPMM and ongoing reviews of their management of
client accounts. In order to assist in the selection of a TPMM, our Firm will gather client information
pertaining to financial situation, investment objectives, and reasonable restrictions to be imposed upon the
management of the account.
Our Firm will periodically review third party money manager reports provided to the client at least annually.
Our Firm will contact clients from time to time in order to review their financial situation and objectives;
communicate information to TPMM as warranted; and, assist the client in understanding and evaluating
the services provided by the TPMM. Clients will be expected to notify our Firm of any changes in their
financial situation, investment objectives, or account restrictions that could affect their financial standing.
Our Firm takes actions on behalf of the client to hire or fire money managers used in the implementation
of a client’s investment plan and execution of the Advisory Agreement with our Firm. Therefore, the Firm
has the discretionary authority to hire or fire the manager or to allocate assets among managers without
obtaining the Client’s consent.
WRAP FEE PROGRAM
Palatine Hill is the sponsor and manager of the Palatine Hill Wrap Program (the “Program”), a wrap fee
program. Under our wrap program, you will receive advisory services, financial planning services, the
execution of securities brokerage transactions, custody and reporting services for a single specified advisory
fee. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs
associated with managing the account, and the frequency or type of securities transactions executed in the
account. A wrap fee program may not be suitable for all accounts, including but not limited to accounts
holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income
securities or no-transaction-fee mutual funds, or any other type of security that can be traded without
commissions or other transaction fees. The terms and conditions of a wrap program engagement are more
fully discussed in our Wrap Fee Program Brochure. We manage wrap accounts on a discretionary basis.
When managing a client’s account on a wrap fee basis, we receive as compensation for our advisory
services, the balance of the total wrap fee you pay after custodial, trading, and other management costs
(including execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest
because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the
total costs incurred in your account(s) subject to a wrap fee. Schwab and other custodians have eliminated
commissions for online trades of U.S. equities, and ETFs. This means that, in most cases, when we buy and
sell these types of securities, we will not have to pay any commissions to the Custodian. We encourage you
to review the Custodian’s pricing to compare the total costs of entering into a wrap fee arrangement versus
a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest
separately.
could
exceed
the
cost of paying
for brokerage
and
advisory
services
ASSETS
As of December 31, 2025, we manage $293,840,462 in discretionary assets under management. Our firm
manages $2,059,928 in non-discretionary assets.
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 7
ITEM 5 - FEES AND COMPENSATION
INVESTMENT MANAGEMENT FEES AND COMPENSATION
Our Firm charges a fee as compensation for providing Investment Management services on your account.
These services include advisory services, trade entry, investment supervision, and other account
maintenance activities. Our custodian charges transaction costs, custodial fees, redemption fees,
retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for
details.
The fees for investment management are based on an annual percentage of assets under management and
are applied to the household asset value on a pro rata basis. Fees are billed quarterly in advance based on
the average daily balance of the account(s) during the previous quarter. Fees may be adjusted for deposits
and withdrawals during the previous quarter. Fees are assessed on all assets under management, including
securities, cash, and money market balances. If a client has a margin account, our fees will be based on the
full value of the assets under management without regard to the amount of margin debt on the account.
Clients need to be aware that buying investments using margin increases the amount of fees paid to us.
Our maximum investment advisory fee is 1.00%, or we may negotiate a lower advisory fee. The specific
advisory fees are set forth in your Investment Advisory Agreement. Fees may vary based on the size of the
account, complexity of the portfolio, extent of activity in the account, or other reasons agreed upon by us
and you as the client. In certain circumstances, our fees and the timing of the fee payments may be
negotiated. Our employees and their family related accounts are charged a reduced fee for our services.
Unless otherwise instructed by the Client, we will aggregate related client accounts for the purposes of
determining the account size and annualized fee. The common practice is often referred to as “house-
holding” portfolios for fee purposes and may result in lower fees than if fees were calculated on portfolios
separately. Our method of house-holding accounts for fee purposes looks at the overall family dynamic
and relationship. When applicable, and noted in Appendix A of the Investment Management Agreement,
legacy positions will also be excluded from the fee calculation.
The independent and qualified custodian holding your funds and securities will debit your account directly
for the advisory fee and pay that fee to us. You will provide written authorization permitting the fees to be
paid directly from your account held by the qualified custodian. Further, the qualified custodian agrees to
deliver an account statement to you on a quarterly basis indicating all the amounts deducted from the
account including our advisory fees.
Either Palatine Hill or you may terminate the management agreement immediately upon written notice to
the other party. The management fee will be pro-rated to the date of termination, for the quarter in which
the cancellation notice was given and the unearned fee refunded to your account.
Upon termination, you are responsible for monitoring the securities in your account, and we will have no
further obligation to act or advise with respect to those assets. In the event of client’s death or disability,
Palatine Hill will continue management of the account until we are notified of client’s death or disability
and given alternative instructions by an authorized party.
FINANCIAL PLANNING FEES
Our financial planning services are included in the investment management fee discussed above, unless
otherwise discussed and documented.
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 8
RETIREMENT PLAN CONSULTING SERVICES
We charge 0.50% for pension consulting services as disclosed in the Employer Sponsored Retirement Plans
Consulting Agreement (“Plan Consulting Agreement”). The compensation method is explained and agreed
upon in advance before any services are rendered.
Plan advisory services begin with the effective date of the Plan Consulting Agreement, which is the date you
sign the Plan Consulting Agreement. For that calendar quarter, fees will be adjusted pro rata based upon
the number of calendar days in the calendar quarter that the Agreement was effective. Our fee is billed in
arrears on the last business day of the calendar quarter, as indicated on the Appendix of the Plan Consulting
Agreement. Invoices are sent out each quarter to either the client or the custodian of the Plan. For Plans
where our fee is billed to the custodian, the fee is deducted directly from the participant accounts. Written
authorization permitting us to be paid directly from the custodial account is outlined in the Plan Consulting
Agreement.
Either party may terminate the Plan Consulting Agreement at any time upon immediate notice. You are
responsible to pay for services rendered until the termination of the agreement.
SUB-ADVISOR/THIRD PARTY MONEY MANAGER (“TPMM”) FEES AND SERVICES
If deemed appropriate by the Firm, Palatine Hill may recommend an independent TPMM to act as a sub-
adviser within a client’s portfolio. In those circumstances, the Sub-Advisor/TPMM manages the assets based
upon the parameters provided by our Firm.
The TPMM recommended for the portfolio may have higher or lower fees than other programs available
through Palatine Hill or available elsewhere. Investment management programs may differ in the services
provided and method or type of management offered, and each may have different account minimums.
Client reports will depend upon the management program selected. TPMM fees and services will be
indicated on your Investment Advisory Agreement. The TPMM fee is in addition to the investment advisory
fee charged by Palatine Hill. The combined advisory fee billed by Palatine Hill and the TPMM fee are not to
exceed 2.00%.
The services provided by the TPMM include:
Implementation of an asset allocation.
Facilitation of portfolio transactions.
▪ Assessment of the client's investment needs and objectives.
▪
▪ Delivery of suitable style allocations (e.g., Large Cap, Small Cap, Growth, Value, etc.)
▪
▪ Ongoing monitoring of investment vehicles performance.
▪ Review of client accounts for adherence to policy guidelines and asset allocation.
▪ Recommendations for account re-balancing, if and when necessary.
▪ Reporting of client portfolio performance and progress.
▪
Engaging selected investment vehicles on behalf of the client
Please see complete details in the program brochure and custodial account agreement for each program
recommended and offered.
A TPMM relationship may be terminated at the IAR’s discretion. Palatine Hill may at any time terminate the
relationship with a TPMM that manages your assets. Palatine Hill will notify you of instances where we have
terminated a relationship with any TPMM you are investing with. Palatine Hill will not conduct on-going
supervisory reviews of the TPMM following such termination.
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 9
Factors involved in the termination of a TPMM may include a failure to adhere to their stated management
style or your objectives, a material change in the professional staff of the TPMM, unexplained poor
performance, unexplained inconsistency of account performance, or our decision to no longer include the
TPMM on our list of approved TPMMs.
ADMINISTRATIVE SERVICES PROVIDED BY BLACK DIAMOND
We have contracted with Black Diamond to utilize its technology platforms to support data reconciliation,
performance reporting, fee calculation, client relationship maintenance, quarterly performance
evaluations, and other functions related to the administrative tasks of managing client accounts. Due to
this arrangement, Black Diamond will have access to client accounts, but Black Diamond will not serve as
an investment advisor to our clients or bill the accounts. Palatine Hill and Black Diamond are non-affiliated
companies. Black Diamond charges our Firm an annual fee for each account administered by its software.
Please note that the fee charged to the client will not increase due to the annual fee Palatine Hill pays to
Black Diamond. The annual fee is paid from the portion of the management fee retained by Palatine Hill.
ADDITIONAL FEES AND EXPENSES:
In addition to the advisory fees paid to our Firm, clients may also incur certain charges imposed by other
third parties, such as broker-dealers, custodians, trust companies, banks, and other financial institutions
(collectively “Financial Institutions”). These additional charges may include custodial fees, fees charged by
the Independent Managers, charges imposed directly by a mutual fund or ETF in a client’s account, as
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), 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. Palatine Hill’s brokerage practices are described
at length in Item 12, below. Neither our Firm nor its supervised persons accept compensation for the sale
of securities or other investment products. Further, our Firm does not share in any of these additional fees
and expenses outlined above.
ITEM 6 - PERFORMANCE BASED FEES AND SIDE -BY-SIDE MANAGEMENT
We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a client
account (so-called performance-based fees), nor engage side by side management.
ITEM 7 - TYPES OF CLIENTS
We provide investment advice to individuals, high-net worth individuals, employee sponsored retirement
plans, institutions, charitable organizations, trusts, foundations, endowments, family offices, and estates.
We do not require a minimum dollar amount to open and maintain an advisory account.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
Asset classes, market capitalizations, and investment styles are cyclical – coming into and going out of favor
without informing market participants when, to what degree, or for how long they intend on remaining
dislocated from their long-term averages. Therefore, we do not try to time when to enter and exit the
market – as time in the market is more important than timing it – nor do we portend to have some divine
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 10
knowledge about the short-term direction of markets – markets that are completely out of our
control. Instead of diverting our attention to the items that we are unable to influence, we focus all of our
energy on the areas of a client portfolio we do have control over – (1) purpose driven investing through
aligning the underlying investment strategy to the needs of the client assets, (2) thorough and exhaustive
investment research to potentially maximize long-term wealth accumulation through portfolio positioning,
(3) consistent and unwavering diversification within the portfolio in an attempt to ensure against the risk
of total loss, and (4) disciplined rebalancing of client assets allowing for an objective reallocation of capital
and risk. These four tenants do not guarantee the road won’t be bumpy at times; however, they do provide
the necessary guardrails to ensure our clients stay on the road to meeting their long-term goals.
Palatine Hill’s fundamental job is to meet a variety of client financial goals by selecting and actively
managing choices of investments against changing market conditions and opportunities as appropriate to
accomplish clients’ needs for income, wealth accumulation and/or capital preservation.
We use the following methods of analysis in formulating our investment advice and/or managing client
assets:
•
FUNDAMENTAL ANALYSIS: We attempt to measure the intrinsic value of a security by looking
at economic and financial factors (including the overall economy, industry conditions, and the
financial condition and management of the company) to determine if the security is underpriced
(indicating that it may be a good time to buy) or overpriced (indicating that it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential
risk because the price of a security can move up or down along with the overall market regardless
of the economic and financial factors considered in evaluating the security.
• ASSET ALLOCATION: In addition to focusing on securities selection, we attempt to identify an
appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and
risk tolerance.
A risk of asset allocation is that the client may not participate in sharp increases in a particular
security, industry or market sector. Another risk is that the ratio of securities, fixed income, and
cash will change over time due to stock and market movements and, if not corrected, will no longer
be appropriate for the client’s goals.
Periodically we may encounter economic conditions that warrant temporary adjustments to the
asset allocation of an investment strategy or portfolio. If we believe that these conditions present
either an increase in risk or opportunity for that particular asset class we may alter the appropriate
allocation to reflect this conviction.
• MUTUAL FUND AND/OR ETF ANALYSIS: We look at the experience and track record of the
manager of the mutual fund or ETF in an attempt to determine if the manager has demonstrated
an ability to invest over a period of time and in different economic conditions. We also look at the
underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap
in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the
funds or ETFs in an attempt to determine if they are continuing to follow their stated investment
strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance
does not guarantee future results. A manager who has been successful may not be able to replicate
that success in the future. In addition, because we do not control the underlying investments in a
fund or ETF, managers of different funds held by the client may purchase the same security thereby
increasing the risk to the client if that security were to fall in value. There is also a risk that a
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 11
•
manager may deviate from the stated investment mandate or strategy of the fund or ETF which
could make the holding(s) less suitable for the client’s portfolio.
TECHNICAL ANALYSIS: Trends in price and trading volume can provide important clues on the
demand for a particular stock. Deciding whether and when to buy or sell a stock or stocks in general
(the overall market) is an important part of the investment process, particularly as it applies to
managing risk. As an aid in making decisions, we look at the basic technical patterns and signals
recognized by the industry as providing meaningful input. The key consideration is a trend: its
strength, length, exhaustion and reversal. These situations can result in buying and selling
opportunities.
• 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 incorrect, there is
always a risk that our analysis may be compromised by inaccurate or misleading information.
• ARTIFICIAL INTELLIGENCE AND MACHINE LEARNING: Certain service providers utilized by the Firm
to service client accounts have artificial intelligence components, such as our client relationship
management system that utilizes artificial intelligence to summarize client meeting notes. The use
of artificial intelligence and machine learning includes increased risk of data inaccuracies and
security vulnerabilities. Due to the rapid advancement of machine learning technologies, future
risks related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our
clients, our Firm performs periodic due diligence of our service providers for assurance that the
service providers have appropriate controls in place to protect our clients’ information and to limit
data inaccuracies when artificial intelligence is used by the service provider.
• USE OF ALTERNATIVE INVESTMENTS: If deemed appropriate for your portfolio, our Firm may
recommend investments classified as "alternative investments". Alternative investments may
include a broad range of underlying assets including, but not limited to, hedge funds, private
equity, limited partnerships, venture capital, and registered, publicly traded securities. Alternative
investments are speculative, not suitable for all clients and intended for only experienced and
sophisticated investors who are willing to bear the high risk of the investment. The maximum and
minimum portion of any client’s portfolio that is invested at any one time is predicated on their
overall risk tolerance and financial goals. Within that range, we will use cash as a cushion against
market volatility. To make these decisions, we employ a combination of technical indicators
provided by outside services, research from academia, and our own Palatine Hill computer models
developed and tested over past periods.
• DIGITAL ASSETS. Certain Accounts may enter into futures contracts based on Bitcoin or other
digital assets or may hold and/or invest in digital assets directly, including Bitcoin. Digital assets,
including “blockchain” assets, digital “tokens” and “cryptocurrencies”, are part of a new and
rapidly evolving industry that is subject to a high degree of volatility in value/price and regulatory
uncertainty. Digital currency is not issued or backed by any government, bank, or central
organization, but instead only exists on an online, peer-to-peer, distributed network that acts as a
public and immutable record of all transactions in the underlying digital currency. Digital asset
prices have been subject to periods of excessive volatility in the past, and such periods can be
expected to recur. Price volatility is influenced by many unpredictable factors, such as market
perception, the development of competing digital assets, changes in government regulation, the
occurrence of an adverse incident relating to one or more digital assets (including digital assets
not held by Accounts), inflation rates, interest rate movements, and general economic and political
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 12
conditions. Changes in the governance of a digital asset network may not receive sufficient support
from users and miners, which may negatively affect that digital asset network’s ability to grow and
respond to challenges. Further, digital asset networks face significant scaling challenges, and
efforts to increase the volume and speed of transactions may not be successful. If the digital asset
award for mining blocks and transaction fees for recording transactions on the Bitcoin Network
are not sufficiently high to incentivize miners, miners may cease expanding processing power or
demand high transaction fees, which could negatively impact the value of Bitcoin. Digital assets
such as Bitcoin were only introduced within the past decade, and the medium-to-long term value
of digital assets are subject to a number of factors relating to the capabilities and development of
blockchain technologies and to the fundamental investment characteristics of digital assets. Digital
asset networks, including the Bitcoin Network, are part of a new and rapidly evolving industry, and
the value of digital assets depends on the development and acceptance of these digital asset
networks. The Bitcoin Network was first launched in 2009 and Bitcoins were the first cryptographic
digital assets created to gain global adoption and critical mass. Although the Bitcoin Network is an
established digital asset network, the Bitcoin Network and other cryptographic and algorithmic
protocols governing the issuance of digital assets represent a new and rapidly evolving industry
that is subject to a variety of factors that are difficult to evaluate. Moreover, in the past, flaws in
the source code for digital assets have been exposed and exploited, including flaws that disabled
some functionality for users, exposed users’ personal information and/or resulted in the theft of
users’ digital assets. The cryptography underlying certain digital assets including Bitcoin could
prove to be flawed or ineffective, or developments in mathematics and/or technology, including
advances in digital computing, algebraic geometry and quantum computing, could result in such
cryptography becoming ineffective. In any of these circumstances, a malicious actor may be able
to take an Account’s digital assets, which would adversely affect the value of the Account.
Moreover, functionality of a digital asset network may be negatively affected such that it is no
longer attractive to users, thereby dampening demand for the applicable digital asset. In addition,
if a digital asset held by an Account is determined to be a “security,” it may adversely affect the
value of the digital asset. Accounts may trade digital assets on an over-the-counter basis or on a
digital asset exchange. Opportunities to trade digital assets OTC may be limited, and OTC platforms
may impose minimum trade size or other requirements that an Account is unable to satisfy.
Exchanges on which digital assets trade generally are relatively new and largely unregulated, and
may therefore be more exposed to fraud, mismanagement and failure than established, regulated
exchanges for other products. The SEC, CFTC, certain state regulators and other U.S. and non-U.S.
government or quasigovernmental agencies have asserted authority over digital assets. Those
entities and other U.S. and non-U.S. government or quasi-governmental agencies have recently
and may, in the future, adopt laws, regulations, directives or other guidance that affect digital
assets. The effect of any future U.S. federal or state or non-U.S. legal or regulatory changes is
impossible to predict, but such change could be substantial and adverse to the value of an
Account’s digital asset investments. Furthermore, the taxation of digital currencies is uncertain in
many jurisdictions and continuously evolving in others. Venues through which digital assets trade
are new and, in many cases, largely unregulated. Furthermore, many such digital asset trading
venues, including digital asset exchanges and over the counter trading venues, do not provide the
public with significant information regarding their ownership structure, management teams,
corporate practices or regulatory compliance. As a result, the marketplace may lose confidence in,
or may experience problems relating to, digital asset trading venues. Digital asset trading venues
may impose daily, weekly, monthly or customer-specific transaction or distribution limits or
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 13
suspend withdrawals entirely, rendering the exchange of digital assets for fiat currency difficult or
impossible. Participation in digital asset trading venues requires users to take on credit risk by
transferring digital assets from a personal account to a third party’s account. Digital assets are also
subject to enhanced custodial risks associated with the unique custodial safekeeping and trading
attributes of these assets.
• DIGITAL ASSET FUTURES RISK. Clients, on an unsolicited basis, may invest in Bitcoin futures
contracts and/or may invest in other digital asset futures. Futures are financial contracts the value
of which depends on, or is derived from, the underlying asset. Futures involve the risk that changes
in their value may not move as expected relative to changes in the value of the underlying asset.
The primary risks associated with futures contracts are imperfect correlation, liquidity, volatility,
leverage, unanticipated market movement and futures commission merchants and clearinghouse
risk. Futures exchanges may limit the amount of fluctuation permitted in certain futures contract
prices during a single trading day. Once the daily limit has been reached in a futures contract
subject to the limit, no more trades may be made on that day at a price beyond that limit. The daily
limit governs only price movements during a particular trading day and therefore does not limit
potential losses because the limit may work to prevent the liquidation of unfavorable positions.
There can be no guarantee that there will be a correlation between price movements in the digital
asset futures and the underlying asset. The market for digital asset futures is relatively new and is
still developing. As a result, digital asset futures markets are thinly traded relative to other futures
markets. Trading in the cash digital asset market is more difficult as compared to more traditional
cash markets, and in particular short selling digital assets remains challenging and costly. As a result
of these features of the digital asset cash market, market makers and arbitrageurs may not be as
willing to participate in the digital asset futures market as they are in other futures markets. Each
of these factors may increase the likelihood that the price of digital asset futures will be volatile
and/or will deviate from the price of the underlying asset. Digital asset futures may experience
significant price volatility. For example, exchange specified collateral for Bitcoin futures is
substantially higher than for most other futures contracts, and collateral may be set as a
percentage of the value of the contract, which means that collateral requirements for long
positions can increase if the price of the contract rises. In addition, futures commission merchants
may require collateral beyond the exchange’s minimum requirement. Futures commission
merchants may also restrict trading activity in digital asset futures by imposing position limits,
prohibiting selling short the future or prohibiting trades where the executing broker places a trade
on behalf of another broker (so-called “give-up transactions”). Specifically, Bitcoin futures are
subject to daily limits that may impede a market participant’s ability to exit a position during a
period of high volatility. Exchanges where digital assets are traded (which are the source of the
price(s) used to determine the cash settlement amount for digital asset futures) have experienced
technical and operational issues, making digital asset prices unavailable at times. The cash market
in digital assets has been the target of fraud and manipulation, which could affect the pricing,
volatility and liquidity of the futures contracts. In addition, if settlement prices for digital asset
futures are unavailable (which may occur following a trading suspension imposed by the exchange
due to large price movements or following a fork of the digital asset, or for other reasons) or our
Firm determines such settlement prices are unreliable, the fair value of an Account’s digital asset
futures may be determined by reference, in whole or in part, to the cash market in the underlying
asset. These circumstances may be more likely to occur with respect to digital asset futures than
with respect to futures on more traditional assets.
•
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FEBRUARY 2026 | PAGE 14
RISK OF LOSS
Clients must understand that past performance is not indicative of future results. Therefore, current and
prospective clients should never assume that future performance of any specific investment or investment
strategy will be profitable. Investing in securities involves risk of loss. Further, depending on the different
types of investments, there will be varying degrees of risk. Clients and prospective clients should be
prepared to bear investment loss including loss of original principal.
Because of the inherent risk of loss associated with investing, our Firm is unable to represent, guarantee,
or even imply that our services and methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate you from losses due to market corrections or declines.
Investors should be aware that accounts are subject to the following risks:
▪ MARKET RISK - Even a long-term investment approach cannot guarantee a profit. Economic,
political, and issuer-specific events will cause the value of securities to rise or fall. Because the
value of investment portfolios will fluctuate, there is the risk that you will lose money and your
investment may be worth more or less upon liquidation.
▪
FOREIGN SECURITIES AND CURRENCY RISK - Investments in international and emerging-
market securities include exposure to risks such as currency fluctuations, foreign taxes and
regulations, and the potential for illiquid markets and political instability.
▪
CAPITALIZATION RISK - Small-cap and mid-cap companies may be hindered as a result of limited
resources or less diverse products or services Their stocks have historically been more volatile than
the stocks of larger, more established companies.
▪
INTEREST RATE RISK - In a rising rate environment, the value of fixed-income securities generally
declines, and the value of equity securities may be adversely affected.
▪
CREDIT RISK - Credit risk is the risk that the issuer of a security may be unable to make interest
payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived
change in an issuer’s financial strength may affect a security’s value and thus, impact the fund’s
performance.
▪
SECURITIES LENDING RISK - Securities lending involves the risk that the fund loses money
because the borrower fails to return the securities in a timely manner or at all. The fund could also
lose money if the value of the collateral provided for loaned securities, or the value of the
investments made with the cash collateral, falls. These events could also trigger adverse tax
consequences for the fund.
▪
EXCHANGE-TRADED FUNDS - ETFs face market-trading risks, including the potential lack of an
active market for shares, losses from trading in the secondary markets, and disruption in the
creation/redemption process of the ETF. Any of these factors may lead to the fund’s shares trading
at either a premium or a discount to its “net asset value.”
▪ PERFORMANCE OF UNDERLYING MANAGERS - We select the mutual funds and ETFs in the
asset allocation portfolios. However, we depend on the manager of such funds to select individual
investments in accordance with their stated investment strategy.
▪ ARTIFICIAL INTELLIGENCE AND MACHINE LEARNING - Certain service providers utilized by the
Firm to service client accounts have artificial intelligence components, such as our client
relationship management system that utilizes artificial intelligence to summarize client meeting
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 15
notes. The use of artificial intelligence and machine learning includes increased risk of data
inaccuracies and security vulnerabilities. Due to the rapid advancement of machine learning
technologies, future risks related to artificial intelligence are unpredictable. As a measure to
mitigate these risks to our clients, our Firm performs periodic due diligence of our service providers
for assurance that the service providers have appropriate controls in place to protect our clients’
information and to limit data inaccuracies when artificial intelligence is used by the service
provider.
▪
▪ NON-LIQUID ALTERNATIVE INVESTMENTS - From time to time, our Firm will recommend
to certain qualifying clients that a portion of such clients’ assets be invested in private funds,
private fund-of-funds and/or other alternative investments (collectively, “Nonliquid Alternative
Investments”). Nonliquid Alternative Investments are not suitable for all of our Firm’s clients and
are offered only to those qualifying clients for whom our Firm believes such an investment is
suitable and in line with their overall investment strategy. Nonliquid Alternative Investments
typically are available to only a limited number of sophisticated investors who meet the definition
of “accredited investor” under Regulation D of the Securities Act of 1933, as amended (the
“Securities Act”), or “qualified client” under the Investment Advisers Act of 1940, or “qualified
purchaser” under the Investment Company Act of 1940. Nonliquid Alternative Investments
present special risks for our Firm’s clients, including without limitation, limited liquidity, higher
fees and expenses, volatile performance, no assurance of investment returns, heightened risk of
loss, limited transparency, additional reliance on underlying management of the investment,
special tax considerations, subjective valuations, use of leverage and limited regulatory oversight.
When a Nonliquid Alternative Investment invests part or all of its assets in real estate properties,
there are additional risks that are unique to real estate investing, including but not limited to:
limitations of the appraisal value; the borrower’s financial conditions (if the underlying property
has been obtained by a loan), including the risk of foreclosures on the property; neighborhood
values; the supply of and demand for properties of like kind; and certain city, state and/or federal
regulations. Additionally, real estate investing is also subject to possible loss due to uninsured
losses from natural and man-made disasters. The above list is not exhaustive of all risks related to
an investment in Nonliquid Alternative Investments. A more comprehensive discussion of the risks
associated with a particular Nonliquid Investment is set forth in that fund’s offering documents,
which will be provided to each client subscribing to a Nonliquid Alternative Investment, for review
and consideration. It is important that each potential, qualified investor carefully read each
offering or private placement memorandum prior to investing.
STRUCTURED NOTES - Structured products are designed to facilitate highly customized risk-
return objectives. While structured products come in many different forms, they typically consist
of a debt security that is structured to make interest and principal payments based upon various
assets, rates, or formulas. Many structured products include an embedded derivative component.
Structured products may be structured in the form of a security, in which case these products may
receive benefits provided under federal securities law, or they may be cast as derivatives, in which
case they are offered in the over-the-counter market and are subject to no regulation. Investment
in structured products includes significant risks, including valuation, liquidity, price, credit, and
market risks. One common risk associated with structured products is a relative lack of liquidity
due to the highly customized nature of the investment. Moreover, the full extent of returns from
the complex performance features is often not realized until maturity. As such, structured products
tend to be more of a buy-and-hold investment decision rather than a means of getting in and out
of a position with speed and efficiency. Another risk with structured products is the credit quality
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 16
of the issuer. Although the cash flows are derived from other sources, the products themselves
are legally considered to be the issuing financial institution’s liabilities. The vast majority of
structured products are from high-investment-grade issuers only. Also, there is a lack of pricing
transparency. There is no uniform standard for pricing, making it harder to compare the net-of-
pricing attractiveness of alternative structured product offerings than it is, for instance, to compare
the net expense ratios of different mutual funds or commissions among broker-dealers.
ITEM 9 - DISCIPLINARY INFORMATION
We do not have any legal, financial or other “disciplinary” item to report.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
SUB ADVISOR/TPMM (“TPMM”) RELATIONSHIPS
Please refer to Item 4 and Item 5 above for more information about the selection of Sub-Advisor/TPMM’s
used with our services. Depending on our Agreement with the Sub-Advisor/TPMM, our Firm pays a portion
of the advisory fee to the Sub-Advisor/TPMM. A conflict of interest for our firm in utilizing a sub advisor is
receipt of discounts or services not available to us from other similar sub advisers. In order to minimize this
conflict our firm will make our recommendations and selections of Sub-Advisor/TPMMs in the best interest
of our clients.
INSURANCE
Aventine Hill, LLC, an affiliated licensed insurance agency, is under common ownership with our Firm.
Because of the common ownership with Aventine Hill, LLC there is a conflict of interest to clients because
our firm indirectly receives compensation (commissions, trails, or other compensation from the respective
insurance products) as a result of effecting insurance transactions for any mutual clients of Aventine Hill,
LLC and Palatine Hill.
Commissions generated by insurance sales do not offset regular advisory fees. Our firm has an incentive to
recommend insurance products and this incentive creates a conflict of interest between your interests and
our Firm. We mitigate this conflict by disclosing to clients they have the right to decide whether or not to
engage the services of our affiliated Insurance agency. Further, clients should note they have the right to
decide whether to act on the recommendations and the right to choose any professional to execute the
advice for any insurance products through any licensed insurance agent not affiliated with our Firm. We
recognize the fiduciary responsibility to place the client’s interests first and have established policies in this
regard to avoid any conflicts of interest.
OTHER AFFLIATIONS
Management personnel of Palatine Hill Wealth Management and Financial Advisors affiliated with Palatine
Hill Wealth Management may engage in outside business activities. As such, these individuals can receive
separate, yet customary commission compensation resulting from implementing product transactions on
behalf of investment advisory Clients. Clients may choose to invest in parallel with their investment advisor
on pooled limited partnerships. Again, Clients are not under any obligation to engage these individuals
when considering implementation of these outside recommendations. The implementation of any or all
recommendations is solely at the discretion of the Client. The following are separate but affiliated entities
under common ownership with our Firm:
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 17
Clients May Invest in Affiliated LLCs/Pooled Investments: Affiliated persons of the Firm are members
and/or managing members of various private limited pooled investment vehicles. All funds committed to
each pooled investment vehicle are for the sole purpose of the singular investment. Once the investment
inside the LLC hits liquidity, the funds will be disbursed in the pooled investment vehicle. These private
investments are not affiliated with Palatine Hill. Affiliated persons receive an allocation interest (5%) in the
LLC for putting the pooled investment vehicle together. This service includes coordinating with the Counsel,
time spent drafting subscription documents, and providing information to the accountant and various other
professionals. This is disclosed to all investors in each separate pooled investment vehicle investment
documents. Certain clients of our Firm may choose to invest (but are not solicited) in this private pooled
investment vehicle. Each entity has an account at a qualified financial institution and/or custodian, through
which investor funds are called to be deposited for the investment and then aggregated for investment into
the placement in which the pooled investment vehicle is investing. Because of the common affiliation
between the pooled investment vehicle and the Registered Investment Adviser (Palatine Hill), our Firm is
deemed to have indirect Custody and therefore subject to an annual audit by an accounting firm registered
with the Public Company Accounting Oversight Board (PCAOB). As outlined under Item 8 above, private
placements, pooled investments such as these often have no liquidity provisions and a secondary market
in which to sell your investment may not be available. Because these types of investments are not regulated,
they are not subject to reporting requirements. Investors must refer to the offering memorandum and
subscription documents for guidance on reporting, if any.
In such instances, our affiliated persons of our Firm may receive additional allocation interest as outlined
above for the administration of the LLC. While our Firm and these individuals endeavor at all times to put
the interest of the clients first as part of our fiduciary duty, clients should be aware that the receipt of
additional compensation itself creates a conflict of interest and may affect the judgment of the Firm and
these individuals when making recommendations. A listing of all outside business activities and entities for
each affiliated person of the firm is associated with can be found in the 2B Brochure for the Investment
Adviser Representative and its Form U4 filing.
OTHER BUSINESS ACTIVITIES
Clients should be aware that the ability to receive additional compensation by our Firm and its management
persons or employees creates conflicts of interest that impair the objectivity of the Firm and these
individuals when making advisory recommendations. Our Firm endeavors at all times to put the interest of
its clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps,
among others to address this conflict:
• we disclose to clients the existence of all material conflicts of interest, including the potential for
the Firm and our employees to earn compensation from advisory clients in addition to the Firm's
advisory fees;
• we disclose to clients that they have the right to decide to purchase recommended investment
products from our employees;
• we collect, maintain and document accurate, complete and relevant client background infor-
•
mation, including the client’s financial goals, objectives, and liquidity needs;
the Firm conducts regular reviews of each client advisory account to verify that all recommenda-
tions made to a client are in the best interest of the client’s needs and circumstances;
• we require that our employees seek prior approval of any outside employment activity so that we
may ensure that any conflicts of interests in such activities are properly addressed;
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 18
• we periodically monitor these outside employment activities to verify that any conflicts of interest
continue to be properly addressed by the Firm; and
• we educate our employees regarding the responsibilities of a fiduciary, including the need for hav-
ing a reasonable and independent basis for the investment advice provided to clients.
Our Firm does not have an application pending to register, as a futures commission merchant, commodity
pool operator, a commodity trading adviser, or an associated person of the foregoing entities.
Our firm nor any of its management persons are registered or have an application pending to register as a
broker-dealer or a registered representative of a broker-dealer.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING
Our Firm and persons associated with us are allowed to invest for their own accounts, or to have a financial
investment in the same securities or other investments that we recommend or acquire for your account,
and may engage in transactions that are the same as or different than transactions recommended to or
made for your account. This creates a conflict of interest. We recognize the fiduciary responsibility to act in
your best interest and have established polices to mitigate conflicts of interest.
We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our
advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things,
personal trading, gifts, and the prohibition against the use of inside information.
The Code of Ethics is designed to protect our clients to detect and deter misconduct, educate personnel
regarding the Firm’s expectations and laws governing their conduct, remind personnel that they are in a
position of trust and must act with complete propriety at all times, protect the reputation of Palatine Hill,
safeguard against the violation of the securities laws, and establish procedures for personnel to follow so
that we may determine whether their personnel are complying with the Firm’s ethical principles.
We have established the following restrictions in order to ensure our Firm’s fiduciary responsibilities:
▪ A director, officer, or employee of Palatine Hill shall not buy or sell any securities for their personal
portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her
employment unless the information is also available to the investing public on reasonable inquiry
No supervised employee of Palatine Hill shall prefer his or her own interest to that of the advisory
client. Trades for supervised employees are traded alongside client accounts
▪ We maintain a list of all securities holdings of anyone associated with this advisory practice with
access to advisory recommendations. These holdings are reviewed on a regular basis by an
appropriate officer/individual of Palatine Hill
▪ We emphasize the unrestricted right of the client to decline implementation of any advice
rendered, except in situations where we are granted discretionary authority of the client’s account
▪ We require that all supervised employees must act in accordance with all applicable Federal and
State regulations governing registered investment advisory practices
▪ Any supervised employee not in observance of the above may be subject to termination.
INVESTMENT POLICY
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 19
None of our associated persons may affect for himself/herself or for accounts in which he/she holds a
beneficial interest, any transactions in a security which is being actively recommended to any of our clients,
unless in accordance with the Firm’s procedures.
You may request a complete copy of our Code by contacting us at the address, telephone, or email on the
cover page of this Part 2; ATTN: Charles Dabrowski, Chief Compliance Officer.
ITEM 12 - BROKERAGE PRACTICES
Clients must maintain assets in an account at a “qualified custodian,” generally a broker-dealer or bank. We
generally recommend that our clients use Charles Schwab & CO. Inc. (“Schwab”) or Interactive Brokers, LLC
(“Interactive Brokers”), collectively, referred to as the “Custodians”. The Custodians are members of
FINRA/SIPC and are independent and unaffiliated SEC-registered broker-dealers. The Custodians offer
services to independent investment advisors that include custody of securities, trade execution, clearance
and settlement of transactions. Advisor receives some benefits from the Custodians through its
participation in the program. (Please see the disclosure under Item 14 below.)
There is no direct link between our participation in the program and the investment advice we give to our
clients, although we receive economic benefits through our participation in the program that are typically
not available to any other independent investment advisors participating in the program. These benefits
include the following products and services (provided without cost or at a discount): receipt of duplicate
Client statements and confirmations; research related products and tools; consulting services; access to a
trading desk serving advisor participants; access to block trading (which provides the ability to aggregate
securities transactions for execution and then allocate the appropriate shares to Client accounts); the ability
to have advisory fees deducted directly from Client accounts; access to an electronic communications
network for Client order entry and account information; access to mutual funds with no transaction fees
and to certain institutional money managers; and discounts on compliance, marketing, research,
technology, and practice management products or services provided to us by third party vendors. Some of
the products and services made available by the Custodians through the program may benefit us but may
not benefit your account. These products or services may assist us in managing and administering your
account, including accounts not maintained at Schwab or Interactive Brokers. Other services made
available by the Custodians are intended to help us manage and further develop our business enterprise.
The benefits received by our Firm or our personnel through participation in the program do not depend on
the amount of brokerage transactions directed to Schwab or Interactive Brokers. As part of our fiduciary
duties to clients, we endeavor at all times to put the interests of our clients first. You should be aware,
however, that the receipt of economic benefits by our Firm or our related persons in and of itself creates a
conflict of interest and may indirectly influence our choice of the Custodians for custody and brokerage
services.
In the event you request us to recommend a broker/dealer custodian for execution and/or custodial
services, we generally recommend your account to be maintained at Schwab or Interactive Brokers. We
may recommend that you establish accounts with the Custodians to maintain custody of your assets and to
effect trades for your accounts. You are under no obligation to act upon any recommendations, and if you
elect to act upon any recommendations, you are under no obligation to place the transactions through any
broker/dealer we recommend. Our recommendation is generally based on the broker’s cost and fees, skills,
reputation, dependability and compatibility with the client. You may be able to obtain lower commissions
PALATINE HILL WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 20
and fees from other brokers and the value of products, research and services given to us is not a factor in
determining the selection of broker/dealer or the reasonableness of their commissions.
Some of the products, services, and other benefits provided by the Custodians benefit Palatine Hill and may
not benefit our client accounts. Our recommendation or requirement that you place assets in the
Custodian's custody may be based in part on benefits the Custodians provide to us, or our agreement to
maintain certain Assets Under Management at the Custodians, and not solely on the nature, cost, or quality
of custody and execution services provided by the Custodians.
We place trades for our clients' accounts subject to its duty to seek best execution and its other fiduciary
duties. TDA's execution quality may be different than other broker-dealers.
We will aggregate trades for ourselves or our associated persons with your trades, providing that the
following conditions are met:
• Our policy for the aggregation of transactions shall be fully-disclosed separately to our existing
clients (if any) and the broker/dealer(s) through which such transactions will be placed
• We will not aggregate transactions unless we believe that aggregation is consistent with our duty
to seek the best execution (which includes the duty to seek best price) for you and is consistent
with the terms of our investment advisory agreement with you for which trades are being
aggregated
• No advisory client will be favored over any other client; each client that participates in an
aggregated order will participate at the average share price for all our transactions in a given
security on a given business day, with transaction costs based on each client’s participation in the
transaction
• We will prepare a written statement (“Allocation Statement”) specifying the participating client
•
accounts and how to allocate the order among those clients
If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with
the allocation statement; if the order is partially filled, the accounts that did not receive the
previous trade’s positions should be “first in line” to receive the next allocation
• Notwithstanding the foregoing, the order may be allocated on a basis different from that specified
in the Allocation Statement if all client accounts receive fair and equitable treatment and the
reason for difference of allocation is explained in writing and is reviewed by our compliance officer.
Our books and records will separately reflect, for each client account, the orders of which
aggregated, the securities held by, and bought for that account
• We will receive no additional compensation or remuneration of any kind as a result of the
•
proposed aggregation; and
Individual advice and treatment will be accorded to each advisory client.
BROKERAGE FOR CLIENT REFERRALS
Our Firm does not receive client referrals from any custodian or third party in exchange for using that
broker-dealer or third party.
AGGREGATION AND ALLOCATION OF TRANSACTIONS
We may aggregate transactions if we believe that aggregation is consistent with the duty to seek best
execution for our clients and is consistent with the disclosures made to clients and terms defined in the
client investment advisory agreement. No advisory client will be favored over any other client, and each
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account that participates in an aggregated order will participate at the average share price (per custodian)
for all transactions in that security on a given business day.
If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro rata basis.
If we determine that a pro rata allocation is not appropriate under the particular circumstances, we will
base the allocation on other relevant factors, which may include:
▪ When only a small percentage of the order is executed, with respect to purchase allocations,
allocations may be given to accounts high in cash
▪ With respect to sale allocations, allocations may be given to accounts low in cash
▪ We may allocate shares to the account with the smallest order, or to the smallest position, or to
an account that is out of line with respect to security or sector weightings, relative to other
portfolios with similar mandates
▪
▪
▪ We may allocate to one account when that account has limitations in its investment guidelines
prohibiting it from purchasing other securities that we expect to produce similar investment
results and that can be purchased by other accounts in the block
If an account reaches an investment guideline limit and cannot participate in an allocation, we may
reallocate shares to other accounts. For example, this may be due to unforeseen changes in an
account’s assets after an order is placed
If a pro rata allocation of a potential execution would result in a de Minimis allocation in one or
more accounts, we may exclude the account(s) from the allocation
▪ We will document the reasons for any deviation from a pro rata allocation.
TRADE ERRORS
We have implemented procedures designed to prevent trade errors; however, trade errors in client
accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade
errors in a manner that is in the best interest of the client. In cases where the client causes the trade error,
the client will be responsible for any loss resulting from the correction. Depending on the specific
circumstances of the trade error, the client may not be able to receive any gains generated as a result of
the error correction. In all situations where the client does not cause the trade error, the client will be made
whole and we will absorb any loss resulting from the trade error if the error was caused by the Firm. If the
error is caused by the Custodian, the Custodian will be responsible for covering all trade error costs. If an
investment gain results from the correcting trade, the gain will be donated to charity. We will never benefit
or profit from trade errors.
DIRECTED BROKERAGE
We do not routinely recommend, request, or require that you direct us to execute transaction through a
specified broker dealer. Additionally, we typically do not permit you to direct brokerage. We place trades
for your account subject to our duty to seek best execution and other fiduciary duties.
ITEM 13 - REVIEW OF ACCOUNTS
ACCOUNT REVIEWS AND REVIEWERS – INVESTMENT SUPERVISORY SERVICES
Our Investment Adviser Representatives will monitor client accounts on a regular basis and perform annual
reviews with each client. All accounts are reviewed for consistency with client investment strategy, asset
allocation, risk tolerance, and performance relative to the appropriate benchmark. More frequent reviews
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may be triggered by changes in an account holder’s personal, tax, or financial status. Geopolitical and
macroeconomic specific events may also trigger reviews.
STATEMENTS AND REPORTS
The custodian for the individual client’s account will provide clients with an account statement at least
quarterly. Upon request, clients can receive Palatine Hill prepared written report detailing their current
positions, asset allocation, and year-to-date performance. You are urged to compare the reports and
invoices provided by our Firm against the account statements you receive directly from your account
custodian.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
We previously disclosed in the “Brokerage Practices” section (Item 12) of this Brochure that our firm
participates in institutional investment adviser programs offered by Schwab and Interactive Brokers and
may, as a result, receive economic benefits from them that relate to our provision of investment advice or
advisory services to clients.
Our Firm neither accepts nor pays fees for client referrals. Further, we do not have any compensation
arrangements other than what is disclosed in this Brochure.
Our Firm may be asked to recommend a financial professional, such as an attorney, accountant, or
mortgage broker. In such cases, our Firm does not receive any direct compensation in return for any
referrals made to individuals or firms in our professional network. Clients must independently evaluate
these firms or individuals before engaging in business with them and clients have the right to choose any
financial professional to conduct business. Individuals and firms in our financial professional network may
refer clients to our Firm. Again, our Firm does not pay any direct compensation in return for any referrals
made to our Firm. Our Firm does recognize the fiduciary responsibility to place your interests first and have
established policies in this regard to mitigate any conflicts of interest.
ITEM 15 – CUSTODY
Custody has been defined by regulators as having access or control over client funds and/or securities. Our
firm does not have physical custody of funds or securities, as it applies to investment advisors.
Per SEC regulations, our Firm is deemed, under Rule 206(4)-2 of the Investment Advisers Act to have custody
by virtue of the common control of our Firm and the Limited Partnership investments held by our affiliated
persons and select clients as described in Item 10 of this Brochure. Partners of pooled investment vehicle
will be provided with annual financial statements audited by an independent public accounting firm
registered with the Public Company Accounting Oversight Board (PCAOB). The SEC requires that firms who
have custody for the reasons listed above are subject to an annual surprise audit to be conducted by an
independent CPA firm which is registered with and subject to regular inspection by the Public Company
Accounting Oversight Board (PCAOB). We have complied with the requirements concerning such surprise
audits and will continue to do so in the future.
DEDUCTION OF ADVISORY FEES
For all accounts, our Firm has the authority to have fees deducted directly from client accounts. Our Firm
has established procedures to ensure all client funds and securities are held at a qualified custodian in a
separate account for each client under that client’s name. Clients, or an independent representative of the
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client, will direct, in writing, the establishment of all accounts and therefore are aware of the qualified
custodian’s name, address, and the manner in which the funds or securities are maintained. Finally, account
statements are delivered directly from the qualified custodian to each client, or the client’s independent
representative, at least quarterly. You should carefully review those statements and are urged to compare
the statements against reports received from Palatine Hill. When you have questions about your account
statements, you should contact Palatine Hill or the qualified custodian preparing the statement.
Please refer to Item 5 for more information about the deduction of advisor fees.
STANDING LETTERS OF AUTHORIZATION (“SLOA”)
Our Firm is deemed to have custody of clients’ funds or securities when clients have standing authorizations
with their custodian to move money from a client’s account to a third-party (“SLOA”) and, under that SLOA,
it authorizes us to designate the amount or timing of transfers with the custodian. The SEC has set forth a
set of standards intended to protect client assets in such situations, which we follow. We do not have a
beneficial interest on any of the accounts we are deemed to have Custody where SLOAs are on file. In
addition, account statements reflecting all activity on the account(s), are delivered directly from the
qualified custodian to each client or the client’s independent representative, at least quarterly. You should
carefully review those statements and are urged to compare the statements against reports received from
us. When you have questions about your account statements, you should contact us, your Advisor or the
qualified custodian preparing the statement.
ITEM 16 – INVESTMENT DISCRETION
For discretionary accounts, prior to engaging Palatine Hill to provide investment advisory services, you will
enter a written Agreement with us granting the Firm the authority to supervise and direct, on an on-going
basis, investments in accordance with the client’s investment objective and guidelines. In addition, you will
need to execute additional documents required by the Custodian to authorize and enable Palatine Hill, in
its sole discretion, without prior consultation with or ratification by you, to purchase, sell, or exchange
securities in and for your accounts. We are authorized, in our discretion and without prior consultation with
you to: (1) buy, sell, exchange and trade any stocks, bonds or other securities or assets and (2) determine
the amount of securities to be bought or sold, and (3) place orders with the custodian. Any limitations to
such discretionary authority will be communicated to our Firm in writing by you, the client.
The limitations on investment and brokerage discretion held by Palatine Hill for you are:
▪
For discretionary accounts, we require that we be provided with authority to determine which
securities and the amounts of securities to be bought or sold.
▪ Any limitations on this discretionary authority shall in writing as indicated on the investment
advisory Agreement. You may change/amend these limitations as required.
In some instances, we may not have discretion. We will discuss all transactions with you prior to execution
or you will be required to make the trades if in an employer sponsored account.
ITEM 17 – VOTING CLIENT SECURITIES
We will not vote proxies on your behalf. You are welcome to vote proxies or designate an independent
third-party at your own discretion. You designate proxy voting authority in the custodial account
documents. You must ensure that proxy materials are sent directly to you or your assigned third party. We
do not take action with respect to any securities or other investments that become the subject of any legal
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FEBRUARY 2026 | PAGE 24
proceedings, including bankruptcies. Clients can contact our office with questions about a particular
solicitation by phone at 313-570-8084
ITEM 18 – FINANCIAL INFORMATION
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in
advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are
not subject to a financial condition that is reasonably likely to impair our ability to meet contractual
commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time.
PRIVACY POLICY
Our Firm collects nonpublic personal information about Clients from information provided on applications
or other forms, as well as from information regarding Client transactions with our Firm, our affiliates, or
others. In accordance with Regulation S-P, our Firm does not disclose any nonpublic personal information
about current or former Clients to third parties, except as permitted or required by law, or as necessary to
service Client accounts. Access to Client information is restricted to Firm personnel who require such
information to provide investment advisory services. Our Firm maintains physical, electronic, and
procedural safeguards designed to protect Client information in compliance with federal standards and
Regulation S-P. Our Firm provides a copy of its Privacy Policy to Clients at the time of account opening,
upon request, and annually if the Policy is amended.
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