Plan to Prosper Wealth Management

ITEM 1 Cover Page DISCLOSURE BROCHURE THE INVESTMENT ADVISERS ACT OF 1940 RULE 203-1 Part 2A of Form ADV: Firm Brochure CORPORATE HEADQUARTERS Principal Office & Mailing Address 595 W. Granada Boulevard Suite K Ormond Beach, Florida 32174 SEC File #: 801-131973 Firm IARD/CRD #: 327660 Contact Information P: 386.271.2127 F: 386.271.2135 C: 386.341.8985 Palacios Wealth Management, LLC R E G I S T E R E D I N V E S T M E N T A D V I S O R erick@myplantoprosper.com www.myplantoprosper.com B R O C H U R E D A T E D This Disclosure Brochure provides information about the qualifications and business practices of Palacios Wealth Management, LLC, which should be considered before becoming a client. You are welcome to contact us if you have any questions about the contents of this brochure – our contact information is listed to the right. Additional information about Palacios Wealth Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. 1 JANUARY 2026 The information contained in this Disclosure Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Administrator. Furthermore, the term “registered investment advisor” is not intended to imply that Palacios Wealth Management, LLC has attained a certain level of skill or training. © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com  DISCLOSURE BROCHURE I MATERIAL CHANGES T E M 2 There are no material changes to report. This Disclosure Brochure has been reviewed and is current as of the date indicated on the cover. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 2 of 22  DISCLOSURE BROCHURE I TABLE OF CONTENTS T E M 3 ITEM 1 Cover Page 1 ITEM 2 Material Changes 2 ITEM 3 Table of Contents 3 ITEM 4 Advisory Business 4 ITEM 5 Who We Are Assets Under Management What We Do Fees & Compensation 4 4 5 6 ITEM 6 Information Gathering Session & Results Presentation Portfolio Management Fee Retirement Planning Fee Performance-Based Fees & Side-By-Side Management 6 6 8 9 ITEM 7 Types of Clients 9 ITEM 8 Methods of Analysis, Investment Strategies & Risk of Loss 9 ITEM 9 Methods of Analysis Investment Strategies Managing Risk Retirement Planning Analysis Disciplinary Information 10 11 14 14 15 ITEM 10 Other Financial Industry Activities & Affiliations 15 ITEM 11 Insurance Company Activities & Affiliations Code of Ethics, Participation or Interest in Client Transactions & Personal Trading 15 16 ITEM 12 Code of Ethics Client Transactions Personal Trading Brokerage Practices 16 16 17 17 ITEM 13 Custodial Services Aggregating Trade Orders Review of Accounts 17 18 19 ITEM 14 Portfolio Management Reviews Retirement Planning Reviews Client Referrals & Other Compensation 19 19 19 ITEM 15 Referral Compensation Other Compensation (Indirect Benefit) Insurance Compensation Retirement Rollover Compensation Custody 19 20 20 20 20 ITEM 16 Management Fee Deduction Standing Letters of Authorization Investment Discretion 20 21 21 ITEM 17 Voting Client Securities 22 ITEM 18 Financial Information 22 Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 3 of 22  DISCLOSURE BROCHURE I ADVISORY BUSINESS T E M 4 Who We Are Plan to Prosper Wealth Management1 (hereinafter referred to as “the Company”, “we”, “us” and “our”) is a fee-based2 registered investment advisor3, organized to offer financial services4 designed to assist you, our client5, achieve the financial stability, security, and independence you desire. Owners The following person controls the Company: CRD# Name Title Erick J. Palacios Managing Member & Chief Compliance Officer 4557570 Our Mission Our mission is to be your trusted confidant, a reliable resource with your monetary decisions, and the one to come alongside and assist you with achieving your finance goals as you pursue a better lifestyle focused on addressing today needs, while building tomorrow’s dreams, and preparing the foundation for a sound retirement and lasting legacy for future generations. We will do our best to keep you focused on where you want to go, offer advice on how best to get there, and continually remind you of the importance of maintaining a disciplined investment approach to achieve your financial goals Assets Under Management As of December 31, 2025, our assets under management totaled: Discretionary Accounts ....................................................... Non-Discretionary Account6 ................................................. $201,230,428 $33,088,798 1 Plan to Prosper Wealth Management is the d/b/a name for Palacios Wealth Management, LLC organized as a Florida Limited Liability Company in October of 2014. 2 As a “fee-based” investment advisor, the compensation we receive can include sales commissions in addition to the compensation paid by you, our client, for the portfolio management services we provide. See Item 10, “Other Financial Industry Activities & Affiliations” and Item 14, “Client Referrals & Other Compensation” for disclosure on these services. 3 The term “registered investment advisor” is not intended to imply that Plan to Prosper Wealth Management has attained a certain level of skill or training. It is used strictly to reference the fact that we are “registered” as a licensed “investment advisor” with the United States Securities & Exchange Commission – and “Notice Filed” with State Regulatory Agencies that have limited regulatory jurisdiction over our business practices. 4 Plan to Prosper Wealth Management is a fiduciary, as defined within the meaning of Title I of the Employer Retirement Income Security Act of 1974 (“ERISA”) and/or as defined under the Internal Revenue Code of 1986 (the “Code”) for any financial services provided to a client who is: (i) a plan participant or beneficiary of a retirement plan subject to ERISA or as described under the Code; or (ii) the beneficial owner of an Individual Retirement Account (“IRA”). 5 A client could be an individual and their family members, a family office, a foundation or endowment, a charitable organization, a corporation and/or small business, a trust, a guardianship, an estate, a retirement plan, or any other type of entity to which we choose to give investment advice. 6 All non-discretionary accounts are Retirement Planning assets. We do not manage individual client portfolio assets on a non- discretionary basis. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 4 of 22  DISCLOSURE BROCHURE What We Do We manage wealth and provide financial solutions that stress the importance of you making fiscally responsible decisions and disciplined economic choices in your personal life, so we can effectively help you maximize wealth, maintain investment expectations, and manage risk. Focus of our wealth management begins with identifying your standards of living and quality of lifestyle expectations. We will accomplish this through an initial Information Gathering Session where we will review the financial information, we requested you bring for discussion. Together, questions will be asked, information shared, and an evaluation made as to whether we should move to the next step. During the meeting, we will: v Learn about your core values and guiding principles. v Seek to understand your financial concerns and how you have been addressing them. v Discover your financial objectives and what success looks like for you. v Create an internal profile consisting of your current income and expenses, assets, career objectives, investment goals, risk tolerance and investment time horizon, targeted rate of return, and prior investment experience, along with personal information about your relationships, your values, and interests. Moving forward from the Information Gathering Session, we will define your goals, objectives, and expectations in a Results Presentation to be reviewed with you in a follow up meeting. From that meeting, should you engage us for our wealth management services, the Results Presentation will be what guides us in the management of your account(s), and as a standard against which to measure future results and to make modifications where necessary. Our services include: Portfolio Management We will create and manage a diversified portfolio, allocating your assets among various investments taking into consideration your stated investment objectives. Our management strategies are not limited to any specific product or service; however, the majority of our portfolio allocations will utilize a mix of equity (“stock”) positions, fixed income/debt (“bond”) instruments, derivatives (“options”) contracts, investment company (“mutual fund”) products, exchange traded funds (“ETFs”), structured notes (“buffered notes”) and cash/cash equivalent securities to achieve the best return on your investment capital7. Information regarding our management fee structure is disclosed under “Portfolio Management Fee” in Item 5, “Fees & Compensation” and further description of our investment strategies under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss.” Retirement Planning We can also assist ERISA-qualified retirement and savings plans in the design of the fiduciary governance structure and with the development of an investment management program. Our services under ERISA are to act as a Limited-Scope 3(21) Fiduciary. As such, we acknowledge we have a co-fiduciary role but do not take discretion or act as a 3(38) Fiduciary to construct an investment menu, select and monitor money managers, mutual funds, or ETFs or to replace the investment options within the plan. 7 You may, at any time, impose restrictions in writing on the securities we may recommend (i.e., limit the types/amounts of particular securities purchased for your account, etc.). Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 5 of 22  DISCLOSURE BROCHURE Our responsibility will be to provide the plan sponsors and/or Named Fiduciary of the retirement plan with access to extensive investment tools offered by various retirement planning providers, Third Party Administrators (“TPAs”), to guide them in their duty to implement, maintain, administer, and provide fiduciary oversight of their corporate defined benefit and/or defined contribution retirement plan. Generally, these services will include, but are not limited to: Identifying asset classes and various asset class combinations. v v Diversification and optimization approaches for the plan to effectively control asset allocation decisions and risk management; and, v Educating plan participants on investment options and use of the investment platform menu. You can find more information about our Retirement Planning fees below under “Retirement Planning Fee” in Item 5, “Fees & Compensation.” I FEES & COMPENSATION T E M 5 Information Gathering Session & Results Presentation The Information Gathering Session and Results Presentation are offered without cost or obligation. These meetings provide the opportunity for both parties to get to know each other and for us to share in greater detail how we can address your monetary objectives: v Diagnose your current financial need. v Address your financial concerns and answer your questions on how we can assist you. v Recommend financial resolutions aimed at lowering costs, reducing risks, increasing expected returns, and/or increasing tax efficiency to improve the likelihood of successfully achieving your goal. v Explain our investment methodology and how our investment strategies work; and, v Explain the benefits of portfolio management and how we can address your financial needs beyond just managing your investable assets. From the Information Gathering Session and the Results Presentation that outlined a retirement plan strategy, our objective will be to move forward under an advisory agreement, based on your need. We will prepare the necessary agreements to perform the desired service. If, however, you do not wish to engage us for financial services, you will be responsible for implementing any recommendations coming out of the Information Gathering Session & Results Presentation. All financial services discussed will have been concluded and we are not responsible to implement the advice or for any on-going supervision, monitoring, and/or reporting. Portfolio Management Fee Portfolio management is provided on an asset-based fee8 arrangement. The management fee will be calculated based on the aggregate fair market value (including cash and cash equivalent securities) of your portfolio account(s) on the last business day of the previous calendar quarter multiplied by one-fourth of the corresponding annual percentage rate for 8 An asset-based fee is a percentage fee charged based on your assets under management for our professional time giving continuous advice, managing investment strategies, and suggesting investment options. We receive no other compensation for this advisory service unless first disclosed to you. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 6 of 22  DISCLOSURE BROCHURE each portion of your portfolio assets that fall within each tier (See “Billing” below under “Protocols for Portfolio Management” for formula calculation.). The tier breaks are as follows: Portfolio Value First $2,000,000 ........................................ Annual Fee Rate Not to Exceed 1.00% Over $2,000,000 ........................................ 0.50% We retain discretion to negotiate the management fee within each tier on a client-by-client basis depending on the size, complexity, and nature of the portfolio managed. In addition, for the portion of your portfolio that exceeds into the next tier level, either through additional deposits or asset growth, a fee break will occur. Our management fee will be fully disclosed to you in an advisory agreement prior to conducting any portfolio management services. We generally require a minimum initial investment of $100,000 to open a managed account; however, we retain the right to waive or reduce this minimum if we feel circumstances are warranted. Protocols for Portfolio Management Services The following protocols establish how we handle our portfolio management accounts and what you should expect when it comes to: (i) managing your account; (ii) your bill for investment services; and (iii) other fees charged to your account(s). Discretion Unless otherwise requested by you, we will establish discretionary trading authority on all management accounts to execute securities transactions at any time without your prior consent or advice. You may, however, at any time, impose restrictions, in writing, on our discretionary authority (i.e., limit the types/amounts of particular securities purchased for your account, exclude the ability to purchase securities with an inverse relationship to the market, limit our use of margin or leverage, etc.). Billing Unless you request other arrangements for payment of our management fee, your account will be billed quarterly, in arrears, a blended fee based on the fair market value for the portion of your portfolio (including cash and cash equivalent securities) that fall within each tier of our fee schedule. For example: Annual Fee % (Per Tier) Tier Fee Contribution (Based on the Account Value Within Each Tier) 1.00% 0.50% Account Value: $5,000,000 First $2,000,000 Next $3,000,000 Blended Annual Fee % 0.40% 0.30% 0.70% For new management accounts opened in mid-quarter, our fee will be based upon a pro- rated calculation of your assets managed for the calendar quarter just ending. Advisory fees will be deducted first from any money market funds or cash balances. If such assets are insufficient to satisfy payment of such fees, a portion of the account assets will be liquidated to cover the fees. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 7 of 22  DISCLOSURE BROCHURE Management Fee Exclusions Custodial Fees The above fees for our portfolio management are exclusive of any charges imposed by the custodial firm who has custody of your account; including, but not limited to: (i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges, such as, postage/handling fees, electronic fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-lot differentials and mutual fund short-term redemption fees; and (iv) brokerage and execution costs associated with securities held in your managed account. There can also be other fees charged to your account that are unaffiliated with our management services. Investment Company Fees All fees paid to us for portfolio management services are separate from any fees and expenses charged on mutual fund shares by the investment company or by the investment advisor managing the mutual fund portfolios. These expenses, which we do not share in, generally include management fees and various fund expenses, such as 12b- 1 fees. Redemption fees, account fees, purchase fees, contingent deferred sales charges and other sales load charges may occur but are the exception within managed accounts at institutional custodians. A complete explanation of these expenses charged by the mutual funds is contained in each mutual fund’s prospectus. You are encouraged to carefully read the fund prospectus. For more information on the custodial firm, we recommend to custody your portfolio accounts, see Item 12, “Brokerage Practices”. Termination of Portfolio Management Service To terminate our portfolio management service, either party (you or us) may terminate the advisory agreement at any time by written notification to the other party, provided such written notification is received at least 5 days before the termination date. Such written notice should include the termination date and any final instructions on the account (i.e., liquidate the account, finalize all transactions, and/or cease all investment activity). In the event termination does not fall on the first/last day of a calendar quarter, we shall bill your account a pro-rated management fee based upon the number of days during the quarter we managed your portfolio account from when the termination notice goes into effect. Once we implement the termination of portfolio management services, neither party has any obligation to the other – we no longer earn management fees or give investment advice, and you become responsible for making investment decisions. Retirement Planning Fee As a Limited-Scope 3(21) Fiduciary our responsibility to the plan sponsors and/or Named Fiduciary will be to assist with the development of an investment program menu based on the investment disciplines that most closely resemble the retirement plan’s investment objectives and risk tolerance as outlined in the plan’s Investment Policy Statement. The investment platform menu administered by a Third-Party Administrator (“TPA”) offers: v Access to several mutual fund families to select from. v Customized mutual fund allocation models. v Customized open architecture platform. v Construction tools to implement effective investment portfolios. v Online reporting and account access. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 8 of 22  DISCLOSURE BROCHURE Once the platform menu is in place, we will advise the plan Investment Committee on the performance of each allocation model and make recommendations, if any, on rebalancing and/or replacement of investment options to the platform menu. How Retirement Planning Fees are Billed Retirement planning services are provided on an asset-based fee arrangement and such fees will be administered by the retirement plan Recordkeeper. Management fees are calculated based on the aggregate market value of the assets in the plan on the last business day of the previous calendar quarter multiplied by one-fourth the agreed to annual fee rate. The Recordkeeper will disclose all fees to the plan sponsors and/or Named Fiduciary in a retirement planning agreement and provide copies of any disclosure documents. Our retirement planning fee (not to exceed 1.00%) will be paid to us by the Recordkeeper from the total fees collected. Protocols for Retirement Planning Services The Recordkeeper and TPA’s retirement planning agreement contains all pertinent disclosures relating to the management services being offered: such as, the fee structure for such services, billing, fee exclusions, termination provisions, and any other unique advisory costs associated with servicing the retirement plan. We will discuss all these arrangements with the plan sponsors and/or Named Fiduciary when we go to select the retirement plan Recordkeeper platform; however, the plan sponsors and/or Named Fiduciary is encouraged to read about these retirement planning services on their own. I PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT T E M 6 We do not charge fees based on a share of capital gains or the capital appreciation of the assets held in your accounts. I TYPES OF CLIENTS T E M 7 The types of clients to whom we offer advisory services are described above under “Who We Are” in the Item 4, “Advisory Business” section. Our minimum account size for portfolio management is disclosed above under “Portfolio Management Fee” in Item 5 above in the “Fees & Compensation” section of this Brochure. I METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS T E M 8 Our portfolio management services are designed to build long-term wealth while maintaining risk tolerance levels acceptable to you. We combine your financial needs and investment objectives, time horizon, and risk tolerance to yield an effective investment strategy. Your portfolio is then tailored to these unique investment parameters utilize a mix of equity (“stock”) positions, fixed income/debt (“bond”) instruments, derivatives (“options”) contracts, investment company (“mutual fund”) products, exchange traded funds (“ETFs”), structured notes (“buffered notes”), and cash/cash equivalent securities to achieve the best return on your investment capital. Other investment alternatives may be recommended depending on your unique investment objectives and risk tolerance (i.e., closed-end funds, private hedge funds, and derivatives, such as: commodities). However, these investment vehicles bring on a different risk dynamic. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 9 of 22  DISCLOSURE BROCHURE If we recommend investment in one of these securities, we will discuss with you the limitations of such security and the potential risk factors to your portfolio. Methods of Analysis In analyzing securities to develop an efficient asset allocation portfolio, we will use a combination of analysis techniques to gather information and to guide us in our management decisions. Fundamental Analysis Fundamental analysis is a method of analyzing the intrinsic value of a financial asset, such as a stock or bond, by examining its underlying economic and financial factors. It involves analyzing a company's financial statement and ratios to determine its financial health and growth prospects. The goal of fundamental analysis is to determine whether the current market price of an asset is undervalued, fairly valued, or overvalued. RISKS – Fundamental analysis places greater value on the long-term financial structure and health of a company, which may have little to no bearing on what is actually happening in the marketplace. Investing in companies with sound financial data/strength and a history of healthy returns can be a good long-term investment to hold in your portfolio; however, such fundamental data does not always correlate to the trading value of the stock on the exchanges. In the short-term, the stock can decrease in value as investors trade in other market sectors. Quantitative Analysis Quantitative analysis uses mathematical and statistical models to analyze financial markets and assets. It involves using many data points, such as historical prices, trading volume, and other financial metrics, to identify patterns and trends. This information is used to make investment decisions based on statistical probabilities and risk management principles. RISKS – The key benefit of quantitative analysis is its ability to reduce complex figures to a single piece of data that is easy to grasp, discuss, and support decision-making and investment recommendations. However, quantitative analysis relies on mathematical models and historical data, which may not always be a reliable indicator of future performance and real-world conditions. Technical Analysis Technical analysis utilizes current and historical pricing information to help us identify trends in the broader domestic and foreign equity and fixed income markets, and in the underlying assets themselves. This may involve the use of various technical indicators, such as moving averages and trend-lines, among others. RISKS – Technical analysis is charting the historical market data of a stock, taking into consideration current market conditions, to forecast the direction of a future stock price rather than using fundamental tools for evaluating a company’s financial strength. Technical analysis focuses on the price movement of a security trading in the marketplace. This is an ideal tool for short-term investing to identify ideal market entry/exit points. However, no market indicator is absolutely reliable, and your investment portfolio can underperform in the short-term should the market indicators be incorrect. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 10 of 22  DISCLOSURE BROCHURE Cyclical Analysis Cyclical analysis uses cyclical patterns and economic data to predict economic trends and market movements. It is based on the theory that economic activity follows a predictable expansion and contraction pattern known as the business cycle. We can predict economic growth and market trends by identifying where the economy is in the business cycle. RISKS – Cyclical data reveals regular intervals of repeated events that can be forecasted into the future to time the market on when to buy/sell a security. The risk with cyclical analysis is attempting to buy/sell a security based on a future price prediction and missing beneficial movements in price due to an error in timing. This causes harm to the value of the security being bought too high or sold too low. Behavioral Economics and Market Psychology In additional to the above analysis techniques, we consider behavioral economics and market psychology in our investment and trading decisions. Large groups of investors may act irrationally for periods of time (the herd mentality), and we seek to exploit the mispricing of equities that this may cause. Social media is now a significant factor in the movement of stocks, and we seek to find ways to trade and invest around the volatility that it creates. RISKS – Attempting to predict rational and/or irrational investment tendencies with social media groups is risky due to their whimsical nature not based on any guiding investing principles. This strategy is usually very short-term due to the extreme tendencies of the group but is a great tool to trade securities with good fundamentals that have been affected by the herd mentality. Fundamental analysis provides us with a broad long-term view of a security that begins with determining a company’s value and the strength of its financials while quantitative analysis assists us with portfolio optimization techniques. Technical analysis is short-term focusing on the statistics generated by market activity, behavioral economics is also short-term but mostly focuses on social trends and the political, societal mood for the day and, cyclical analysis provides us with historical data on market trends to focus our technical/behavioral analysis for optimal entry/exit points. Investment Strategies We are not bound to a specific investment strategy or ideology for the management of your investment portfolio. We understand markets and money made from increased stock values has greater risk (volatility) than money earned from dividends (secure and stable) in income- oriented securities. Our goal is to balance making and earning money by maintaining a disciplined management approach, regardless of the strategy, so as to not sacrifice long-term goals for short-term gains. Asset Allocation Strategy Asset allocation is a broad term used to define the process of selecting a mix of asset classes and the efficient allocation of capital to those assets by matching rates of return to a specified and quantifiable tolerance for risk. From this we may use more narrow and aggressive asset allocation derivatives. Other features of our asset allocation strategies can utilize these portfolio-modeling structures for analyzing various possible portfolio groupings of securities. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 11 of 22  DISCLOSURE BROCHURE Modern Portfolio Theory Modern Portfolio Theory (“MPT”)9 is the analysis of a portfolio of stocks as opposed to selecting stocks based on their unique investment opportunity. The objectives of MPT is to determine your preferred level of risk and then construct a portfolio that seeks to maximize your expected return for that given level of risk. Post-Modern Portfolio Theory Post-Modern Portfolio Theory (“PMPT”)10 is a portfolio optimization methodology that uses the downside risk of returns instead of the mean variance of investment returns used by MPT. Both theories describe how risky assets should be valuated, and how you should utilize diversification to achieve portfolio optimization. The difference lies in each theory's definition of risk, and how that risk influences expected returns. Strategic Allocation Modeling Strategic asset allocation is a strategy that involves setting target allocations for various asset classes, then periodically rebalancing the portfolio back to the original allocations when target allocations deviate significantly from the initial setting due to differing returns from various assets. Tactical Allocation Modeling Tactical asset allocation is a dynamic investment strategy that actively rebalances a portfolio allocation mix to take advantage of short-term market pricing anomalies or strong market sectors. Sharpe Ratio Model Sharpe Ratio11 is a risk-adjusted measure of return often used to evaluate the performance of a portfolio. The Sharpe Ratio is the average return earned in excess of the risk-free rate per unit of volatility. Core-Satellite Approach Core-Satellite is an investment strategy that blends a static (passive) and dynamic (active) investment management style to achieve more consistent tracking to asset class benchmarks. The objective behind the core-satellite approach is that most of the portfolio will be dedicated to matching its benchmark with low risk, while a smaller allocation will target enhanced returns so that, when the two elements are combined, the portfolio is potentially able to beat its benchmark in a risk-controlled manner. Value Investing Strategy Value Investing involves selecting securities that trade for less than their intrinsic values, being more concerned with the business and its fundamentals than other influences on the stock’s price. Value investing is about findings stocks or funds invested in stocks that we believe the market has undervalued and out of favor with the market creating a deflated 9 The “Portfolio Theory” was developed and introduced by Harry M. Markowitz in his paper “Portfolio Selection” published in 1952 by the Journal of Finance while he was working on his PhD doctoral thesis at the University of Chicago. Mr. Markowitz further refined his theory during the latter part of the 1950’s and on into the 70’s. Along the way, his theory became known as the “Modern Portfolio Theory”. Mr. Markowitz won the Nobel Memorial Prize in Economic Sciences in 1990 as a co-laureate along with William Sharpe. 10 PMPT was conceived in 1991 when software designers Brian M. Rom and Kathleen Ferguson perceived there to be significant flaws and limitations with software based on MPT and sought to differentiate the portfolio construction software developed by their company, Investment Technologies. The theory uses the standard deviation of negative returns as the measure of risk, while MPT uses the standard deviation of all returns as a measure of risk 11 Nobel laureate and economist William F. Sharpe developed the Sharpe Ratio. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 12 of 22  DISCLOSURE BROCHURE stock price. If we find that a company’s fundamentals reveal the stock to be undervalued, we may buy the security. Bond Investing Strategy Our bond investing focuses on an investment portfolio that aims to achieve long-term returns by investing in individual fixed income bonds generally with ratings of BBB or better at the time the investment is made. We also utilize fixed income mutual funds and ETFs. The investment methodology of the portfolio uses fixed income strategies designed to match the portfolio to your current and future income needs. We periodically assess our fixed income portfolios with regards to duration (interest rate sensitivity), industry and sector weightings, convexity, and yield to maturity, liquidity and quality - the key factors that determine fixed income market performance. Option12 Investing Strategy While options, as derivatives, often are unfairly labeled as “risky” investments, we feel that options – when used properly – are a vehicle to provide superior risk adjusted returns. We employ options to limit downside risk while capturing upside gains. Our typical option strategies are described below: v Covered Call – An investor who buys or owns stock and writes call options in the equivalent amount can earn premium income without taking additional risk. The premium received adds to the investor’s bottom line regardless of outcome. It offers a small downside “cushion” in the event the stock slides downward which can also be used to provide additional income. v v Cash-Secured Put – The cash-secured put involves writing a put option and simultaneously setting aside sufficient cash to purchase the security in question should the option be exercised. The goal is to earn income in the form of option premium while waiting for the possibility of acquiring the stock below today’s market price. A feature of the cash-secured put is that the total value at risk will always be less than an outright purchase. Index Put Option Purchase – One of the most common strategies is to hold a portfolio of individual stocks that we expect to outperform the market as a whole while purchasing a like amount of out-of-the-money Index Put Options. This strategy gives up a bit of upside in the form of insurance premiums on the Index Puts but helps to protect the portfolio against sharp and severe drawdowns. v Stock Replacement – In certain circumstances, we may seek to gain exposure to a particular stock or ETF by purchasing call option contracts on that security rather than by buying the security itself. This strategy can provide leveraged exposure to a desired security with relatively limited downside risk as losses are limited the amount of premium spent for the options while the upside potential of such trades may be many times the premium invested. The relative risk of this strategy vs. an outright purchase is that the security in question fails to move in any direction for a period of time while the options decay in value and any dividends that would have been earned by owning the underlying security are foregone. v Option Spreads – At times, when market conditions dictate, we may employ other option spread strategies such as Calendar Spreads, Verticals, Collars, and Spreads where we sell an out-of-the money put or call spread to buy a similarly priced call 12 Prior to any option trading activity, you will receive the “Characteristics and Risks of Standardized Options” produced by the Chicago Board Options Exchange. It is mutually understood between you and us, that you have read this document prior to engaging us to perform option trading activities. The “Characteristics and Risks of Standardized Options” thoroughly explain the risks and rewards associated with option trading. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 13 of 22  DISCLOSURE BROCHURE or put. In all cases we do not sell naked options (i.e., we never enter into option positions with unlimited downside risk.). Structured Notes We may recommend structured notes when appropriate based on your investment objectives, risk tolerance, financial circumstances, liquidity needs, and overall investment strategy. Structured notes are investments whose return is linked to the performance of an underlying asset, index, interest rate, commodity, currency, or other benchmark. They are generally issued by banks or other financial institutions and may be designed to provide income, enhanced yield, downside protection, or other investment outcomes. Structured notes involve risks that may be greater than those associated with traditional investments. v Issuer Credit Risk – Structured notes are obligations of the issuing financial institution. If the issuer experiences financial difficulties or becomes insolvent, you could lose some or all your investment, regardless of the performance of the underlying asset. v Market Risk – The value of a structured note depends on the performance of the underlying asset or benchmark and may decline in value. You may lose some or all your principal. v Liquidity Risk – Structured notes are generally intended to be held until maturity. A secondary market may be limited or unavailable, and should you choose to sell before maturity may result in you receiving substantially less than the amount originally invested. v Cost and Valuation Risk – Structured notes may include embedded costs, such as issuer compensation, hedging expenses, and distribution costs. Their value before maturity may be affected by factors other than the performance of the underlying asset, including interest rates, market volatility, time remaining until maturity, and changes in the issuer’s financial condition. v Complexity and Limited Return Risk – Structured notes may contain features that limit gains, condition payments on certain events, permit early redemption by the issuer, or otherwise affect performance. As a result, you may not fully participate in gains of the underlying asset and may earn less than you would through other investments. v Tax Risk – Structured notes may have complex tax consequences. You should consult your tax advisers regarding the tax treatment of these investments. The Company performs due diligence before recommending structured notes and considers factors such as issuer creditworthiness, liquidity, costs, complexity, client suitability, and available alternatives. However, all investments involve risk, and there can be no assurance that any investment strategy will be successful Managing Risk The biggest risk to you is the risk that the value of your investment portfolio will decrease due to moves in the market. This risk is referred to as the market risk factor, also known as variability or volatility risk. Other important risk factors: v Interest Rate Risk – Interest rate risk affects the value of bonds more than stocks. Essentially, when the interest rate on a bond begins to rise, the value (bond price) begins to drop; and vice versa, when interest rates on a bond fall, the bond value rises. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 14 of 22  DISCLOSURE BROCHURE v Equity Risk – Equity risk is the risk that the value of your stocks will depreciate due to stock market dynamics causing one to lose money. v Currency Risk – Currency risk is the risk that arises from the change in price of one currency against that of another. Investment values in international securities can be affected by changes in exchange rates. v Liquidity Risk – A financial risk where a company is unable to meet short-term financial obligations without selling either hard-assets or finding another way to reduce the discrepancy between cash flow and debt obligations. Inflation Risk – The reduction of purchasing power of investments over time. v v Commodity Risk – Commodity risk refers to the uncertainties of future market values and the size of future income caused by the fluctuation in the prices of commodities (i.e., grains, metals, food, electricity, etc...). The risk factors we have cited here are not intended to be an exhaustive list but are the most common risks your portfolio will encounter. Other risks that we haven’t defined could be political, and over-concentration to name a few. However, notwithstanding these risk factors, the most important thing for you to understand is that regardless of how we analyze securities or the investment strategy and methodology we use to guide us in the management of your investment portfolio, investing in a security involves a risk of loss that you should be willing and prepared to bear; and furthermore, past market performance is no guarantee that you will see equal or better future returns on your investment. Retirement Plan Analysis Our methods of analysis, investment strategies and managing risk will, for the most part, follow what we have disclosed above for investment management; except that, we are bound to the investment objectives as outlined in the retirement plan’s Investment Policy Statement and to the type of investments allowed by the custodian and recordkeeping platform. Investments are limited to mutual funds, ETFs, and in some cases, advisor managed models and self-directed brokerage accounts. Focus of our selecting, monitoring, and replacing investments on the plan platform is to balance investment return and risk, with the emphasis on spreading risk among asset classes. We will perform an evaluation and review of current/prospective investments to determine which investments to include and/or to leave on the plan platform as well as when to replace existing investments. I DISCIPLINARY INFORMATION T E M 9 We have no legal or disciplinary events to report. I OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS T E M 1 0 Insurance Company Activities & Affiliations All of our management persons are licensed as life and annuity insurance agents by the State of Florida and as non-resident agents in other states. As agents, these management persons are licensed to sell insurance-related products and earn commissions from the sale of these products. A conflict of interest can potentially occur when these management persons, as trusted advisors managing your portfolio for a fee, recommend you purchase an insurance product in which they will earn a commission. This can create a situation of divided loyalty Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 15 of 22  DISCLOSURE BROCHURE and the objectivity of the advice rendered could be subjective and create a disadvantage to you. Therefore, keep in mind you are under no obligation to accept these management persons recommendations to purchase insurance related products. You are free to reject their recommendation or, if you need the insurance, to choose the insurance agency, agent, and insurance company from whom to purchase the insurance. However, if you elect to purchase the insurance, regardless of where, and from whom you purchase it, such person will be entitled to earn a commission. More information on the potential conflicts and economic benefits from being a licensed insurance agent can be found in each of our management persons “Brochure Supplements.” I CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING T E M 1 1 Code of Ethics As a fiduciary, the Company has an affirmative duty to render continuous, unbiased investment advice, and at all times act in your best interest. To maintain this ethical responsibility, we have adopted a Code of Ethics that establishes the fundamental principles of conduct and professionalism expected by all personnel in discharging their duties. This Code is a value- laden guide committing such persons to uphold the highest ethical standards, rooted in the most elementary decorum. Our Code of Ethics is designed to deter inappropriate behavior and heighten awareness as to what is right, fair, just and good by promoting: v Honest and ethical conduct. v Full, fair and accurate disclosure. v Compliance with applicable rules and regulations. v Reporting of any violation of the Code. v Accountability. To help you understand our ethical culture and standards, how we control sensitive information and what steps have been taken to prevent personnel from abusing their inside position, a copy of our Code of Ethics is available for review upon request. Client Transactions We have a fiduciary duty to ensure that your welfare is not subordinated to any interests of ours or of our personnel. The following disclosures are internal guidelines we have adopted to assist us in protecting all of our clientele. Participation or Interest It is against our policies for any owners, officers, directors and employees to invest with you or with a group of clients, or to advise you or a group of clients to invest in a private business interest or other non-marketable investment unless prior approval has been granted by our Chief Compliance Officer, and such investment is not in violation of any SEC and/or State rules and regulations. Insider Trading Policy We comply with the Insider Trading and Securities Fraud Enforcement Act of 1988. We do not share any non-public information with anyone who does not need to know and have established internal controls to guard your personal information. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 16 of 22  DISCLOSURE BROCHURE Class Actions, Bankruptcies, and Other Legal Proceedings Policy The Company does not elect to participate in class action lawsuits on your behalf. Such decisions shall remain with you or with an entity you designate. We will neither advise nor act on your behalf in legal proceedings involving companies whose securities are held in your account(s), including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, you may direct us to transmit copies of class action notices to you or a third party or to relate requested claim form information to you or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. Personal Trading Employees of ours are permitted to personally invest their own monies in securities, which may also be, from time to time, recommended to you. Sometimes, such investment purchases are independent of, and not connected in any way to, the investment decisions made on your behalf. However, there may be instances where investment purchases for you may also be made, at or about the same time, in an employee’s account. This practice can create a conflict of interest as our employees may benefit from the sale and purchase of those securities. In these situations, we have implemented the following guidelines in order to ensure our fiduciary integrity: 1. No employee acting as an Investment Advisor Representative (“IAR”), or who has discretion over your account, shall buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment, unless the information is also available to the investing public on reasonable inquiry. No employee of ours shall prefer his or her own interest to that of yours or any other advisory client. 2. Our Chief Compliance Officer reviews securities holdings for all our access employees on a regular basis. 3. We require that all employees act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 4. Bunched orders (See “Aggregating Trade Orders” below under Item 12, “Brokerage Practices”) may include employee accounts. In such cases, priority and advantage will be given to satisfy your order first regardless of the situation. 5. Any individual not in observance of the above may be subject to termination. Personal trading activities are monitored by our Chief Compliance Officer to ensure that such activities do not impact your security or create conflicts of interest. I BROKERAGE PRACTICES T E M 1 2 Custodial Services The Company maintains a custodial relationship with Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer and member of FINRA/SIPC, through Schwab Advisor Services, a business unit that provides custodial services to independent investment advisers. Schwab provides services including custody of client assets, trade execution, clearance, and settlement of transactions. While we do not have a soft-dollar arrangement with Schwab, we receive certain economic and administrative benefits from Schwab Advisor Services that are not typically available to retail clients of Schwab. These benefits create a potential conflict of interest because they Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 17 of 22  DISCLOSURE BROCHURE provide an incentive for us to recommend Schwab as custodian. The benefits we receive include, but are not limited to: v Access to electronic systems for order entry, account information, and reporting. v Receipt of duplicate client statements and trade confirmations. v Access to trading and operational support services, including a dedicated trading desk. v Access to batch trading capabilities for the aggregation and allocation of transactions. v The ability to have advisory fees deducted directly from client accounts. v Access to educational, practice management, and consulting resources. These benefits are not paid for with client commissions and do not constitute soft-dollar arrangements. We are not affiliated with Schwab, and Schwab does not supervise or direct the investment advice we provide. We retain sole responsibility for the investment advice rendered to clients. Direction of Transactions and Best Execution As a fiduciary, we seek to obtain best execution for client transactions, taking into account factors such as execution capability, transaction costs, financial strength, responsiveness, and the overall quality of services provided. The custodial support services and benefits we receive from Schwab create a potential conflict of interest, as they provide an incentive to recommend Schwab as custodian. We address this conflict by periodically evaluating Schwab’s services and pricing and by determining that Schwab’s overall services are reasonable and appropriate for our clients. We generally recommend Schwab as custodian and do not routinely offer clients a selection of alternative custodians. Clients are not required to use Schwab and may select a different custodian; however, doing so may limit our ability to provide certain services and may result in additional costs to the client. Aggregating Trade Orders Our objective in order execution is to act fairly, impartially, and to take all reasonable steps to obtain the best possible results (known as “best execution”) for our clients. Therefore, we typically bunch (aggregate) orders for a block trade when: (i) the bunching of orders is done for the purpose of achieving best execution; and, (ii) no client is systematically advantaged or disadvantaged by bunching the orders. In consideration of these objectives, we will take into account the unique execution factors of the buy/sell order before bunching accounts for a block trade. A few of those factors are: v Security Trading Volume – Bunching orders in a block trade can secure price parity and continuity for our clients during heavy trading activity. v Number of Clients – The fewer the number of client accounts involved in the bunched order may not yield better pricing or order execution; it may be more advantageous to perform an individual market order for each client. In addition, preparing individual market orders, for the small number accounts involved, may be quicker to complete than preparing a bunch order. v Financial Instruments – The type of security involved as well as the complexity of order can affect our ability to achieve best execution. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 18 of 22  DISCLOSURE BROCHURE I REVIEW OF ACCOUNTS T E M 1 3 Portfolio Management Reviews Your investment strategies and investments are monitored by Erick J. Palacios and reviewed on an on-going basis by the Investment Advisor Representative (“IAR”) managing your account. The general economy, market conditions, and/or changes in tax law can trigger more frequent reviews. Cash needs will be adjusted as necessary. Material changes in your personal/financial situation and/or investment objectives will require additional review and evaluation for us to properly advise you on revisions to previous recommendations and/or services. However, it is your responsibility to communicate these changes for us to make the appropriate corrections to your management account(s). You will receive statements, at least quarterly, from Schwab where your account(s) are held in custody that identifies your current investment holdings, the cost of each of those investments, and their current market values. You are encouraged to review the trading activities disclosed on your account statements from these institutions, which summarizes your portfolio account value, current holdings, and all account transactions made during the quarter. It is important for you to review these documents for accurate reporting and to determine whether we are meeting your investment expectations. Retirement Planning Reviews Erick J. Palacios will supervise the Investment Adviser Representative (“IAR”) assigned to conduct at least an annual review of fund data for investments held in the retirement plan and to assess whether such investments continue to perform in a manner consistent with the objectives and guidelines set forth in the Investment Policy Statement. The plan’s administrator and named fiduciary are responsible for reviewing and understanding the information and analysis we provide and assessing the adequacy of any particular investment’s overall performance. We assist the named fiduciary in fulfilling this responsibility. I CLIENT REFERRALS & OTHER COMPENSATION T E M 1 4 Referral Compensation We may directly compensate persons for client referrals provided such persons are qualified and have entered a referral partner’s agreement with us as required by Rule 206(4)-1 of the Investment Adviser Act of 1940, as amended. Under such arrangements, if a referral partner referred you, the referral partner will provide you complete information on our relationship – the relationship between the referral partner and us – and the compensation the referral partner will receive should you choose to open an account. This compensation will be paid solely from our fee and will not result in any additional charge to you. The referral partner is not licensed to give you any investment advice and therefore cannot advise you on the management of your account. A referral partner simply makes an introduction and is compensated only if you were to open a management account with us under these arrangements. Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 19 of 22  DISCLOSURE BROCHURE Other Compensation (Indirect Benefit) The Company receives an indirect economic benefit from Schwab (See “Custodial Services” above under Item 12, “Brokerage Practices” for more detailed information on what these services and products could be.). Insurance Compensation All of our management persons who are commissioned insurance agents, there is an incentive for them to recommend only those insurance products in which they will receive a commission. Consequently, loyalties could be divided, and the objectivity of our advice could be subjective and create a disadvantage to you. Therefore, you are under no obligation to purchase any insurance products from our management persons. You are free to choose the insurance agency, agent, and insurance company from whom to underwrite our insurance recommendations. Keep in mind that regardless of the agent you select to purchase the insurance from, that person will be entitled to earn a commission from the sale. Retirement Rollover Compensation Earning a management fee from recommending the rollover of retirement plan assets to an IRA we manage is considered “self-dealing” and prohibited unless we comply with the Prohibited Transaction Exemption (“PTE”) 2020-02, “Improving Investment Advice for Workers & Retirees” exemption issued by the Department of Labor (“DOL”). The DOL considers earning a management fee “self-dealing” because it increases our compensation and profits while potentially disregarding the underlying costs paid by, and the services provided under, the retirement plan that might be more beneficial to you should your retirement assets remain with the plan. Therefore, when it comes to your retirement assets, there are typically four options you should consider when leaving an employer: v Leave the account assets in the former employer’s plan, if permitted. v Rollover the assets to the new employer’s plan if one is available and rollovers are permitted. v Rollover the assets to an Individual Retirement Account (an “IRA”); or, v Cash out the retirement account assets (There may be tax consequences and/or IRS penalties depending on your age.). Should you choose to rollover your retirement account assets to an individual IRA account, you understand you are under no obligation to engage us to manage these assets… that you are free to take your IRA account anywhere to be managed. I CUSTODY T E M 1 5 Management Fee Deduction We do not take possession of or maintain custody of your funds or securities but will simply monitor the holdings within your portfolio and trade your account based on your stated investment objectives and guidelines. Physical possession and custody of your funds and/or securities are maintained with Charles Schwab & Company, Inc., as indicated above in Item 12, “Brokerage Practices.” We are however defined as having custody since you have authorized us to deduct our advisory fees directly from your account. Therefore, to comply with the United States Securities and Exchange Commission’s Custody Rule (1940 Act Rule 206(4)-2) requirements, and to protect you Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 20 of 22  DISCLOSURE BROCHURE as well as to protect our advisory practice, we have implemented the following regulatory safeguards: v Your funds and securities will be maintained with a qualified custodian (Schwab) in a separate account in your name. v Authorization to withdraw our management fees directly from your account will be approved by you prior to engaging in any portfolio management services. Schwab is required by law to send you, at least quarterly, statements summarizing the specific investments currently held in your account, the value of your portfolio, and account transactions. You are encouraged to compare the financial data contained in our report and/or itemized fee notice with the financial information disclosed in your account statement from Schwab to verify the accuracy and correctness of our reporting. Standing Letters of Authorization We will allow you to maintain a Standing Letter of Authorization (“SLOA”) with our firm. However, SLOAs with asset transfer instructions to a third-party (e.g., any person/entity/joint account other than just you alone) define us as having custody under the Custody Rule (1940 Act Rule 206(4)-2). Therefore, to comply with the No-Action Letter issued by the SEC, relating to SLOAs and the Custody Rule, we have implemented the following regulatory safeguards and will only accept SLOAs under these conditions: v The person and place of delivery must always be identified in the SLOA instructions. We will not approve any SLOAs where we are authorized to modify the instructions relating to the person and/or place of delivery. v We will not accept SLOA instructions for delivery to a person affiliated with our firm and/or located at our place of business. v The timing and amount of assets to transfer can be open-ended per the instructions of the SLOA. v All SLOA instructions must be in writing and confirmed with your signature. We will not accept verbal changes to any SLOAs. The SEC SLOA No-Action Letter identifies seven (7) steps to follow as part of the safekeeping requirements. The first two bullet-points above are our responsibility under the No-action Letter, the remaining five (5) are the responsibility of the qualified custodian (Schwab). If you would like a complete list of the safekeeping instructions, let us know and we will be glad to provide you a copy. I INVESTMENT DISCRETION T E M 1 6 Unless otherwise requested by you, we have you complete our advisory agreement, which sets forth our discretionary trading authority to buy and sell securities in whatever amounts are determined to be appropriate for your account and whether such transactions are with, or without, your prior approval. You may, at any time, impose restrictions, in writing, on our discretionary authority (i.e., limit the types/amounts of particular securities purchased for your account, exclude the ability to purchase securities with an inverse relationship to the market, limit our use of margin or leverage, etc.). Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 21 of 22  DISCLOSURE BROCHURE I VOTING CLIENT SECURITIES T E M 1 7 We do not vote client proxies. You understand and agree that you retain the right to vote all proxies solicited for securities held in your managed accounts. Schwab, the custodian of your managed accounts, will mail you all proxy solicitations. Any proxy solicitations inadvertently received by us will be immediately forwarded to you for your evaluation and decision. If you have specific questions regarding an action being solicited by the proxy that you do not understand, or you want clarification, you may contact us, and we will explain the particulars. Keep in mind we will not advise you in a direction to vote; the ultimate decision on how you vote is your responsibility and left to you to decide. I FINANCIAL INFORMATION T E M 1 8 We are not required to include financial information in our Disclosure Brochure since we will not take physical custody of client funds or securities or bill client accounts six (6) months or more in advance for more than $1,200. We are not aware of any current financial conditions that are likely to impair our ability to meet our contractual commitments to you. In addition, the Company has not, nor have any of our officers and directors, been the subject of a bankruptcy petition at any time during the past ten years. END OF DISCLOSURE BROCHURE Form ADV: Part 2A Plan to Prosper Wealth Management © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 22 of 22