Overview

Total Firm Assets
$129 million
Average High-Net-Worth Client Portfolio Size
$2.3 million

Fee Structure

Primary Fee Schedule (PATINA WEALTH LLC DISCLOSURE BROCHURE)

MinMaxMarginal Fee Rate
$0 $250,000 1.25%
$250,001 $2,000,000 1.00%
$2,000,001 $3,000,000 0.90%
$3,000,001 and above 0.70%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,625 1.06%
$5 million $43,625 0.87%
$10 million $78,625 0.79%
$50 million $358,625 0.72%
$100 million $708,625 0.71%

Clients

High-Net-Worth Share of Firm Assets
62.77%
Number of High-Net-Worth Clients
35
Total Client Accounts
356
Discretionary Accounts
351
Non-Discretionary Accounts
5

Services Offered

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

Regulatory Filings

SEC CRD Number
283813

Primary Brochure: PATINA WEALTH LLC DISCLOSURE BROCHURE (2026-06-29)

View Document Text
Patina Wealth LLC d/b/a Patina Wealth 3190 Court Mont Way Crozet, VA 22932 Telephone: 434-282-4284 www.patinawealth.com June 29, 2026 FORM ADV PART 2A BROCHURE This brochure provides information about the qualifications and business practices of Patina Wealth. If you have any questions about the contents of this brochure, contact us at 434-282-4284. 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. Additional information about Patina Wealth (CRD# 283813) is available on the SEC's website at www.adviserinfo.sec.gov. Patina Wealth is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1 Item 2 Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. This version of Patina Wealth’s Brochure, dated June 29, 2026, is an interim amendment to our Brochure filed in connection with our application for registration as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”). It contains the following material changes since our last filing on March 30, 2026: • Patina Wealth has applied to register as an investment adviser with the SEC and will withdraw its Commonwealth of Virginia investment adviser registration upon approval. As a result, the Firm is transitioning from state regulation to regulation by the SEC. Item 19 (Requirements for State-Registered Advisers) has been removed because it no longer applies, and the Firm has prepared a Form CRS (Client Relationship Summary) for delivery to retail investors. 2 Item 3 Table of Contents Item 2 Material Changes ....................................................................................................... 2 Item 3 Table of Contents ....................................................................................................... 3 Item 4 Advisory Business ...................................................................................................... 4 Item 5 Fees and Compensation ............................................................................................ 9 Item 6 Performance-Based Fees and Side-By-Side Management ..................................... 12 Item 7 Types of Clients ....................................................................................................... 12 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................. 12 Item 9 Disciplinary Information ............................................................................................ 15 Item 10 Other Financial Industry Activities and Affiliations ................................................. 15 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................................................................................................................................ 15 Item 12 Brokerage Practices ............................................................................................... 16 Item 13 Review of Accounts ................................................................................................ 20 Item 14 Client Referrals and Other Compensation ............................................................. 21 Item 15 Custody .................................................................................................................. 21 Item 16 Investment Discretion ............................................................................................. 21 Item 17 Voting Client Securities .......................................................................................... 22 Item 18 Financial Information .............................................................................................. 22 3 Item 4 Advisory Business Description of the Firm Patina Wealth LLC is a Virginia domiciled limited liability company formed in March of 2016. Patina Wealth LLC may be referred to herein as “Patina Wealth” or the “Firm” or “us” or “we”. Our principal office is located in Crozet, Virginia and we have a branch office located in Richmond, Virginia. We typically operate under the trade name Patina Wealth. Our firm is not a subsidiary of nor does it control another reportable financial industry entity. Patina Wealth is registered as an investment adviser with the SEC. The Firm was previously registered as an investment adviser with the Commonwealth of Virginia in June of 2016 and converted to SEC registration because its regulatory assets under management exceed $100 million. Patina Wealth and its associates may register, become licensed, make notice filings, or meet certain exemptions to registration and/or licensing within other jurisdictions where investment advisory business may be conducted. Samuel Carter Harris is the firm's Principal and Chief Compliance Officer (supervisor). He is also Managing Member and maintains controlling interest in the firm. Description of Services Offered Patina Wealth's financial planning services provide clients with advice on key topics such as cash flow and budgeting, funding a college education, retirement planning, risk management, estate or tax planning, among others. Ongoing and continuous supervision of clients' portfolios are provided through our portfolio management services, which includes the management of certain clients under ERISA Section 3(38). We also provide educational workshops involving a broad range of financial planning and investing topics. An initial interview is conducted by a representative of our firm to discuss your current situation, goals and the scope of services that may be provided to you. During or prior to this meeting you will be provided with our Form ADV Part 2 firm brochure that includes a statement involving our privacy policy, as well as a brochure supplement about the representative who will be assisting you. We will also ensure that any material conflicts of interest have been disclosed to you that could be reasonably expected to impair the rendering of unbiased and objective advice. If you choose to engage Patina Wealth for its services, you must first execute our client engagement agreement. Thereafter discussion and analysis will be conducted to determine your financial needs, goals, holdings, risk tolerance, and financial circumstances. Depending on the scope of the engagement, you may be asked to provide copies of the following documents early in the process: • Wills, codicils and trusts • Insurance policies • Mortgage information • Student loan data • Divorce decree or separation agreement • Tax returns • Current financial specifics including W-2s or 1099s • Information on current retirement plans and benefits provided by your employer • Statements reflecting current investments in retirement and non-retirement accounts • Employment or other business agreements you may have in place • Completed risk profile questionnaires or other forms provided by our firm 4 It is important that we are provided with an adequate level of information and supporting documentation throughout the term of the engagement including but not limited to: source of funds, income levels, and an account holder or attorney-in-fact's authority to act on behalf of the account, among other information that may be necessary for our services. The information and/or financial statements provided to us need to be accurate. Our firm may, but is not obligated to, verify the information that you have provided to us which will then be used in the advisory process. It is essential that you inform our firm of significant issues that may call for an update to their plan. Events such as changes in employment or marital status, an unplanned windfall, etc., can have an impact on your circumstances and plans. Our firm needs to be aware of such events so that adjustments may be made as necessary. Financial Planning Our customized financial planning may be as broad-based or narrowly focused as you desire. The incorporation of most or all of the listed components allows not only a thorough analysis but also a refined focus of your plans so that the firm is able to assist you in reaching your goals and objectives. Cash Flow Analysis and Debt Management A review of your income and expenses will be conducted to determine your current surplus or deficit. Based upon the results, we will provide advice on prioritizing how any surplus should be used, or how to reduce expenses if they exceed your income. In addition, advice on the prioritization of which debts to repay may be provided, based upon such factors as the debt's interest rate and any income tax ramifications. Recommendations may also be made regarding the appropriate level of cash reserves for emergencies and other financial goals. These recommendations are based upon a review of cash accounts (such as money market funds) for such reserves and may include strategies to save desired reserve amounts. 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"). Employee Benefits A review is conducted and analysis is made as to whether you, as an employee, are taking maximum advantage of your employee benefits. We will also offer advice on your employer-sponsored retirement plan and/or stock options, along with other benefits that may be available to you. Personal Retirement Planning Retirement planning services typically include projections of your likelihood of achieving your financial goals, with financial independence usually the primary objective. For situations where projections show less than the desired results, a recommendation may include showing you the impact on those projections by making changes in 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. Education Planning Advice involving college funding may include projecting the amount that will be needed to achieve post-secondary education funding goals, along with savings strategies and the "pros-and-cons" of 5 various college savings vehicles that are available. We are also available to review your financial picture as it relates to eligibility for financial aid or the best way to contribute to family members, such as grandchildren, if appropriate. Tax Strategies Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, recommendations may be offered as to 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. Estate Planning Our review typically 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. We may assess ways to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We generally 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 prior approval. Divorce Planning Separation or divorce can have a major impact on your goals and plans. We will work with you to help you gain an understanding of your unique situation and provide you with a realistic financial picture so that you are in a better situation to communicate with legal counsel, a mediator or soon to be ex- spouse. We can assist in the completion of cash flow and net worth projections, budgetary analysis, as well as help you to understand what the consequences and/or benefits are involving a settlement. Investment Consultation Investment consultation services often involve providing information on the types of investment vehicles available, employee retirement plans and/or stock options, investment analysis and strategies, asset selection and portfolio design, as well as limited assistance if your investment account is maintained at another broker/dealer or custodian. The strategies and types of investments that may be recommended are further discussed in Item 8 of this brochure. Business Consultation We are available to assist small businesses in a variety of ways to include business strategy, practice management, general financial advice, debt management, as well as assisting you with matters involving coordination with your financial institution, retirement plan advisor, and attorney or accounting firm. Broad-Based v. Modular Financial Planning A broad-based plan is an endeavor that requires detail. Certain variables can affect the development of the plan, such as the quality of your own records, complexity and number of current investments, diversity of insurance products and employee benefits you currently hold, size of the potential estate, and special needs of the client or their dependents, among others. At your request we may concentrate on reviewing only a specific area (modular planning), such as an employer retirement plan allocation, funding an education or estate planning issues, or evaluating the sufficiency of your current retirement plan. Note that when we focus only on certain areas of your interest or need, your overall situation or needs may not be fully addressed due to limitations you may have established. Whether we have created a broad-based or modular plan, we will present you with a 6 summary of our recommendations, guide you in the implementation of some or all of them per your decision, as well as offer you periodic reviews thereafter. In all instances you retain full discretion over all implementation decisions and are free to accept or reject any recommendation we make. Educational Workshops Our firm provides periodic complimentary educational seminar sessions for those desiring information on personal finance and investing. Topics may include issues related to general financial planning, educational funding, estate planning, retirement strategies, implications involving changes in marital status, and various other current economic or investment topics. Our workshops are educational in nature and do not involve the sale of investment products. Portfolio Management Services We evaluate the information you have provided to us, including your investment objectives, time horizon, tolerance for risk, and financial circumstances and use the information to develop a customized portfolio for you based on your unique situation. You may be asked to review and provide your final approval on the portfolio before we implement it. You may impose reasonable restrictions related to investing in certain securities or types of securities in writing. We will make every effort to comply with your wishes but cannot guarantee absolute adherence due to the use of model portfolios, indexed products, funds, and ETFs. If we are not able to honor your request due to the nature of the investments, the make-up of the model portfolio, or because the restriction prevents us from properly servicing your portfolio, we will notify you accordingly, both you and Patina Wealth have the right to terminate the relationship. We manage your portfolio on a discretionary or non-discretionary basis (defined in Item 16). We want to note that it will remain your responsibility to promptly notify us if there is any change in your financial situation and/or investment objectives for the purpose of our reviewing, evaluating or revising previous account restrictions or firm investment recommendations. 401Ks, Pension and Profit-Sharing Plans We provide discretionary investment advisory services to certain Clients under ERISA Section 3(38). As a discretionary investment manager, Patina Wealth provides ongoing and continuous discretionary investment management with respect to the asset classes and investment alternatives available under the Plan in accordance with the investment policy statement ("IPS"). Under this authority, we will select, retain, remove and/or replace the investment alternatives available under the Plan in its sole discretion without the Client’s prior approval. We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as: • Diversification • Asset allocation • Risk tolerance • Time horizon We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. 7 Types of Investments We primarily offer advice on exchange traded funds ("ETFs") and mutual funds. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Wrap Fee Program Our firm does not sponsor or serve as a portfolio manager in an investment program involving wrapped (bundled) fees. IRA Rollover Considerations As part of our investment advisory services, we may recommend that you withdraw assets from your employer's retirement plan and roll them over into an individual retirement account ("IRA") that we manage. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code. This means we are legally obligated to act in your best interest and not put our interests ahead of yours. However, this recommendation to rollover presents an inherent conflict of interest because our firm earns an asset- based fee for managing IRAs, creating an incentive for us to advise rollovers as this increases our assets under management and, in turn, our advisory fees. Therefore, we operate under specific Department of Labor rules, requiring us to: follow policies and procedures designed to ensure advice is in your best interest; • meet a professional standard of care when making investment recommendations; • never put our financial interests ahead of yours; • avoid misleading statements; • • charge no more than reasonable fees; and • give you basic information about conflicts of interest. When considering whether to roll over retirement assets, it is important to evaluate all available options and their respective costs and benefits. You should consider the following options: • Leaving funds in your current (or former) employer's plan. • Moving funds to a new employer’s retirement plan. • Cashing out and taking a taxable distribution from the plan. • Rolling funds into an IRA rollover account. Each of these options presents distinct advantages and disadvantages, and we strongly encourage you to consult with your CPA and/or tax attorney before making any decisions. 1. Investment Options: Evaluate whether the investment options within your employer's retirement plan adequately meet your needs or if you desire a broader range of investment choices. o Employer retirement plans usually provide a smaller range of investment options compared to IRAs. o Conversely, employer plans may offer unique investment options not publicly available, such as employer securities or previously closed funds. 2. Fees and Costs: Your current plan may have lower fees compared to our advisory fees. o If you are primarily interested in mutual fund investments, compare the cost structure of share classes available in your employer's plan with those available in an IRA. o Understand the various products, services, and associated costs offered by IRA 8 providers. 3. Investment Strategy and Risk: Our investment strategy for an IRA may carry a higher risk profile than the investment options within your current plan. 4. Financial Advice: Determine if your current plan provides access to financial advice services. 5. Required Minimum Distributions (RMDs): Keeping assets in a 401(k) or retirement account may allow you to potentially delay required minimum distributions beyond age 72, depending on your specific circumstances and plan rules. 6. Liability Protection: A 401(k) may offer greater protection from creditors than a rollover IRA, although legal protections can vary by state. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have also generally been protected in bankruptcies. However, exceptions may exist, and you should consult with an attorney if creditor protection is a significant concern. 7. Loan Options: You may be able to take out a loan from your 401(k), which is not an option with an IRA. 8. Accessibility and Tax Implications: IRA assets are generally accessible at any time; however, distributions are subject to ordinary income tax and may incur a 10% early distribution penalty unless an exception applies (e.g., disability, higher education expenses, or first-time home purchase). 9. Company Stock: If your plan holds company stock, you might be able to liquidate those shares at a potentially lower capital gains tax rate compared to ordinary income tax rates. 10. Manager Options within Existing Plan: Inquire whether your plan permits you to hire our firm as your investment manager while keeping the assets titled within the plan name. Be assured that despite this conflict, we only recommend a rollover when we have a reasonable basis to believe it is in your best interest. You are under no obligation to complete a rollover, and if you do, you are not required to have the IRA managed by our firm. If you are contemplating rolling over your retirement funds to an IRA for our management, please consider the following points: Client Assets Under Management As of December 31, 2025, we provide continuous management services for $119,137,755 in client assets on a discretionary basis, and $10,034,114 in client assets on a non-discretionary basis. Item 5 Fees and Compensation Portfolio Management Services Our portfolio management service clients are an annualized asset-based fee per based on the average daily balance during the previous quarter per the Fee Schedule below. Fees are charged quarterly, in arrears. Using an average daily balance allows our firm to readily adjust for additions and withdrawals, as well as mid-cycle account openings or closures. For the benefit of discounting your asset-based fee, we will attempt to aggregate accounts for the same individual or two or more accounts within the same household. We bill on a quarterly basis, in arrears, per the following table. Method of Compensation and Fee Schedule: Assets Under Management Annualized Asset-Based Fee First $0 - $249,999 Next $250,000 - $1,999,999 Next $2,000,000 - $2,999,999 Next $3,000,000 - Above 1.25% (125 basis points) 1.00% (100 basis points) 0.90% (90 basis points) 0.70% (70 basis points) 9 The asset-based fee is based on a blended tier; for example, a client's portfolio with $750,000 in assets would be assessed an annualized fee of 125 basis points for the first $249,999 and 100 basis points on the remaining amount. Forms of payment are based on the types of services being provided, term of service, etc., and will be stated in your engagement agreement with our firm. Published fees may be discounted at the discretion of our firm but they are not generally negotiable. Fees are to be paid by check or draft from US-based financial institutions. With your prior authorization payment may also be made through a qualified, unaffiliated PCI compliant1 third-party processor, or withdrawal from your investment account held at your custodian of record. Payment requests for our advisory fees will be preceded by our invoice, and fees paid to our firm will be noted in your account statement you will receive from your custodian. Our firm does not accept cash, money orders or similar forms of payment for its engagements. Accounts will be assessed in accordance with asset values disclosed on the statement the client will receive from the custodian of record for the purpose of verifying the computation of the advisory fee. In the rare absence of a reportable market value, our firm may seek a third-party opinion from a recognized industry source (e.g., unaffiliated public accounting firm), and the client may choose to separately seek such an opinion at their own expense as to the valuation of "hard-to-price" securities if necessary. Your first billing cycle will begin once your agreement is executed with our firm and assets have settled into your account held by the custodian of record. Fee payments will generally be assessed within the first 10 days of each month. We will concurrently send you and the custodian of record a written notice ("invoice") each period that describes the advisory fees to be deducted from your account at our request. This notice will be delivered prior to the deduction of fees. Your notice will include the total fee assessed, covered time period, calculation formula utilized, and reference to the assets under management in which the fee had been based. We encourage you to verify the accuracy of fee calculations; the custodian may not verify the accuracy of advisory fee assessments for you. By signing our firm's engagement agreement, as well as the selected custodian account opening documents, you will be authorizing the withdrawal of our advisory fees from your account. The withdrawal will be accomplished by the custodian of record at the request of our firm, and the custodian will remit our fee directly to our firm. All fees deducted will be clearly noted on account statements that you will receive directly from the custodian of record. Alternatively, you may request to directly pay our advisory firm its portfolio management fee in lieu of having the advisory fee withdrawn from your investment account. Our valuation assessment will remain the same as described above, and the client's direct payment must be received by our firm within 10 days of our invoice. 401Ks, Pension and Profit-Sharing Plans Our advisory fee for these customized services is up to 0.50% of the market value of the Plan assets under our management and will be negotiated with the plan sponsor or named fiduciary. Where the firm is compensated as a percentage of assets, this fee is assessed as part of the administrative fee which is assessed to all participants in the plan by the record keeper or custodian. 1 For an explanation of the term “PCI,” who the PCI Security Standards Council is, as well as its comprehensive standards to enhance payment card data security, please go to https://www.pcisecuritystandards.org/security_standards/index.php 10 Our fees are charged quarterly in arrears based on the market value of all assets at the end of the billing period, as agreed to in writing with the plan sponsor. Assets under management for a partial quarter at the commencement of an agreement will be pro-rated based on the number of days the account was open during the quarter. You may terminate the portfolio management agreement for pension and profit-sharing plans upon 30 days written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. Education Workshops We believe every client should have a basic knowledge and understanding of their goals and objectives, as well as a foundation -- their plan. As such, we do not charge a fee for our educational workshops. Financial Planning Financial planning services are offered to clients as part of our wealth management service at no additional charge. For individuals or households that are not Patina Wealth clients, we offer financial planning for a flat fee of $750.00. Client will receive an invoice for the financial planning upon the completion of the financial plan. Additional Client Fees Any transactional or service fees (sometimes termed brokerage fees), individual retirement account fees, qualified retirement plan fees, account termination fees, or wire transfer fees will be borne by the account holder and per the separate fee schedule of the custodian of record. We will ensure you receive a copy of our custodian's fee schedule at the beginning of the engagement, and you will be notified of any future changes to these fees by the custodian of record and/or third-party administrator for certain tax-qualified plans. Fees paid by our clients to our firm for our services are separate from any internal fees or other charges involving mutual funds, exchange-traded funds (ETFs), exchange- traded notes (ETNs), or other similar investments. Per annum interest at the current maximum statutory rate may be assessed on fee balances due more than 30 days; we may refer past due accounts to collections or legal counsel for processing. We reserve the right to suspend some or all services once an account is deemed past due. Additional information about our fees in relationship to our brokerage and operational practices are referenced in Items 12 and 14 of this document. External Compensation for the Sale of Securities to Clients Our firm does not charge or receive a commission or a mark-up on securities transactions, nor will the firm or an associate be paid a commission on the purchase of a securities holding that is recommended to a client. We do not receive "trailer" or SEC Rule 12b-1 fees from an investment company that may be recommended to a client. Fees charged by such issuers are detailed in prospectuses or product descriptions and interested investors are always encouraged to read these documents before investing. Our firm and its associates receive none of these described or similar fees or charges. Our clients have the right to purchase recommended or similar investments through their own service provider. 11 Termination of Services Either party may terminate the agreement at any time by communicating the intent to terminate in writing. If you verbally notify our firm of the termination and, if in two business days following this notification, we have not received your notice in writing, we will make a written notice of the termination in our records and send you our own termination notice as a substitute. Our firm will not be responsible for investment allocation, advice or transactional services (except for limited closing transactions) upon receipt of a termination notice. It will also be necessary that we inform the custodian of record and/or third-party investment manager that the relationship between parties has been terminated. If a client did not receive our Form ADV Part 2 firm brochure at least 48 hours prior to entering into the firm's agreement, then that client will have the right to terminate the engagement without fee or penalty within five business days after entering into the agreement. Should a client terminate our services after this five-day period, the client will be assessed fees on a per-day prorated basis for services incurred from either (i) as a new client, the date of the engagement to the date of the firm's receipt of the written notice of termination, or (ii) all other accounts, the last billing period to the date of the firm's physical or constructive receipt of written termination notice. Item 6 Performance-Based Fees and Side-By-Side Management Our firm's advisory fees will not be based on a share of capital gains or capital appreciation (growth) of any portion of managed funds, also known as performance-based fees. Our fees will also not be based on side-by-side management, which refers to a firm simultaneously managing accounts that do pay performance-based fees (such as a hedge fund) and those that do not. Item 7 Types of Clients Patina Wealth provides advisory services to individuals and high net worth individuals of all investment experience, as well as, pension and profit sharing plans, businesses of all scale, and charitable organizations. We do not require minimum income, minimum asset levels or other similar preconditions. We reserve the right to waive or reduce certain fees based on unique individual circumstances, special arrangements or preexisting relationships. Our firm reserves the right to decline services to any prospective client for any nondiscriminatory reason. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We employ fundamental analysis; evaluating economic factors including interest rates, the current state of the economy, or the future growth of an industry sector. Our research is drawn from sources that include financial periodicals, as well as reports from economists and other industry professionals. Investment Strategies Our firm believes that a long term, buy-and-hold investment strategy with periodic rebalancing is preferred over most active investment strategies. Investment policy decisions are made in our best judgment to help you achieve your overall financial objectives while minimizing risk exposure. We will mostly use mutual funds and ETFs. In markets where efficiency is not as apparent and passive strategies do not provide an adequate risk/return tradeoff, we may choose to employ individual equities and fixed income (stocks and bonds) to gain the return and diversification exposure desired. Risk of Loss Our firm believes its strategies and investment recommendations are designed to produce the 12 appropriate potential return for the given level of risk; however, there is no guarantee that an investment objective or planning goal will be achieved. Investing in securities involves risk of loss that clients should be prepared to bear. We have offered examples of such risk in the following paragraphs, and we believe it is important that our clients review and consider each of them prior to investing. Company Risk When investing in securities, such as stocks, there is always a certain level of company or industry- specific risk that is inherent in each company or issuer. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. This is also referred to as unsystematic risk and can be reduced or mitigated through diversification. Equity (Stock) Risk Common stocks are susceptible to general stock market fluctuations and to volatile increases or decreases in value as market confidence in and perceptions of their issuers change. If an investor held common stock or common stock equivalents of any given issuer, they may be exposed to greater risk than if they held preferred stocks and debt obligations of the issuer. ETF and Mutual Fund Risks The risk of owning ETFs and mutual funds reflect their underlying securities (e.g., stocks, bonds, etc.). These forms of securities may carry additional expenses based on their share of operating expenses and certain brokerage fees, which may result in the potential duplication of certain fees. Certain ETFs and indexed funds have the potential to be affected by "active risk" or "tracking error risk;" a deviation from a stated index (e.g., S&P 500). While many ETFs and index mutual funds are known for their potential tax-efficiency and higher "qualified dividend income" (QDI) percentages, there are asset classes within these investment vehicles or holding periods within that may not benefit. Shorter holding periods, as well as commodities and currencies (that may be an ETF or mutual fund holding), may be considered "non-qualified" under certain tax code provisions. A holding's QDI will be considered when tax-efficiency is an important aspect of the client's portfolio. We do not recommend leveraged or inverse ETFs due to their inherent heightened risk. Failure to Implement As a financial planning client, you are free to accept or reject any or all of the recommendations made to you. While no advisory firm can guarantee future performance, no plan can succeed if it is not implemented. Clients who choose not to take the steps recommended in their financial plan may face an increased risk that their stated goals and objectives will not be achieved. Financial Risk Excessive borrowing to finance a business operation increases profitability risk because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Fixed Income Risks Various forms of fixed income instruments, such as bonds, money market or bond funds, may be affected by various forms of risk, including: • Credit Risk - The potential risk that an issuer would be unable to pay scheduled interest or repay principal at maturity, sometimes referred to as "default risk." Credit risk may also occur when an issuer's ability to make payments of principal and interest when due is interrupted. This may result in a negative impact on all forms of debt instruments, as well as funds or ETF share values that hold these issues. Bondholders are creditors of an issuer and have priority to assets before equity holders (i.e., stockholders) when receiving a payout from liquidation or restructuring. When defaults occur due to bankruptcy, the type of bond held will determine 13 seniority of payment. • Duration Risk - Duration is a measure of a bond's volatility, expressed in years to be repaid by its internal cash flow (interest payments). Bonds with longer durations carry more risk and have higher price volatility than bonds with shorter durations. • Interest Rate Risk - The risk that the value of the fixed income holding will decrease because of an increase in interest rates. • Liquidity Risk - The inability to readily buy or sell an investment for a price close to the true underlying value of the asset due to a lack of buyers or sellers. While certain types of fixed income are generally liquid (i.e., bonds), there are risks which may occur such as when an issue trading in any given period does not readily support buys and sells at an efficient price. Conversely, when trading volume is high, there is also a risk of not being able to purchase a particular issue at the desired price. • Reinvestment Risk - With declining interest rates, investors may have to reinvest interest income or principal at a lower rate. Fundamental Analysis The challenge involving fundamental analyses is that information obtained may be incorrect; the analysis may not provide an accurate estimate of earnings, which may be the basis for a security's value. If a security's price adjusts rapidly to new information, a fundamental analysis may result in unfavorable performance. Inflation When any type of inflation is present, a dollar today will not buy as much as a dollar next year because purchasing power is eroding at the rate of inflation. Market Risk When the stock market as a whole or an industry as a whole fall, it can cause the prices of individual stocks to fall indiscriminately. This is also called systemic or systematic risk. Passive Investing A portfolio that employs a passive, efficient markets approach has the potential risk at times to generate lower-than-expected returns for the broader allocation than might be the case for a more narrowly focused asset class, and the return on each type of asset may be a deviation from the average return for the asset class. Political Risk The risk of financial and market loss because of political decisions or disruptions in a particular country or region and may also be known as "geopolitical risk." Research Data When research and analyses are based on commercially available software, rating services, general market and financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the information or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. While our firm makes every effort to determine the accuracy of the information received, we cannot predict the outcome of events or actions taken or not taken, or the validity of all information researched or provided which may or may not affect the advice on or investment management of an account. 14 Item 9 Disciplinary Information Neither the firm nor its management has been involved in a material criminal or civil action in a domestic, foreign or military jurisdiction, an administrative enforcement action, or self-regulatory organization proceeding that would reflect poorly upon our offering advisory business or its integrity. Item 10 Other Financial Industry Activities and Affiliations We have not provided information on other financial industry activities and affiliations because we do not have any relationship or arrangement that is material to our advisory business or to our clients with any of the types of entities listed below. 1. broker-dealer, municipal securities dealer, or government securities dealer or broker; 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund); 3. other investment adviser or financial planner; 4. futures commission merchant, commodity pool operator, or commodity trading adviser; 5. banking or thrift institution; 6. accountant or accounting firm; 7. lawyer or law firm; 8. insurance company or agency; 9. pension consultant; 10. real estate broker or dealer; and/or 11. sponsor or syndicator of limited partnerships. Upon your request, you may be provided a referral to various other professionals, such as an accountant or attorney. While these referrals are based on the best information made available, the firm does not guarantee the quality or adequacy of the work provided by these referred professionals. There is not an agreement with these entities nor are referral fees received from these professionals for such informal referrals. Any fees charged by these other entities for their services are completely separate from our advisory fee. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Patina Wealth holds itself to a fiduciary standard, which means the firm and its associates will act in the utmost good faith, performing in a manner believed to be in the best interests of its clients. Our firm believes that business methodologies, ethics rules, and adopted policies are designed to eliminate or at least minimize material conflicts of interest and to appropriately manage any material conflicts of interest that may remain. You should be aware that no set of rules can anticipate or relieve all material conflicts of interest. We will disclose to our clients any material conflict of interest relating to the firm, its representatives, or any of its employees which could reasonably be expected to impair the rendering of unbiased and objective advice. Code of Ethics Description We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. Our firm accepts the obligation not only to comply with all applicable laws and regulations but also to act in an ethical and professionally responsible manner in all professional services and activities. Our firm policies include prohibitions against insider trading, the circulation of industry rumors, and certain political contributions, among others. 15 Patina Wealth periodically reviews and amends its Code of Ethics to ensure that it remains current, and we require firm personnel to annually attest to their understanding of and adherence to the firm's Code of Ethics. A copy of the firm's Code of Ethics is made available to any client or prospective client upon request. Participation or Interest in Client Transactions Neither our firm nor any persons associated with our firm has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. Firm/Personnel Purchases of Securities Recommended to Clients We do not trade for our own firm account (e.g., proprietary trading). The firm's related persons may buy or sell securities that are the same as, similar to, or different from, those recommended to clients for their accounts, and this poses a conflict of interest. We mitigate this conflict by ensuring that we have policies and procedures in place to ensure that the firm or a related person will not receive preferential treatment over a client. In an effort to reduce or eliminate certain conflicts of interest involving personal trading (i.e., trading ahead of client recommendations, etc.), firm policy may require that we periodically restrict or prohibit related parties' transactions. Any exceptions must be approved in writing by our Chief Compliance Officer, and personal trading accounts are reviewed on a quarterly or more frequent basis. Item 12 Brokerage Practices We recommend the brokerage and custodial services of Charles Schwab and Charles Schwab Bank FSB (whether one or more, referred to herein as "Custodian"). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. In recognition of the value of the services the Custodian provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. We believe that the recommended Custodian provides quality execution services for you 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 the Custodian, including the value of the Custodian's reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In recognition of the value of the services the Custodian provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, the most favorable compared to other available providers and their services. We consider various factors, including: • Capability to buy and sell securities for your account itself or to facilitate such services. • The likelihood that your trades will be executed. • Availability of investment research and tools. • Overall quality of services. • Competitiveness of price. • Reputation, financial strength, and stability. • Existing relationship with our firm and our other clients. Research and Other Soft Dollar Benefits We do not have any soft dollar arrangements. 16 Economic Benefits As a registered investment adviser, we have access to the institutional platform of your account custodian. As such, we will also have access to research products and services from your account custodian and/or other brokerage firm. These products are in addition to any benefits or research we pay for with soft dollars, and may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms, and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Schwab - Your Custody and Brokerage Costs For our clients’ accounts it maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. For some accounts, Schwab may charge you a percentage of the dollar amount of assets in the account in lieu of commissions. Schwab’s commission rates and/or asset-based fees applicable to our client accounts were negotiated based on our commitment to maintain $10 million of our clients’ assets statement equity in accounts at Schwab. This commitment benefits you because the overall commission rates and/or asset-based fees you pay are lower than they would be if we had not made the commitment. In addition to commission rates and/or asset-based fees Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. Schwab Advisor Services Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally are available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: Services that Benefit You Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit You Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our 17 clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements); • facilitate trade execution and allocate aggregated trade orders for multiple client accounts; • provide pricing and other market data; or facilitate payment of our fees from our clients’ accounts; and • assist with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only Us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • educational conferences and events; • technology, compliance, legal, and business consulting; • publications and conferences on practice management and business succession; • access to employee benefits providers, human capital consultants and insurance providers; • discount of up to $4,250 on PortfolioCenter® software. Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. Our Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services so long as we keep a total of at least $10 million of client assets in accounts at Schwab. Beyond that, these services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The $10 million minimum may give us an incentive to recommend that you maintain your account with Schwab based on our interest in receiving Schwab’s services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. It is primarily supported by the scope, quality and price of Schwab’s services (based on the factors discussed above – see “The Custodian and Broker We Use”) and not Schwab’s services that benefit only us. We do not believe that maintaining at least $10 million of assets under management at Schwab in order to avoid paying Schwab quarterly service fees presents a material conflict of interest. Best Execution "Best execution" means the most favorable terms for a transaction based on all relevant factors, including those listed in the paragraph titled Factors Used to Select Broker/Dealers for Client Transactions. We recognize our obligation in seeking best execution for our portfolio management services clients; however, it is our belief that the determinative factor is not always the lowest possible cost but whether the selected custodian's transactions represent the best "qualitative execution" while taking into consideration the full range of services provided. Our firm will seek services involving competitive rates but it may not necessarily correlate into the lowest possible rate for each transaction. We have determined having our clients' accounts trades completed through our recommended custodian is consistent with our obligation to seek best execution of client trades. A review is regularly 18 conducted with regard to recommending a custodian to our clients in light of our duty to seek best execution. Directed Brokerage Our internal policy and operational relationship with our custodians require client accounts custodied with them to have trades executed per their order routing requirements. We do not direct which executing broker should be selected for client account trades; whether that is an affiliate of a preferred custodian or another executing broker of that custodian's choice. As a result, you may pay higher commissions or other transaction costs, experience greater spreads, or receive less favorable net prices on transactions than might otherwise be the case. In addition, since we routinely recommend a particular custodian(s) for our advisory clients, and that custodian may choose to use the execution services of its broker affiliate for some or all of our client account transactions, there is an inherent conflict of interest involving our recommendation since our advisory firm receives various products or services described in this section from that custodian. Note that we are not compensated for trade routing/order flow, nor are we paid commissions on such trades. We do not receive interest on our client accounts' cash balances. Our clients are unable to engage in directed brokerage via our custodian. As a result, they may pay higher commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case if they had the opportunity to direct brokerage. For those clients who maintain account assets at another custodian of record, the client may choose to request that a particular broker is used to execute some or all account transactions. Under these circumstances, the client will be responsible for negotiating, in advance of each trade, the terms and/or arrangements involving their account with that broker, and whether the selected broker is affiliated with their custodian of record or not. We will not be obligated to seek better execution services or prices from these other brokers. As a result, the client may pay higher commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case. Aggregating Securities Transactions for Client Accounts Trade aggregation involves the purchase or sale of the same security for several clients/accounts at approximately the same time. This may also be termed "blocked”, "bunched" or "batched" orders. Aggregated orders are effected in an attempt to obtain better execution, negotiate favorable transaction rates, or to allocate equitably among multiple client accounts should there be differences in prices, brokerage commissions or other transactional costs that might otherwise be unobtainable through separately placed orders. Our firm may, but is not obligated to, aggregate orders and we do not receive additional compensation or remuneration as a result of aggregated transactions. Transaction charges and/or prices may vary due to account size and/or method of receipt. To the extent that the firm determines to aggregate client orders for the purchase or sale of securities, including securities in which a related person may invest, the firm will generally do so in accordance with the parameters set forth in SEC No-Action Letter, SMC Capital, Inc.,or similar guidance if the jurisdiction in which the client resides provides such direction. Please note that when trade aggregation is not allowed or infeasible and necessitates individual transactions (e.g., withdrawal or liquidation requests, odd-lot trades, non-discretionary accounts, etc.), an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. 19 We review firm trading processes on a periodic basis to ensure they remain within stated policies and regulation. You will be informed, in advance, should trading practices change at any point in the future. Mutual Fund Share Classes Mutual funds are sold with different share classes, which carry different cost structures. Each available share class is described in the mutual fund's prospectus. When we purchase, or recommend the purchase of, mutual funds for a client, we select the share class that is deemed to be in the client’s best interest, taking into consideration cost, tax implications, and other factors. When the fund is available for purchase at net asset value, we will purchase, or recommend the purchase of, the fund at net asset value. We also review the mutual funds held in accounts that come under our management to determine whether a more beneficial share class is available, considering cost, tax implications, and the impact of contingent deferred sales charges. Trade Errors Our firm corrects its trade errors through an account maintained by our custodian, and the firm may be responsible for certain trading error losses that occur within a client account. Trade errors that result in a gain less than or equal to $100, where Schwab is the custodian, the credit will remain in Schwab's error account. Trading errors that result in a gain over $100, where Schwab is the custodian, will be credited to the client's account Item 13 Review of Accounts Scheduled Reviews Investment accounts are reviewed on a quarterly or more frequent basis by our investment committee. Client-level reviews are also completed by Samuel Carter Harris, and we recommend that they occur on at least an annual basis. Performance or asset allocation reports will be provided to the client upon request. Unscheduled Reviews You should contact our firm for additional reviews when you anticipate or have experienced changes in your financial situation (i.e., changes in employment, an inheritance, the birth of a new child, etc.), or if you require changes involving your investment account. Additional reviews by Samuel Carter Harris may be triggered by news or research related to a specific holding, a change in our view of the investment merits of a holding, or news related to the macroeconomic climate affecting a sector or holding within that sector. A portfolio may be reviewed for an additional holding or when an increase in a current position is under consideration. Account cash levels above or below what we deem appropriate for the investment environment, given the client's stated tolerance for risk and investment objectives, may also trigger a review. Client Reports Whether you have opened and maintained an investment account on your own or with our assistance, you will receive account statements sent directly from mutual fund companies, transfer agents, custodians or brokerage companies where your investments are held. We urge you to carefully review these account statements for accuracy and clarity, and to ask questions when something is not clear. Clients may receive written performance reports from our firm that have been generated from our custodian's data systems; however, we do not create our own performance reports. Clients are urged to carefully review and compare account statements that they have received directly from their custodian of record with any report they may receive from any source that contains investment performance information. 20 Item 14 Client Referrals and Other Compensation Please refer to Item 12 for information with respect to our offerings and the potential conflict of interest they may present. Client Referrals We do not receive any compensation from any third party in connection with providing investment advice to you nor do we compensate any individual or firm for client referrals. Item 15 Custody As paying agent for our firm, your independent custodian will directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other qualified custodian. You will receive account statements from the qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. We will also provide statements to you reflecting the amount of the advisory fee deducted from your account. You should compare our statements with the statements from your account custodian(s) to reconcile the information reflected on each statement. If you have a question regarding your account statement, or if you did not receive a statement from your custodian, contact us immediately at the telephone number on the cover page of this brochure. Item 16 Investment Discretion We generally provide our portfolio management services on a discretionary basis. Similar to a limited power of attorney, discretionary authority allows our firm to implement investment decisions, such as the purchase or sale of a security on behalf of your account, without requiring your prior authorization for each transaction in order to meet your stated investment objectives. This authority will be granted through your execution of both our engagement agreement and the selected custodian's account opening documents. Note that your custodian will specifically limit our firm's authority within your account to the placement of trade orders and the request for the deduction of our advisory fees. Our Firm primarily manages client accounts on a discretionary basis but may consider non- discretionary arrangements upon request. Non-discretionary accounts require your ongoing prior approval involving the investment and reinvestment of account assets, portfolio rebalancing, or for our firm to give instructions to the custodian maintaining your account (i.e., wire instructions, etc.). Should you find it necessary to require such restrictions, we may not offer a reduced fee due to the additional operational costs involved managing your account. You will be required to execute our firm's client services agreement that describes our limited account authority, as well as the custodian of record's account opening document that includes their limited power of attorney form or clause. Please note that in light of the requirement for your pre-approval you must make yourself available and keep our firm updated on your contact information so that instructions can be efficiently effected on your behalf. You may amend our account authority by providing our firm revised written instructions. As noted in Item 4, we will allow for reasonable restrictions involving the management of your account. It remains 21 your responsibility to notify us if there is any change in your situation and/or investment objective so that we may reevaluate previous investment recommendations or portfolio holdings. Item 17 Voting Client Securities You may periodically receive proxies or other similar solicitations sent directly from your custodian or a transfer agent. Should we receive a duplicate copy, note that we do not forward these or any correspondence relating to the voting of your securities, class action litigation, or other corporate actions. Patina Wealth does not vote proxies on behalf of an account holder, including accounts that we have discretionary authority. We do not offer guidance on how to vote proxies, nor will we offer guidance involving any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in a client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. We will answer limited questions with respect to what a proxy voting request or other corporate matter may be and how to reach the issuer or their legal representative. You will maintain exclusive responsibility for directing the manner in which proxies solicited by issuers of securities that are beneficially owned by you shall be voted, as well as making all other elections relative to mergers, acquisitions, tender offers or other legal matters or events pertaining to your holdings. You should consider contacting the issuer or your legal counsel involving specific questions you may have with respect to a particular proxy solicitation or corporate action. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. Item 18 Financial Information Patina Wealth will not take physical custody of client assets, nor do we have the type of account authority to have such control. Fee withdrawals must be done through a qualified intermediary (e.g., custodian of record), per prior written agreement with the client, and following the client's receipt of our firm's written notice (termed "constructive custody"). Engagements with our firm do not require that we collect fees of $500 or more for our services that we have agreed to perform six months or more into the future. Neither our firm nor its management serve as general partner for a partnership or trustee for a trust in which the firm's advisory clients are either partners of the partnership or beneficiaries of the trust. The firm and its management do not have a financial condition likely to impair its ability to meet commitments to clients, nor has the firm and its management been the subject of a bankruptcy petition. Due to the nature of our firm's advisory services and operational practices, an audited balance sheet is not required nor included in this brochure. 22 Privacy Policy Statement We respect the privacy of all clients and prospective clients both past and present (collectively termed "customers" per regulatory guidelines). It is recognized that you have entrusted our firm with non-public personal information and it is important that both access persons and customers are aware of firm policy concerning what may be done with that information. The firm collects personal information about customers from the following sources: • Information customers provide to complete their financial plan or investment recommendations; • Information customers provide in engagement agreements and other documents completed in connection with the opening and maintenance of an account; • Information customers provide verbally; and • Information received from service providers, such as custodians, about customers' transactions. The firm does not disclose non-public personal information about our customers to anyone, except in the following circumstances: • When required to provide services our customers have requested; • When our customers have specifically authorized us to do so; • When required during the course of a firm assessment (i.e., independent audit); or • When permitted or required by law (i.e., periodic regulatory examination). To ensure security and confidentiality, the firm maintains physical, electronic, and procedural safeguards to protect the privacy of customer information. Within the firm, access to customer information is restricted to personnel who need to know that information. All access persons and service providers understand that everything handled in firm offices is confidential and they are instructed not to discuss customer information with someone else that may request information about an account unless they are specifically authorized in writing by the customer to do so. This includes providing information about a family member. Patina Wealth will provide our customers with its privacy policy on an annual basis and at any time, in advance, if our privacy policy is expected to change. 23

Frequently Asked Questions