PENINSULA WEALTH, LLC

ITEM 1. COVER PAGE FOR PART 2A OF FORM ADV: FIRM BROCHURE March 2025 350 TOWNSEND STREET, SUITE 411 SAN FRANCISCO, CA 94107 (415) 678-5360 WWW.PENINSULAWEALTH.COM FIRM CONTACT: RAHUL SHAH CHIEF COMPLIANCE OFFICER firm by telephone at This brochure provides information about the qualifications and business practices of Peninsula Wealth, LLC. If you have any questions about the contents of this brochure, please contact our (415) 678-5360 or by email at rahul@peninsulawealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about Peninsula Wealth, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD#: 152436. Please note that the use of the term “registered investment adviser” and description of Peninsula Wealth, LLC and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and its employees.  ITEM 2. MATERIAL CHANGES TO OUR PART 2A OF FORM ADV: FIRM BROCHURE Peninsula Wealth, LLC is required to advise you of any material changes to our Firm Brochure (“Brochure”) from our last annual update, identify those changes on the cover page of our Brochure or on the page immediately following the cover page, or in a separate communication accompanying our Brochure. We must state clearly that we are discussing only material changes since the last annual update of our Brochure, and we must provide the date of the last annual update of our Brochure. Since our last annual amendment filing, we have no material changes to report. ADV Part 2A – Firm Brochure Page 2 Peninsula Wealth, LLC  ITEM 3. TABLE OF CONTENTS ITEM 1. COVER PAGE ............................................................................................................... 1 ITEM 2. MATERIAL CHANGES.................................................................................................... 2 ITEM 3. TABLE OF CONTENTS .................................................................................................... 3 ITEM 4. ADVISORY BUSINESS ..................................................................................................... 4 ITEM 5. FEES AND COMPENSATION ......................................................................................... 5 ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................... 7 ITEM 7. TYPES OF CLIENTS AND ACCOUNT REQUIREMENTS ................................................... 7 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ..................... 7 ITEM 9. DISCIPLINARY INFORMATION ...................................................................................... 9 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................... 9 ITEM 11. CODE OF ETHICS ........................................................................................................ 9 ITEM 12. BROKERAGE PRACTICES ...........................................................................................10 ITEM 13. REVIEW OF ACCOUNTS OR FINANCIAL PLANS .......................................................13 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION ...................................................13 ITEM 15. CUSTODY ...................................................................................................................14 ITEM 16. INVESTMENT DISCRETION ..........................................................................................15 ITEM 17. VOTING CLIENT SECURITIES .......................................................................................15 ITEM 18. FINANCIAL INFORMATION ........................................................................................15 ADV Part 2A – Firm Brochure Page 3 Peninsula Wealth, LLC  ITEM 4. ADVISORY BUSINESS Peninsula Wealth, LLC is dedicated to providing clients with a wide array of investment advisory services. Our firm is a limited liability company formed in the State of California. We have been in business as an investment adviser since February 2010 and is principally owned by Rahul Shah. Description of the Types of Advisory Services We Offer Asset Management We emphasize continuous and regular account supervision. As part of our asset management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least annually and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Comprehensive Portfolio Management Our comprehensive portfolio management service encompasses asset management as well as providing financial planning/financial consulting to clients. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds, mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts at least annually or as often as necessary. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Our firm utilizes the sub-advisory services of a third-party investment advisory firm or individual advisor to aid in the implementation of an investment portfolio designed by our firm. Before selecting a firm or individual, our firm will ensure that the chosen party is properly licensed or registered. Our firm will not offer advice on any specific securities or ADV Part 2A – Firm Brochure Page 4 Peninsula Wealth, LLC  other investments in connection with this service. We will provide initial due diligence on third party money managers and ongoing reviews of their management of client accounts. In order to assist in the selection of a third-party money manager, 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 third party money managers as warranted; and, assist the client in understanding and evaluating the services provided by the third party money manager. 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. Tailoring of Advisory Services We offer individualized investment advice to all clients tailoring to their risk tolerance. We usually do not allow clients to impose restrictions on investing in certain securities or types of securities due to the level of difficulty this would entail in managing their account. Participation in Wrap Fee Programs We do not offer wrap fee programs. Regulatory Assets Under Management We manage $676,425,339 on a discretionary basis as of December 31, 2024. ITEM 5. FEES AND COMPENSATION We are required to describe our brokerage, custody, fees and fund expenses so you will know how much you are charged and by whom for our advisory services provided to you. Our fees are generally negotiable. Asset Management Our annual fees for our Asset Management service shall be based on the market value of the assets under management and shall be calculated at up to 1.25% of all assets under management. Fees are billed on a pro-rata annualized basis quarterly in arrears based on the average daily balance of your account during the quarter. Unless otherwise agreed to in writing, advisory fees shall be assessed on cash and cash equivalents. Fees will be deducted from your managed account. In rare cases, we will agree to directly bill clients. As part of this process, you understand and acknowledge the following: ADV Part 2A – Firm Brochure Page 5 Peninsula Wealth, LLC  a) Your independent custodian sends statements at least quarterly to you showing all disbursements for your account, including the amount of the advisory fees paid to us; b) You provide authorization permitting us to be directly paid by these terms; c) If we send a copy of our invoice to you, our invoice includes a legend as required by paragraph (a)(2) of Rule 206(4)-2 under the Investment Advisers Act of 1940 that urges clients to compare the statement from their custodian with ours. Comprehensive Portfolio Management Our annual fees for our Comprehensive Portfolio Management service shall be based on the market value of the assets under management and shall be calculated at up to 1.25% of all assets under management. Fees are billed on a pro-rata annualized basis quarterly in arrears based on the average daily balance of your account during the quarter. Unless otherwise agreed to in writing, advisory fees shall be assessed on cash and cash equivalents. Fees will be deducted from your managed account. In rare cases, we will agree to directly bill clients. As part of this process, you understand and acknowledge the following: a) Your independent custodian sends statements at least quarterly to you showing all disbursements for your account, including the amount of the advisory fees paid to us; b) You provide authorization permitting us to be directly paid by these terms; c) If we send a copy of our invoice to you, our invoice includes a legend as required by paragraph (a)(2) of Rule 206(4)-2 under the Investment Advisers Act of 1940 that urges clients to compare the statement from their custodian with ours. For the sub-advisory services rendered to our clients, third-party managers will charge an additional fee which is in addition to the fee agreed to for our firm’s services. This will be described in the chosen manager’s Form ADV which shall be provided to clients upon engagement of their services. Additionally, the fees for 55ip’s Tax Alpha program are covered by Blackrock. While clients are not subject to additional fees for this program, the expenses paid by Blackrock may create a conflict of interest that incentivize our firm to recommend the use of Blackrock funds in these accounts. We will adhere to our fiduciary duty and ensure that other fund families are utilized where appropriate. Other Types of Fees & Expenses Clients will incur transaction charges for trades executed in their accounts. These transaction fees are separate from our fees and will be disclosed by the firm that the trades are executed through. It is important to note that Fidelity Brokerage Services eliminated transaction fees for U.S. listed equities and exchange traded funds for clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity and Charles Schwab & Co. has eliminated transaction costs on U.S. listed equities and exchange traded funds for all clients. Also, clients will pay the following separately ADV Part 2A – Firm Brochure Page 6 Peninsula Wealth, LLC  incurred expenses, which we do not receive any part of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses). Additionally, certain alternative investments where CAIS Group creates a feeder fund will have an additional sponsor fee charged by CAIS. Termination and Refunds Either party may terminate our services at any time upon providing written notice to the other party, subject to the settlement of any outstanding trades. In the event a client wishes to terminate our services, we will charge the pro rata balance due to clients. Termination will be effective on the specified date in such notification. Any earned, pro- rated fees will be calculated based on the percentage of days that services were provided during the calendar month multiplied by the average daily balance during the portion of the calendar month that services were provided by us (the beginning of the quarter through the termination date). Commissionable Securities Sales We do not sell securities for a commission. ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance fees to our clients. ITEM 7. TYPES OF CLIENTS AND ACCOUNT REQUIREMENTS We have the following types of clients are serviced by Peninsula Wealth LLC: • High-Net Worth Individuals; • Corporations, limited liability companies and/or other business types. Our requirements for opening and maintaining accounts or otherwise engaging us: • We require a minimum aggregated account balance of $1,000,000 for our Comprehensive Portfolio Management service. Generally, this minimum account balance requirement is negotiable and would be required throughout the course of the client’s relationship with our firm. However, minimum account balance size may vary due to the fact that some client household may have multiple accounts under management with us. • Clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity will not be charged transaction fees for U.S. listed equities and exchange traded funds. ADV Part 2A – Firm Brochure Page 7 Peninsula Wealth, LLC  ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis: Charting. In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when how long the trend may last and when that trend might reverse. 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 itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as 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 stock. Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement. Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. Investment Strategies We Use: Long-Term Purchases. When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Short-Term Purchases. When utilizing this strategy, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. Option Writing. We may use options as an investment strategy. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. ADV Part 2A – Firm Brochure Page 8 Peninsula Wealth, LLC  Alternative Investments: Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”), Business Development Companies (“BDCs”), and other alternative investments involve a high degree of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They can be highly leveraged, speculative and volatile, and an investor could lose all or a substantial amount of an investment. Alternative investments may lack transparency as to share price, valuation and portfolio holdings. Complex tax structures often result in delayed tax reporting. Compared to mutual funds, hedge funds and commodity pools are subject to less regulation and often charge higher fees. Alternative investment managers typically exercise broad investment discretion and may apply similar strategies across multiple investment vehicles, resulting in less diversification. Risk of Loss: Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and ask us any questions you may have. Cash Balances in Client Accounts We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to achieve the highest return on our client’s cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to comprehensive portfolio management and asset management services, as applicable. ITEM 9. DISCIPLINARY INFORMATION Neither our firm nor, our management, or investment adviser representatives have disciplinary events to disclose. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS As a fiduciary, Peninsula Wealth, LLC has certain legal obligations, including the obligation to act in clients' best interest. We maintain a Business Continuity and Succession Plan and seeks to avoid a disruption of service to clients in the event of an unforeseen loss of key personnel, due to disability or death. To that end, we have entered into a succession agreement with Buckingham Asset Management, LLC. Additional ADV Part 2A – Firm Brochure Page 9 Peninsula Wealth, LLC  information to any current or prospective client upon request to Kristina Ventura at kristina@peninsulawealth.com or by calling our office. We have no other financial industry activities and affiliations to disclose. ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts1. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. 1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. ADV Part 2A – Firm Brochure Page 10 Peninsula Wealth, LLC  Related persons of our firm may also buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. ITEM 12. BROKERAGE PRACTICES Selecting a Brokerage Firm We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, these: Timeliness of execution Timeliness and accuracy of trade confirmations • Ability to maintain the confidentiality of trading intentions • • • Liquidity of the securities traded • Willingness to commit capital • Ability to place trades in difficult market environments • Research services provided • Ability to provide investment ideas • Execution facilitation services provided • Record keeping services provided • Custody services provided • Frequency and correction of trading errors • Ability to access a variety of market venues • Financial condition • Business reputation Our firm has an arrangement with National Financial Services LLC and Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity") through which Fidelity provides our firm with "institutional platform services." Our firm is independently operated and owned and is not affiliated with Fidelity. The institutional platform services include, among others, brokerage, custody, and other related services. Fidelity's institutional platform services that assist us in managing and administering clients' accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Additionally, our firm recommends that clients use the Schwab Advisor Services division of Charles Schwab & Co. Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the qualified custodian. Our firm is independently owned and operated, and not affiliated ADV Part 2A – Firm Brochure Page 11 Peninsula Wealth, LLC  with Schwab. Schwab will hold client assets in a brokerage account and buy and sell securities when instructed. While our firm recommends that clients use Schwab as custodian/broker, clients will decide whether to do so and open an account with Schwab by entering into an account agreement directly with them. Fidelity and Schwab (collectively “our custodians”) may make certain research and brokerage services available at no additional cost to our firm all of which qualify for the safe harbor exemption defined in Section 28(e) of the Securities Exchange Act of 1934. These services may be directly from independent research companies, as selected by our firm (within specific parameters). Research products and services provided by our custodians may include research reports on recommendations or other information about, particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Fidelity to our firm in the performance of our investment decision- making responsibilities. The availability of these services from our custodians benefits us because we do not have to produce or purchase them. In addition, we don’t have to pay for our custodians’ services. These services may be contingent upon us committing a certain amount of business to our custodians in assets in custody. We may have an incentive to recommend that you maintain your account with our custodians, based on our interest in receiving their 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 our custodians as a custodian and broker is in the best interests of our clients and is consistent with our duty to seek “best execution” of client trades. Our selection is primarily supported by the scope, quality, and price of services and not services that benefit only us. We do not use client brokerage commissions to obtain research or other products or services. The aforementioned research and brokerage services are used by our firm to manage accounts for which we have investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense, which may cause advisory fees to be higher. Therefore, we recommend clients utilize our custodians’ platform. Our custodians generally do not charge you separately for custody services. Rather they charge brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). Our custodians enable us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Our custodians’ commission rates are generally discounted from customary retail commission rates. The commission and transaction fees charged may be higher or lower than those charged by other custodians and broker-dealers. ADV Part 2A – Firm Brochure Page 12 Peninsula Wealth, LLC  research provided, execution capability, commission Our clients may pay a commission to our custodians that is higher than another qualified broker dealer might charge to effect the same transaction where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of rates, and responsiveness. Accordingly, although we will seek competitive rates, to the benefit of all clients, we may not necessarily obtain the lowest possible commission rates for specific client account transactions. Soft Dollars Although the investment research products and services that may be obtained by our firm will generally be used to service all of our clients, a brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client’s account. Our firm does not accept products or services that do not qualify for Safe Harbor outlined in Section 28(e) of the Securities Exchange Act of 1934, such as those services that do not aid in investment decision-making or trade execution. Client Brokerage Commissions We do not acquire client brokerage commissions (or markups or markdowns). Procedures to Direct Client Transactions in Return for Soft Dollars We do not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals Our firm does not receive brokerage for client referrals. Directed Brokerage Neither we nor any of our firm’s related persons have discretionary authority in making the determination of the brokers with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. We routinely recommend that a client directs us to execute through a specified broker-dealer. Our firm recommends the use of Fidelity and/or Schwab. Each client will be required to establish their account(s) with their chosen custodian if not already done. Please note that not all advisers have this requirement. Permissibility of Client-Directed Brokerage We allow clients to direct brokerage. However, we may not have a data feed to execute trades similar to those at our custodians. In addition, we may be unable to achieve the ADV Part 2A – Firm Brochure Page 13 Peninsula Wealth, LLC  most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices. Prime Brokerage Our firm participates in prime brokerage services provided by different bond traders. Orders shall be transmitted to the outside firm for the execution of trades. Our custodians clear our prime brokerage transactions in our block trading brokerage account established in the name of Peninsula Wealth, LLC and designated for our client account holders in an allocation established by us prior to placing orders. Pursuant to the prime brokerage services agreement, our custodian will maintain all details of each prime brokerage transaction, including, but not limited to, contract amount, the security involved, the number of shares or units, and whether the transaction was a long or short sale or a purchase. Aggregation of Purchase or Sale We perform investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when we believe that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, we attempt to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration and consistently non- arbitrary methods of allocation. ITEM 13. REVIEW OF ACCOUNTS OR FINANCIAL PLANS We review accounts at least annually, or as often as necessary, for our clients. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Each review will be conducted by an Investment Adviser Representative registered with our firm. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. ADV Part 2A – Firm Brochure Page 14 Peninsula Wealth, LLC  Clients may also have the ability to access written performance reports from our recommended vendor(s) to review their own account’s performance as needed. In addition, we contact clients annually for verbal reviews. ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION Fidelity & Schwab Except for the arrangements outlined in Item 12 of this brochure, we have no additional arrangements to disclose. Referral Fees In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). ITEM 15. CUSTODY All of our clients receive at least quarterly account statements directly from their custodians. Upon opening an account with a qualified custodian on a client's behalf, we promptly notify the client in writing of the qualified custodian's contact information. If we decide to also send account statements to clients, such notice and account statements include a legend that recommends that the client compare the account statements received from the qualified custodian with those received from our firm. We encourage our clients to raise any questions with us about the custody, safety or security of their assets. The custodians we do business with will send you independent account statements listing your account balance(s), transaction history and any fee debits or other fees taken out of your account. The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards. As such, our firm has adopted the following safeguarding procedures in conjunction with our custodians: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. ADV Part 2A – Firm Brochure Page 15 Peninsula Wealth, LLC  • • • • • • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. The client has the ability to terminate or change the instruction to the client’s qualified custodian. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. ITEM 16. INVESTMENT DISCRETION Our clients need to sign a discretionary investment advisory agreement with our firm for the management of their account. Clients may limit our authority by designating which accounts they wish for our firm to manage on a non-discretionary basis. ITEM 17. VOTING CLIENT SECURITIES We do not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. ADV Part 2A – Firm Brochure Page 16 Peninsula Wealth, LLC  ITEM 18. FINANCIAL INFORMATION We have never been the subject of a bankruptcy proceeding. We are not required to provide financial information in this Brochure because: • We do not require the prepayment of more than $1,200 in fees and six or more months in advance. • We do not take custody of client funds or securities. • We do not have a financial condition that could impair our ability to meet contractual commitments. • We have never been the subject of a bankruptcy proceeding. ADV Part 2A – Firm Brochure Page 17 Peninsula Wealth, LLC