Powerhouse Financial Advisors, Inc.

Item 1- Cover Page FIRM BROCHURE FORM ADV PART 2A Powerhouse Financial Advisors, Inc. CRD No. 338952 SEC-Registered Investment Adviser Investment Advisers Act of Principal Office 1674 US Hwy 395 N, Suite 208, Minden, NV 89423 (775) 266-8867 www.powerhousefinancialadvisors.com Chief Compliance Officer Steven James Smit CFP® │ CEO │ CCO steve@powerhousefa.com I MPORTANT NOTICE: This brochure provides informaCon about the qualificaCons and business pracCces of Powerhouse Financial Advisors, Inc. (“PHFA” or the “Firm”). If you have any quesCons about the contents of this brochure, please contact us at (775) 266-8867 or steve@powerhousefa.com. The informaCon in this brochure has not been approved or verified by the United States SecuriCes and Exchange Commission (“SEC”) or by any state securiCes authority. AddiConal informaCon about PHFA is available on the SEC’s website at www.adviserinfo.sec.gov. Registra)on as an investment adviser does not imply a certain level of skill or training. Brochure Date: July 31, 2026 Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 1  Item 2. Material Changes This brochure has been updated in connecCon with Powerhouse Financial Advisors, Inc.’s transiCon from state registraCon to registraCon with the U.S. SecuriCes and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940. The following material changes are disclosed as required under SEC rules: ● SEC RegistraCon TransiCon: PHFA has applied for registraCon with the SEC as an investment adviser. Upon SEC effecCveness, PHFA's registraCon with the applicable state securiCes authoriCes will be withdrawn pursuant to a parCal Form ADV-W. PHFA is registered under the Investment Advisers Act of 1940 and applicable SEC rules. ● Howard Capital Management (HCM), CRD #118070 — Two Separate Arrangements: (1) PHFA-Managed SDBA Accounts: PHFA manages Self-Directed Brokerage Accounts (SDBA) within 401(k) plans under PHFA’s own advisory agreement, using HCM’s affiliated mutual funds (HCMPX, HCMDX, HCMKX) as investment vehicles through Charles Schwab. PHFA exercises investment discreCon over these accounts and bills its advisory fee through Orion. These assets are included in PHFA’s regulatory assets under management. HCM’s funds pay 12b-1 shareholder services fees, which creates a conflict of interest when PHFA selects those funds, as disclosed herein. (2) Direct HCM Referrals: PHFA has also entered into a wrinen Investment Advisory SolicitaCon Agreement with HCM, executed February 24–25, 2026, under Rule 206(4)-1 of the Advisers Act. Under this arrangement PHFA refers certain reCrement plan parCcipants directly to HCM as their investment adviser of record. Assets under direct HCM referrals are managed by HCM and are not included in PHFA’s RAUM. PHFA receives a 0.75% annual referral fee from HCM’s mutual fund management fees as revenue sharing. PTE 2020-02 rollover analysis is completed for each eligible reCrement account referral under both arrangements. ● Aspire Financial Services Added as ReCrement Plan Custodian/Recordkeeper: PHFA has engaged Aspire as a recordkeeper for reCrement plan consulCng services. Aspire's fees, PHFA's compensaCon arrangements, and the nature of any economic benefits received are disclosed in Items 5 and 10 of this brochure. ● Jackson NaConal Life Insurance Company Added — Variable Annuity Advisory Fee Arrangement: PHFA has entered into an Onboarding Agreement with Jackson NaConal Life Insurance Company, dated April 20, 2026, authorizing PHFA to administer variable annuity contracts held by PHFA advisory clients and to bill its advisory fee directly from those contract values via fee disbursements. PHFA does not receive commissions on these contracts. This arrangement creates a conflict of interest because fee disbursements reduce clients’ contract values, death benefits, and opConal benefits, and because PHFA has a financial incenCve to recommend clients maintain assets in Jackson NaConal contracts. Full disclosure of this arrangement is in Item 10.A. Pursuant to SEC rules, PHFA will deliver this updated brochure to all exisCng clients within 30 days of SEC effecCveness. Clients may request a copy of this brochure at any Cme, without charge, by contacCng PHFA at steve@powerhousefa.com or (775) 266-8867. Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 2  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 CompensaCon.......................................................................................................................................5 Item 6. Performance-Based Fees and Side-By-Side Management....................................................................................8 Item 7. Types of Clients.....................................................................................................................................................8 Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss..............................................................................8 Item 9. Disciplinary InformaCon........................................................................................................................................9 Item 10. Other Financial Industry AcCviCes and AffiliaCons.............................................................................................10 Item 11. Code of Ethics, ParCcipaCon or Interest in Client TransacCons, and Personal Trading.......................................12 Item 12. Brokerage PracCces............................................................................................................................................12 Item 13. Review of Accounts............................................................................................................................................13 Item 14. Client Referrals and Other CompensaCon..........................................................................................................14 Item 15. Custody...............................................................................................................................................................14 Item 16. Investment DiscreCon.........................................................................................................................................14 Item 17. VoCng Client SecuriCes.......................................................................................................................................15 Item 18. Financial InformaCon..........................................................................................................................................15 Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 3  Item 4. Advisory Business A. Descrip+on of the Firm Powerhouse Financial Advisors, Inc. (“PHFA” or the “Firm”) is a Nevada corporaCon formed in August 2025. PHFA is registered with the U.S. SecuriCes and Exchange Commission as an investment adviser under the Investment Advisers Act of 1940 (“Advisers Act”). Steven James Smit is the Chief ExecuCve Officer, Chief Compliance Officer, and sole owner (100%) of PHFA. Mr. Smit holds the CERTIFIED FINANCIAL PLANNER™ (CFP®) designaCon. B. Descrip+on of Advisory Services PHFA offers the following advisory services: 1. DiscreWonary PorXolio Management PHFA provides conCnuous and ongoing discreConary poruolio management services. PHFA constructs, monitors, and rebalances investment poruolios consisCng of equiCes, fixed income securiCes, mutual funds, exchange-traded funds (ETFs), and other investment vehicles. PHFA tailors each poruolio to the individual client's investment objecCves, risk tolerance, Cme horizon, and financial situaCon as gathered through the client intake process and ongoing reviews. 2. SEI Sub-Advised Program PHFA offers access to the SEI Private Trust Company (“SPTC”) and Capital Bank & Trust (“CB&T”) sub-advisory plauorm. Under this arrangement, client assets are invested in SEI-managed model poruolios. SEI serves as sub-adviser and directs the day-to-day investment decisions within the client's selected strategy. PHFA acts as the introducing adviser, establishes the client relaConship, assists with account opening and strategy selecCon, and monitors the overall suitability of the SEI program for the client. PHFA receives a referral/revenue-sharing porCon of the SEI program fee. PHFA does not charge an addiConal advisory fee on SEI sub-advised accounts. See Item 5 and Item 10 for full disclosure of the SEI fee arrangement. 3. Financial Planning Services PHFA offers comprehensive financial planning services on a fixed-fee or hourly basis. Financial planning services may address reCrement planning, investment planning, tax planning consideraCons, educaCon funding, insurance analysis, estate planning, cash flow analysis, and debt management. Financial planning recommendaCons are based on informaCon provided by the client. ImplementaCon of financial planning recommendaCons through PHFA's investment advisory services may result in addiConal compensaCon to PHFA. 4. ReWrement Plan ConsulWng PHFA provides consulCng services to employer-sponsored reCrement plans, including 401(k) plans, Cash Balance Pension plans, Self-Directed Brokerage Accounts (SDBA), and Personal Choice ReCrement Accounts (PCRA). Services include plan design review, investment menu evaluaCon, investment policy statement development, parCcipant educaCon, and fiduciary support. PHFA manages certain SDBA accounts under its own advisory agreement using HCM’s affiliated mutual funds as investment vehicles, with PHFA’s advisory fee billed through Orion. PHFA may also refer certain reCrement plan parCcipants directly to Howard Capital Management (“HCM”) as their investment adviser under a wrinen solicitaCon agreement. See Items 5, 10, and 14 for complete disclosure of both HCM arrangements. C. Client-Tailored Services and Investment Restric+ons PHFA tailors its advisory services to the individual needs of each client. Prior to the commencement of advisory services, PHFA gathers informaCon regarding the client's investment objecCves, risk tolerance, investment Cme horizon, liquidity needs, and any investment restricCons. Clients may impose reasonable restricCons on the management of their accounts, including restricCons on invesCng in specific securiCes or categories of securiCes. PHFA will Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 4  accommodate reasonable restricCons to the extent pracCcable; however, PHFA may decline to accept or conCnue an advisory relaConship if the restricCons significantly limit PHFA's ability to manage the account in a suitable manner. D. Wrap Fee Programs PHFA does not sponsor or parCcipate in a wrap fee program. E. Assets Under Management As of June 26, 2026, PHFA managed $108,231,666 in client assets on a discreConary basis and $0 in client assets on a non-discreConary basis. These amounts are calculated on the same basis as the regulatory assets under management reported in Item 5.F of Part 1A of Form ADV. Clients and prospecCve clients may obtain current informaCon at www.adviserinfo.sec.gov. Item 5. Fees and CompensaBon A. Discre+onary PorEolio Management Fees PHFA charges fees for discreConary poruolio management services based on a percentage of assets under management (AUM), billed quarterly in arrears at one-quarter of the applicable annual rate. The Cered fee schedule is as follows: AUM Tier Annual Fee Rate Notes First $500,000 1.00% per annum 0.25% billed quarterly in arrears $500,001 – $1,000,000 0.80% per annum 0.20% billed quarterly in arrears $1,000,001 – $2,500,000 0.70% per annum 0.175% billed quarterly in arrears $2,500,001 – $5,000,000 0.60% per annum 0.15% billed quarterly in arrears $5,000,001 – $10,000,000 0.50% per annum 0.125% billed quarterly in arrears Above $10,000,000 0.40% per annum 0.10% billed quarterly in arrears Fees are negoCable in PHFA's sole discreCon. The applicable fee rate is determined by the total value of assets under PHFA's management for each client household, as agreed in the advisory agreement. Poruolio values are calculated based on the market value of assets as of the last business day of each calendar quarter. Advisory fees are deducted directly from client accounts. Clients must grant PHFA wrinen authorizaCon to deduct fees from custodial accounts. The custodian will send account statements showing all fees deducted. Clients are encouraged to review these statements for accuracy. B. SEI Sub-Advised Program Fees Clients who parCcipate in the SEI sub-advised program are charged a single bundled program fee ranging from approximately 0.25% to 2.00% annually, depending on the investment strategy selected. This fee covers SEI's subadvisory services, custody services provided by SPTC or CB&T, and an adviser revenue-sharing component paid to PHFA. PHFA does not charge a separate advisory fee on SEI accounts in addiCon to the program fee. The exact fee applicable to each client is disclosed in the SEI account documentaCon provided at account opening. PHFA receives a porCon of the SEI program fee as compensaCon for its advisory and referral services. This arrangement creates a conflict of interest because PHFA has a financial incenCve to recommend the SEI program. See Item 10 for addiConal discussion. Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 5  C. Financial Planning Fees PHFA charges financial planning fees on a fixed-fee or hourly basis as follows: ● Fixed Fee: $1,500 to $3,000 per engagement, depending on the scope and complexity of services requested. ● Hourly Fee: $350 to $450 per hour. The fee and scope of services are agreed upon in wriCng before services commence. Financial planning fees are not based on assets under management and are not affected by investment performance. A porCon of the fee may be collected in advance; however, PHFA does not collect more than $1,200 more than six months in advance of services rendered. Financial planning clients who also engage PHFA for discreConary poruolio management services may receive a fee credit or reducCon at PHFA's discreCon. D. Re+rement Plan Consul+ng Fees Fees for reCrement plan consulCng services are negoCated on a case-by-case basis, taking into account the number of plan parCcipants, plan assets, and the scope of services. ReCrement plan consulCng fees may be charged as a flat retainer, a percentage of plan assets, or on an hourly basis. All fees and compensaCon arrangements for reCrement plan consulCng are disclosed to the plan sponsor in the applicable services agreement. E. Howard Capital Management — SDBA Accounts and Direct Referral Arrangement PHFA has two separate arrangements with Howard Capital Management (“HCM”), CRD No. 118070, each with disCnct fee and disclosure implicaCons: Arrangement 1 — PHFA-Managed SDBA Accounts: PHFA manages Self-Directed Brokerage Accounts (SDBA) within 401(k) plans under PHFA’s own advisory agreement with the plan parCcipant. PHFA exercises investment discreCon over these accounts, selecCng HCM’s affiliated mutual funds (HCM Dividend Sector Plus Fund (HCMPX), HCM TacCcal Growth Fund (HCMDX), and HCM Income Plus Fund (HCMKX)) as investment vehicles through Charles Schwab. PHFA’s standard advisory fee applies to these accounts and is billed through Orion. These assets are included in PHFA’s regulatory assets under management. The HCM mutual funds carry internal management fees of 0.95%–1.25% annually depending on the fund, and pay 12b-1 shareholder services fees. Because PHFA’s selecCon of HCM funds results in 12b-1 fee payments, PHFA has a conflict of interest in recommending these funds over funds that do not pay such fees. PHFA discloses this conflict to affected clients. Arrangement 2 — Direct HCM Referrals: PHFA also refers certain reCrement plan parCcipants directly to HCM as their investment adviser of record, pursuant to a wrinen Investment Advisory SolicitaCon Agreement executed February 24– 25, 2026, under Rule 206(4)-1 of the Advisers Act. Under this arrangement, HCM manages the assets and is the adviser of record; those assets are not yet included in PHFA’s RAUM. PHFA receives a referral fee of 0.75% annually from HCM’s mutual fund management fees as revenue sharing. This fee does not result in any addiConal charge to the referred client. PHFA has a conflict of interest because it has a financial incenCve to refer clients to HCM rather than other managers. PHFA addresses this by providing a wrinen solicitor disclosure at the Cme of each referral and compleCng a PTE 2020-02 rollover analysis for each eligible reCrement account referral. F. Aspire — Re+rement Plan Recordkeeping PHFA uses Aspire Financial Services as a reCrement plan recordkeeper for certain reCrement plan consulCng clients. Aspire charges its own recordkeeping and administraCve fees directly to plan accounts or plan sponsors. These fees are separate from and in addiCon to any fees charged by PHFA. PHFA does not receive compensaCon directly from Aspire in connecCon with plan referrals. Aspire's fees and services are disclosed in the plan's service agreement. Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 6  G. Jackson Na+onal Life Insurance Company — Variable Annuity Advisory Fee Disbursements PHFA has entered into an Onboarding Agreement for Registered Investment Advisers with Jackson NaConal Life Insurance Company (“Jackson NaConal”), dated April 20, 2026. Under this agreement, PHFA is authorized to administer and service variable annuity (“VA”) contracts issued by Jackson NaConal and held by PHFA advisory clients. PHFA does not receive commissions on Jackson NaConal VA contracts. Instead, PHFA bills its standard advisory fee by direcCng fee disbursements directly from the client’s annuity contract value (“Fee Disbursements”). Fee Disbursements are subject to the following condiCons and limitaCons: (i) each Fee Disbursement request must be submined to Jackson NaConal in good order prior to the close of the New York Stock Exchange on the day requested; (ii) Fee Disbursements in any calendar year may not exceed 1.5% of the total cash value of the contract; (iii) Fee Disbursements reduce the cash surrender value of the contract, the basic death benefit, and may reduce any opConal living or death benefits elected by the client; (iv) Fee Disbursements count as withdrawals under the terms of the contract and are included in the calculaCon of the free withdrawal amount; and (v) Fee Disbursement withdrawals are not available if the client has elected an opConal death or living benefit unless those benefits are explicitly idenCfied as eligible for Fee Disbursements in the contract or any endorsements. Jackson NaConal VA contract values subject to PHFA’s ongoing advisory services are included in PHFA’s regulatory assets under management. The conflicts of interest associated with this arrangement are disclosed in Item 10.A of this brochure. H. Third-Party and Custodial Fees In addiCon to PHFA's advisory fees, clients may incur the following third-party costs and expenses, which are not included in PHFA's fee schedule and are payable to third parCes: ● Custodial Fees: TransacCon commissions, account maintenance fees, and other charges assessed by custodians (Charles Schwab, SEI Private Trust Company, Capital Bank & Trust, or Aspire). These fees are disclosed in the custodian's fee schedule. ● Mutual Fund and ETF Expenses: Internal management fees and operaCng expenses charged by mutual fund and ETF companies, reflected in the fund's expense raCo. These fees are not paid to PHFA. ● HCM Mutual Fund Internal Fees: HCM’s affiliated mutual funds held in PHFA-managed SDBA accounts carry internal management fees of 0.95%–1.25% annually, charged within the fund. These are in addiCon to PHFA’s advisory fee. For accounts referred directly to HCM, HCM’s advisory fee applies and is separate from any PHFA fee. ● Financial Planning So|ware and Data Services: Third-party financial planning tool costs may be incurred by PHFA in providing services; however, PHFA does not pass these costs directly to clients. Clients should review all custodial and third-party account statements and fee disclosures. PHFA's fees are in addiCon to these third-party fees and expenses, and clients will generally pay a higher total cost when mulCple service providers are involved. I. Fee Billing and Account Deduc+on Advisory fees for discreConary poruolio management are billed quarterly in arrears. Fees are calculated based on the market value of assets in the client's account(s) as of the last business day of the applicable calendar quarter. Clients authorize PHFA in their advisory agreement to instruct the custodian to deduct advisory fees directly from the client's account. The custodian will send account statements to clients showing all deducCons, including advisory fees. Clients should review these statements carefully and contact PHFA with any quesCons or discrepancies. PHFA maintains a Billing Error Log and reviews billing calculaCons for accuracy on at least an annual basis. Clients who believe a billing error has occurred should contact PHFA promptly. Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 7  J. Termina+on and Refunds Either party may terminate the advisory agreement upon 30 days' prior wrinen noCce. Upon terminaCon, PHFA will prorate fees for the porCon of the quarter during which services were rendered and refund any unearned prepaid fees, or invoice for fees earned but not yet collected, as applicable. PHFA does not charge early terminaCon fees or penalCes. Item 6. Performance-Based Fees and Side-By-Side Management PHFA does not charge performance-based fees (fees based on a share of capital gains or capital appreciaCon of client assets). PHFA does not engage in side-by-side management of accounts that are charged performance-based fees. Item 7. Types of Clients PHFA provides advisory services to the following types of clients: Individuals (including high net worth individuals) Joint accounts and family accounts Trusts, estates, and charitable organizaCons CorporaCons and business enCCes ● ● ● ● ● Employer-sponsored reCrement plans (401(k) plans, Cash Balance Pension plans) and plan parCcipants PHFA has no minimum account size requirement. Minimum account sizes may be established for specific services, programs, or strategies at PHFA's discreCon. PHFA reserves the right to decline advisory relaConships based on the nature of services requested, account size, suitability consideraCons, or other factors at its reasonable discreCon. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis PHFA uses the following methods of analysis in formulaCng investment advice and managing client poruolios: Fundamental Analysis PHFA evaluates the intrinsic value of securiCes by examining financial statements, management quality, earnings growth, compeCCve posiConing, industry trends, and macroeconomic factors. Fundamental analysis is used primarily in the evaluaCon of individual equity and fixed income securiCes and fund managers. Technical Analysis PHFA may use technical analysis, including review of price trends, momentum indicators, and charCng panerns, to assist in Cming investment decisions or idenCfying entry and exit points. Asset AllocaWon and Modern PorXolio Theory PHFA constructs diversified poruolios based on principles of asset allocaCon and modern poruolio theory, seeking to opCmize the expected risk-return profile of the poruolio consistent with the client's investment objecCves and risk tolerance. Third-Party Research and Sub-Adviser Analysis PHFA may uClize research and analysis provided by third parCes, including Howard Capital Management, SEI, and other investment managers. In the SEI program, SEI's proprietary research and poruolio management process govern the investment decisions within the selected strategy. Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 8  Risk Assessment PHFA conducts ongoing risk assessment of client poruolios, including monitoring for concentraCon risk, liquidity risk, interest rate sensiCvity, and changes in client circumstances. Clients are encouraged to noCfy PHFA of any material changes in their financial situaCon, investment objecCves, or risk tolerance. B. Investment Strategies PHFA employs the following primary investment strategies: Long-term buy-and-hold strategies using diversified poruolios of mutual funds and ETFs Income-oriented strategies using fixed income securiCes, dividend-paying equiCes, and income-focused funds ● ● Asset allocaCon strategies tailored to individual client objecCves and risk profiles ● ● Growth-oriented strategies emphasizing equiCes and equity funds ● ConservaCve strategies emphasizing capital preservaCon with limited equity exposure ● ReCrement income strategies including annuity and insurance product integraCon (through PHFA's affiliated insurance acCviCes — see Item 10) ● SDBA accounts managed by PHFA using HCM’s affiliated mutual funds (HCMPX, HCMDX, HCMKX) as investment vehicles through Charles Schwab C. Risk of Loss All invesCng involves the risk of loss, including possible loss of principal. PHFA does not guarantee any specific investment outcome. Clients should be aware of the following material investment risks: ● Market Risk: The value of investments may decline due to general market condiCons, economic factors, ● poliCcal events, or investor senCment. Interest Rate Risk: Rising interest rates typically cause bond prices to decline, which may reduce the value of fixed income holdings. ● Credit Risk: The issuer of a bond or other fixed income security may default on its obligaCons, resulCng in loss of principal. InflaCon Risk: InflaCon may erode the purchasing power of investment returns over Cme. ● ● ConcentraCon Risk: Poruolios concentrated in specific sectors, geographies, or individual securiCes may experience greater volaClity. Liquidity Risk: Certain investments may not be readily sold at a fair price in a Cmely manner. ● ● Manager Risk (Sub-Advised Accounts): In the SEI program, investment results depend in part on the investment decisions of SEI as sub-adviser. In PHFA-managed SDBA accounts, investment results depend in part on the performance of HCM’s affiliated mutual funds selected by PHFA. For accounts referred directly to HCM, investment results depend on HCM’s management decisions as adviser of record. ● ReCrement Plan Risk: Investments held in reCrement plans are subject to ERISA requirements and early withdrawal penalCes. Plan parCcipants should consult with their tax and legal advisers. ● Model Poruolio Risk: Clients in model-based strategies are invested in the same poruolio as other clients; individual circumstances may not be fully reflected in the model poruolio. Past performance of any investment strategy is not indicaCve of future results. Clients should carefully consider their investment objecCves, risk tolerance, and financial situaCon before invesCng. Item 9. Disciplinary InformaBon Registered investment advisers are required to disclose all material facts regarding legal or disciplinary events that would be material to a client's or prospecCve client's evaluaCon of the firm or the integrity of its management. Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 9  PHFA and Steven James Smit (CRD No. 5849990) have no disciplinary history. There are no legal or disciplinary events required to be disclosed under this Item. Item 10. Other Financial Industry AcBviBes and AffiliaBons A. Licensed Insurance Agent — BackNine Insurance (Fixed and Life Insurance) and Jackson Na+onal Life Insurance Company (Variable Annui+es) Steven James Smit is an independent licensed insurance agent affiliated with BackNine Insurance. In this capacity, Mr. Smit may recommend and sell fixed insurance and life insurance products to PHFA advisory clients. If a client purchases a fixed or life insurance product on Mr. Smit's recommendaCon, Mr. Smit will receive commissions or other compensaCon from the insurance carrier. This creates a conflict of interest because Mr. Smit has a financial incenCve to recommend insurance products, and the compensaCon received may vary depending on the product recommended. Separately, PHFA has entered into an Onboarding Agreement for Registered Investment Advisers with Jackson NaConal Life Insurance Company (“Jackson NaConal”), dated April 20, 2026. Under this agreement, PHFA is authorized to administer and service Jackson NaConal variable annuity (“VA”) contracts held by PHFA advisory clients. This is a disCnct arrangement from the BackNine relaConship: PHFA does not receive commissions on Jackson NaConal VA contracts. Instead, PHFA bills its standard advisory fee by direcCng fee disbursements directly from the client’s annuity contract value (“Fee Disbursements”). This arrangement creates the following conflicts of interest: Fee Disbursements reduce the cash surrender value of the client’s contract, the basic death benefit, and may reduce opConal living and death benefits. Fee Disbursements count against the contract’s annual free withdrawal amount and are capped at 1.5% of total contract value per calendar year. Because PHFA earns its ongoing advisory fee from the Jackson NaConal VA contract, PHFA has a financial incenCve to recommend that clients maintain assets in Jackson NaConal VA contracts rather than moving those assets to other investment vehicles, even if an alternaCve might be more appropriate for the client’s needs at a given Cme. PHFA addresses both the BackNine and Jackson NaConal conflicts by recommending insurance and annuity products only when PHFA believes such products are suitable and in the client’s best interest. Clients are not required to purchase any insurance or annuity product, and doing so is not a condiCon of the advisory relaConship. Jackson NaConal VA contracts not yet reflected in PHFA’s RAUM will be included in future RAUM calculaCons as assets are placed in those contracts and PHFA provides ongoing advisory services with respect to them. PHFA addresses this conflict by disclosing it to affected clients and recommending insurance products only when PHFA believes such products are suitable and in the client's best interest. Clients are not required to purchase insurance products through Mr. Smit, and purchasing insurance through Mr. Smit is not a condiCon of the advisory relaConship. B. SEI Revenue Sharing Arrangement As described in Item 5, PHFA receives a revenue-sharing payment from the SEI program fee paid by clients who parCcipate in the SEI Sub-Advised Program. This creates a conflict of interest because PHFA has a financial incenCve to recommend the SEI program over other investment opCons. PHFA miCgates this conflict by recommending the SEI program only when PHFA believes it is suitable for the client and consistent with the client's investment objecCves. Clients may receive a lower overall fee by invesCng directly in funds outside the SEI program; however, the SEI program provides professional sub-advisory management and associated services that PHFA believes jusCfy the program fee for appropriate clients. C. Tax Prepara+on Referral — Steven James Financial Steven Smit refers PHFA clients to Steven James Financial, a separate tax preparaCon business, and may receive referral compensaCon in connecCon with such referrals. This creates a conflict of interest because Mr. Smit has a financial incenCve to recommend Steven James Financial's tax preparaCon services. Clients are not required to use Steven James Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 10  Financial's services and are free to choose any tax preparer. PHFA discloses the existence and nature of this referral compensaCon arrangement to affected clients. D. Custodian Economic Benefits — Schwab, SEI, CB&T PHFA or its principal may receive economic benefits from custodians, including Charles Schwab InsCtuConal, SEI Private Trust Company, and Capital Bank & Trust. These benefits may include access to technology plauorms, compliance tools, pracCce management resources, research materials, client reporCng systems, and other services that benefit PHFA's business. These benefits create a potenCal conflict of interest because PHFA has an incenCve to recommend these custodians and to maintain client accounts at these custodians in order to conCnue receiving such benefits. PHFA addresses this conflict by selecCng custodians based primarily on service quality, client benefit, and overall suitability for client needs. E. Howard Capital Management (HCM) — Two Separate Arrangements PHFA has two disCnct arrangements with Howard Capital Management (“HCM”), CRD No. 118070, each governed separately and disclosed below: ● PHFA and HCM have executed a wrinen Investment Advisory SolicitaCon Agreement dated February 24–25, 2026, pursuant to Rule 206(4)-1 of the Advisers Act. Under this agreement, PHFA refers reCrement plan parCcipants to HCM-managed investment strategies accessed through SDBA and PCRA accounts at Charles Schwab. PHFA uses only markeCng materials supplied or approved in wriCng by HCM in connecCon with its solicitaCon acCviCes. ● Arrangement 2 — Direct HCM Referrals: PHFA also refers certain reCrement plan parCcipants directly to HCM as their investment adviser of record, pursuant to the wrinen Investment Advisory SolicitaCon Agreement executed February 24–25, 2026, under Rule 206(4)-1 of the Advisers Act. In this arrangement HCM is the adviser of record, HCM manages the assets, and those assets are not included in PHFA’s RAUM. ● HCM is a registered investment adviser and manages the day-to-day investment decisions for assets placed in HCM-managed strategies. HCM performance results and track records belong to HCM and are anributed to HCM, not PHFA, in any markeCng or client communicaCons. ● Under Arrangement 2, PHFA receives a referral fee of 0.75% annually from HCM, paid monthly from HCM’s mutual fund management fees as revenue sharing. This fee does not result in any addiConal charge to the referred client. Because PHFA receives ongoing compensaCon Ced to referred assets, PHFA has a material conflict of interest and a financial incenCve to refer parCcipants to HCM rather than other investment managers. Under both arrangements, HCM’s mutual funds pay 12b-1 shareholder services fees, presenCng an addiConal conflict of interest as described above. ● At the Cme of each referral, PHFA provides the referred parCcipant with a wrinen disclosure describing the nature of the referral arrangement, the compensaCon received by PHFA, and any material conflicts of interest. PTE 2020-02 rollover analysis is completed for each eligible reCrement account referral as required by the Department of Labor. ● Plan sponsors whose parCcipants are referred to HCM through PCRA/SDBA accounts receive appropriate disclosure of the arrangement. ERISA fiduciary obligaCons apply to reCrement account referrals. F. Aspire Financial Services PHFA uses Aspire Financial Services as a reCrement plan recordkeeper for certain reCrement plan consulCng clients. Aspire provides recordkeeping, plan administraCon, and parCcipant services. PHFA's engagement of Aspire is based on service quality and suitability for client needs. PHFA does not receive direct compensaCon from Aspire in connecCon with plan referrals. Aspire charges its own fees to plans and plan sponsors, as disclosed in the applicable service agreement. Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 11  Item 11. Code of Ethics, ParBcipaBon or Interest in Client TransacBons, and Personal Trading A. Code of Ethics PHFA has adopted a Code of Ethics (“Code”) pursuant to Rule 204A-1 under the Advisers Act. The Code establishes standards of conduct expected of all personnel, including the duty to act in a manner consistent with PHFA's fiduciary obligaCons to clients. The Code addresses: ● The duty to put client interests first ● Personal trading policies and pre-clearance requirements ● ProhibiCon on insider trading and misuse of material, non-public informaCon ● Gi|s and entertainment policies ● ReporCng obligaCons for access persons ● ConfidenCality of client informaCon Clients and prospecCve clients may obtain a copy of PHFA's Code of Ethics upon request by contacCng steve@powerhousefa.com. B. Par+cipa+on or Interest in Client Transac+ons PHFA and its associated persons do not buy or sell securiCes for their own accounts in transacCons in which PHFA simultaneously buys or sells the same securiCes for client accounts in a manner that would disadvantage clients. PHFA's Code of Ethics requires that client interests take priority over the personal interests of PHFA and its associated persons. PHFA may invest its own assets or the assets of its principal in the same securiCes recommended to clients. Such personal transacCons may create conflicts of interest if PHFA's principal benefits from price movements caused by client transacCons. PHFA's Code of Ethics and personal trading policies are designed to detect and prevent such conflicts. C. Personal Trading PHFA's Code of Ethics requires access persons to report personal securiCes transacCons and holdings on at least an annual basis. Access persons must obtain pre-clearance for trades in certain securiCes. PHFA reviews personal trading records to idenCfy and address any conflicts of interest or violaCons of the Code. Item 12. Brokerage PracBces A. Custodian Selec+on PHFA recommends that clients establish custodial accounts at one of the following custodians: Charles Schwab InsCtuConal, SEI Private Trust Company (for SEI sub-advised accounts), Capital Bank & Trust (for certain SEI program accounts), or Aspire (for reCrement plan accounts). PHFA is not affiliated with any of these custodians. PHFA recommends these custodians based on the quality and breadth of services offered, execuCon capabiliCes, technology plauorms, client reporCng, and overall value to clients. Clients are not required to use a custodian recommended by PHFA. However, if a client chooses a different custodian, PHFA may not be able to provide all advisory services or to implement investment strategies as efficiently. B. SoW Dollars PHFA does not maintain a formal so| dollar program and does not direct client brokerage to generate so| dollar credits for specific research services. PHFA may enter into so|-dollar arrangements consistent with (and not outside of) the Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 12  safe harbor contained in SecCon 28(e) of the SecuriCes Exchange Act of 1934. PHFA does receive technology, research tools, and pracCce management resources from Schwab and other custodians as described in Item 10.D, which represents an economic benefit from the custodial relaConship. C. Brokerage for Client Referrals PHFA does not direct client brokerage based on the referral of clients by custodians or other third parCes. D. Directed Brokerage PHFA exercises full discreCon over the selecCon of brokers and dealers for client transacCons in discreConary accounts, subject to the client's best interest and the policies described above. Clients may direct PHFA to use a specific broker or dealer in limited circumstances; however, directed brokerage may result in less favorable execuCon prices or increased transacCon costs. E. Trade Aggrega+on PHFA may aggregate or "batch" trades across mulCple client accounts to obtain more efficient execuCon. When trades are aggregated, execuCon prices and transacCon costs are allocated equitably among parCcipaCng accounts. Item 13. Review of Accounts A. Periodic Reviews PHFA reviews client accounts on an ongoing basis. At minimum, PHFA conducts a formal review of each client account at least annually. Reviews address poruolio performance, asset allocaCon, changes in client circumstances, and conCnued suitability of the investment strategy. Steven James Smit, CFP®, CEO, and CCO, is responsible for account reviews. B. Triggering Events for Addi+onal Reviews AddiConal reviews may be triggered by: ● Significant changes in the client's financial situaCon, investment objecCves, or risk tolerance ● Material changes in market condiCons ● Significant deposits, withdrawals, or other account acCvity ● Client request ● Changes in the investment strategy or applicable regulatory requirements C. Client Reports Clients receive regular account statements from their custodian(s), typically on a monthly or quarterly basis. PHFA may also provide performance reports and poruolio summaries at the client's request. Clients are encouraged to review all account statements carefully and noCfy PHFA promptly of any discrepancies. Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 13  Item 14. Client Referrals and Other CompensaBon A. Referral Compensa+on Received by PHFA PHFA may receive compensaCon in connecCon with the referral of clients or reCrement plan parCcipants to third-party service providers, including: ● Howard Capital Management (HCM): PHFA receives a referral fee of 0.75% annually pursuant to a wrinen Investment Advisory SolicitaCon Agreement with HCM dated February 24–25, 2026, under Rule 206(4)-1 of the Advisers Act. This fee is paid monthly from HCM’s mutual fund management fees as revenue sharing and does not result in any addiConal charge to referred clients. At the Cme of each referral, PHFA provides the referred client with a wrinen solicitor disclosure (Exhibit A to the Agreement) describing the referral relaConship, the compensaCon received, and the associated conflicts of interest. The client also receives HCM’s Form ADV Part 2A and privacy noCce prior to engagement. ● Steven James Financial (Tax PreparaCon): Steven Smit may receive referral compensaCon when PHFA clients engage Steven James Financial for tax preparaCon services. This is disclosed to affected clients. ● SEI Revenue Sharing: PHFA receives a porCon of the SEI program fee as described in Items 5 and 10. B. Compensa+on Paid for Client Referrals to PHFA PHFA does not currently pay referral fees to third parCes for the referral of clients to PHFA. If PHFA enters into any solicitor arrangements in the future, such arrangements will comply with the requirements of Rule 206(4)-1 under the Advisers Act, including the requirement for a wrinen agreement and appropriate disclosure to referred clients. C. Economic Benefits from Custodians As described in Item 10, PHFA may receive economic benefits from custodians, including pracCce management support, technology access, compliance tools, and educaConal resources. These benefits are not Ced to specific client referrals and do not result in direct payments to PHFA. Clients do not pay addiConal fees as a result of these arrangements. Item 15. Custody Under Rule 206(4)-2 of the Advisers Act, an investment adviser is deemed to have "custody" of client assets if it holds, directly or indirectly, client funds or securiCes or has authority to obtain possession of them. PHFA is deemed to have limited custody of client assets because PHFA has the authority to instruct custodians to deduct advisory fees directly from client accounts. PHFA addresses this limited custody by: ● Maintaining client assets with qualified custodians (Charles Schwab InsCtuConal, SEI Private Trust Company, Capital Bank & Trust, Aspire); ● Ensuring that custodians send account statements directly to clients at least quarterly; ● Encouraging clients to carefully review all account statements from their custodians and to compare them ● against any reports received from PHFA; LimiCng its ability to deduct fees from client accounts to the amounts agreed upon in the advisory agreement. Clients who do not receive account statements directly from their custodian should contact PHFA or the custodian immediately. PHFA does not maintain physical custody of client assets. Item 16. Investment DiscreBon PHFA accepts discreConary authority to manage client accounts pursuant to wrinen advisory agreements. With discreConary authority, PHFA is authorized to buy, sell, and manage securiCes in client accounts without obtaining client approval for individual transacCons. Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 14  PHFA's discreConary authority is broad but is subject to: ● The investment objecCves, risk tolerance, and guidelines established with the client in the advisory agreement; ● Any reasonable investment restricCons imposed by the client in wriCng; ● PHFA's fiduciary duty to act in the best interest of the client. In the SEI sub-advised program, investment discreCon over the day-to-day poruolio management is delegated to SEI. PHFA retains discreCon over the selecCon of the SEI program strategy and the overall suitability of the SEI program for the client. For PHFA-managed SDBA accounts using HCM mutual funds, PHFA retains full investment discreCon and selects the HCM fund holdings. For accounts referred directly to HCM under the solicitaCon agreement, HCM exercises investment discreCon as the adviser of record. Item 17. VoBng Client SecuriBes PHFA does not vote proxies on behalf of clients. Clients retain the right and responsibility to vote proxies for securiCes held in their accounts. Clients will receive proxy materials directly from the custodian or the issuer. Clients who have quesCons about a parCcular proxy may contact PHFA for general guidance; however, the voCng decision rests with the client. PHFA does not take any acCon with respect to class acCon lawsuits, bankruptcies, or other legal proceedings affecCng client securiCes. Clients should consult their own legal counsel regarding parCcipaCon in any such proceedings. Item 18. Financial InformaBon PHFA does not require or solicit prepayment of fees of more than $1,200, six or more months in advance of services rendered. Accordingly, PHFA is not required to include a balance sheet for its most recent fiscal year in this brochure. PHFA does not have any financial condiCon that is reasonably likely to impair its ability to meet contractual commitments to clients. PHFA has not been the subject of a bankruptcy peCCon at any Cme. CerBficaBon I, Steven James Smit, as Chief Compliance Officer of Powerhouse Financial Advisors, Inc., hereby cerCfy that, to the best of my knowledge and belief, the informaCon in this Form ADV Part 2A Firm Brochure is true, accurate, and complete as of the date set forth above, and that this brochure complies with the applicable requirements of the Investment Advisers Act of 1940 and the rules thereunder. July 31 2026 Date Steven James Smit, CFP® CEO & Chief Compliance Officer Powerhouse Financial Advisors, Inc. Powerhouse Financial Advisors, Inc. — CRD No. 338952 1674 US Hwy 395 N, Suite 208, Minden, NV 89423 | (775) 266-8867 | www.powerhousefinancialadvisors.com SEC-Registered Investment Adviser | Investment Advisers Act of 1940 Powerhouse Financial Advisors, Inc. | Form ADV Part 2A — Firm Brochure | Version Date: July 31 2026 | Powerhouse Financial Advisors, Inc. • Form ADV Part 2A • CRD No. 338952 • Page 15