Overview

Assets Under Management: $2.7 billion
Headquarters: MADISON, CT
High-Net-Worth Clients: 506
Average Client Assets: $5 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (FIRM BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 1.25%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $12,500 1.25%
$5 million $62,500 1.25%
$10 million $125,000 1.25%
$50 million $625,000 1.25%
$100 million $1,250,000 1.25%

Clients

Number of High-Net-Worth Clients: 506
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 85.90
Average High-Net-Worth Client Assets: $5 million
Total Client Accounts: 3,732
Discretionary Accounts: 3,732

Regulatory Filings

CRD Number: 290180
Filing ID: 1981388
Last Filing Date: 2025-04-21 16:43:00
Website: https://principlewealthpartners.com

Form ADV Documents

Additional Brochure: FIRM BROCHURE (2025-04-21)

View Document Text
Principle Wealth Partners, LLC d/b/a Principle Wealth Form ADV Part 2A – Disclosure Brochure Effective: April 21, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Principle Wealth Partners, LLC d/b/a Principle Wealth (“PWP” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact Michael J. Castiello at (203) 318-8892 or by email at mcastiello@principlewealthpartners.com. PWP is a registered investment advisor with U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about PWP to assist you in determining whether to retain the Advisor. Additional information about PWP and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name or CRD# 290180. Principle Wealth Partners, LLC Mailing Address PO Box 1007 Madison, CT 06443 Principal Location 670 Boston Post Road Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of PWP. PWP believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. PWP encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the annual amendment filing on March 19th, 2024: • Principle Wealth Partners is a subsidiary of Principle Wealth Holdings, LLC. Please see Item 4A for more information. • Principle Wealth Partners now offers Trust and Fiduciary Services. Please see Item 4B for more information. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for our firm name or by our CRD# 290180. You may also request a copy of this Disclosure Brochure at any time, by contacting Michael J. Castiello at (203) 318-8892 or by email at mcastiello@principlewealthpartners.com. Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com 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 Services..................................................................................................................................... 4 A. Firm Information ..............................................................................................................................................................4 B. Advisory Services Offered ...............................................................................................................................................4 C. Client Account Management ...........................................................................................................................................6 D. Wrap Fee Programs ........................................................................................................................................................6 E. Assets Under Management .............................................................................................................................................6 Item 5 – Fees and Compensation .......................................................................................................................... 6 A. Fees for Advisory Services ..............................................................................................................................................7 B. Fee Billing ........................................................................................................................................................................7 C. Other Fees and Expenses...............................................................................................................................................8 D. Advance Payment of Fees and Termination ...................................................................................................................8 E. Compensation for Sales of Securities .............................................................................................................................9 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9 Item 7 – Types of Clients ........................................................................................................................................ 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 9 A. Methods of Analysis ........................................................................................................................................................9 B. Risk of Loss ...................................................................................................................................................................10 Item 9 – Disciplinary Information ........................................................................................................................ 11 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 11 A. Code of Ethics ...............................................................................................................................................................11 B. Personal Trading with Material Interest .........................................................................................................................11 C. Personal Trading in Same Securities as Clients ...........................................................................................................11 D. Personal Trading at Same Time as Client.....................................................................................................................12 Item 12 – Brokerage Practices ............................................................................................................................. 12 A. Recommendation of Custodian[s] .................................................................................................................................12 B. Aggregating and Allocating Trades ...............................................................................................................................12 Item 13 – Review of Accounts.............................................................................................................................. 13 A. Frequency of Reviews ...................................................................................................................................................13 B. Causes for Reviews.......................................................................................................................................................13 C. Review Reports .............................................................................................................................................................13 Item 14 – Client Referrals and Other Compensation ......................................................................................... 13 A. Compensation Received by PWP .................................................................................................................................13 B. Compensation for Client Referrals ................................................................................................................................13 Item 15 – Custody.................................................................................................................................................. 13 Item 16 – Investment Discretion .......................................................................................................................... 14 Item 17 – Voting Client Securities ....................................................................................................................... 14 Item 18 – Financial Information ........................................................................................................................... 14 Privacy Policy ........................................................................................................................................................ 15 Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 3 Item 4 – Advisory Services A. Firm Information Principle Wealth Partners LLC (“PWP” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). PWP was organized as a Limited Liability Company (“LLC”) under the laws of the State of Connecticut in 2017. PWP is owned by Principle Wealth Holdings LLC. The majority owner of Principle Wealth Holdings LLC is Robert S. Paolucci (Founder and Chief Executive Officer). PWP is operated by Robert S. Paolucci and Michael J. Castiello (Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by PWP. For information regarding this Disclosure Brochure, please contact Michael J. Castiello at (203) 318-8892 or by email at mcastiello@principlewealthpartners.com. B. Advisory Services Offered PWP offers investment advisory services to individuals, high net-worth individuals, trusts, estates, retirement plans and corporations (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. PWP’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services PWP may provide Clients with wealth management services, which generally includes a broad range of comprehensive financial planning and consulting services in connection with discretionary management of investment portfolios. These services are described below. Investment Management Services – PWP provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing investment management and related advisory services. PWP works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. PWP will then construct an investment portfolio, consisting of diversified mutual funds, exchange-traded funds (“ETFs”) and individual stocks to achieve the Client’s investment goals. The Advisor may also utilize bonds, alternative investments and margin to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. PWP, in very limited circumstances, will retain mutual funds on a fund by fund basis. Due to specific custodial, platform and/or mutual fund company constraints and/or material tax consideration, PWP will retain a mutual fund share class that does not have trading costs, but do have higher internal expense ratios than institutional share classes. PWP will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and stated investment guidelines. PWP’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. PWP will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. PWP evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. The Advisor may recommend employing cash positions as a possible hedge against market movement. PWP may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 4 At no time will PWP accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the agreement, please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services – PWP will typically provide a variety of financial planning and consulting services to Clients, as part of its wealth management services. PWP may also provide standalone financial planning pursuant to a written agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, insurance needs, goal based planning, tax and estate planning, establish education savings and/or charitable giving programs. PWP may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Use of Independent Managers – When deemed to be in the Client’s best interest, PWP will recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with an Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 5 Independent Manager, will be provided with the Independent Manager’s Form ADV 2A (or a brochure that makes the appropriate disclosures). Trust and Fiduciary Services – In certain circumstances and as a part of the Advisor’s Wealth Management Services, the Advisor offers trust and fiduciary services. The Advisor will assist Clients who serve as trustees with trustee-related functions. Such assistance include support with the documentation, accounting, and reporting requirements associated with the trustee’s responsibilities. Clients are under no obligation to engage the Advisor for these services. Retirement Plan Advisory Services PWP provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring Investment Management Services (ERISA 3(38)) Investment Oversight Services (ERISA 3(21)) • Vendor Analysis • Plan Participant Enrollment and Education Tracking • • • • Ongoing Investment Recommendation and Assistance These services are provided by PWP serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of PWP’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging PWP to provide investment advisory services, each Client is required to enter into an agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – PWP, in connection with the Client, may develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – PWP will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client. • Portfolio Construction – PWP will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – PWP will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs PWP does not manage or place Client assets into a wrap fee program E. Assets Under Management As of December 31, 2024, PWP manages $2,658,955,480 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 6 A. Fees for Advisory Services Wealth Management Services Clients engaged for comprehensive wealth management services will be charged a single combined fee for investment management and financial planning services based on the market value of assets under management. Investment advisory fees are paid quarterly, in advance of each quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior quarter. Investment advisory fees range from up to 1.25% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the Advisor. Fees may be reduced if certain asset thresholds are met. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees are negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor, the scope of work required, and the services provided. All securities held in accounts managed by PWP will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing.. Legacy Clients have fee arrangements that may differ from the above fee range. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Use of Independent Managers – As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed the above posted fee schedule. Financial Planning Services For standalone financial planning services, the Advisor will charge a fixed fee ranging up to $5,000 per engagement. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total costs will be determined prior to engaging for these services. Retirement Plan Advisory Services Fees for retirement plan advisory services are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the retirement plan advisory agreement. Retirement plan advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees range up to 1.00% based on the size and complexity of the plan. B. Fee Billing Wealth Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by the number of days in the year, multiplied by the number of days in the quarter) to the total assets under management with PWP at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 7 responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by PWP directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers – For Clients referred by the Advisor to an Independent Manager, the Client’s fee may be separately billed or deducted from the Client’s account[s] with the respective manager and a portion of the investment advisory fee may be provided the respective manager. Financial Planning Services Financial planning fees are invoiced by the Advisor and are due upon execution of the financial planning agreement. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than PWP, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian. One of the Advisor’s recommended Custodians does not charge securities transaction fees for ETF and equity trades in a Client’s account, provided that the account meets the terms and conditions of the Custodian’s brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by PWP are separate and distinct from these custody and execution fees. In addition, all fees paid to PWP for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of PWP, but would not receive the services provided by PWP which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by PWP to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services PWP is compensated for its services in advance of the quarter in which wealth management services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing ten (10) days advance written notice to the other party. The Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers – In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and that Independent Manager. PWP will assist the Client with the termination and transition as appropriate. Financial Planning Services PWP requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 8 termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid planning fees from the effective date of termination to the end of the quarter. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services PWP is compensated for its services in advance of the quarter in which retirement plan advisory services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing ten (10) days advance written notice to the other party. The Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities PWP does not buy or sell securities and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management PWP does not charge performance-based fees for its investment advisory services. The fees charged by PWP are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. PWP does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients PWP offers investment advisory services to individuals, high net-worth individuals, trusts, estates, retirement plans and corporations. The amount of each type of Client is available on PWP’s Form ADV Part 1A. These amounts will change over time and are updated at least annually by the Advisor. The Advisor requires a minimum annual fee of $5,000. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis PWP employs fundamental analysis in developing investment strategies for its Clients. Research and analysis from PWP is derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. As noted above, PWP generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. PWP will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, PWP may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 9 B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. PWP will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bonds time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 10 the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving PWP or any of its management persons. PWP values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider with whom the Client engages. The backgrounds of the Advisor and its Advisory Persons are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching by the Advisor’s firm name or CRD# 290180. Item 10 – Other Financial Industry Activities and Affiliations The sole business of PWP is to provide investment advisory services to its Clients. Neither PWP nor its management persons are involved in other business endeavors. PWP does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics PWP has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with PWP (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. PWP and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of PWP’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of our Code, please contact the Advisor at (203) 318-8892 or via email at mcastiello@principlewealthpartners.com. B. Personal Trading with Material Interest PWP allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. PWP does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. PWP does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients PWP allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities PWP recommends (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, PWP must disclose to Clients and mitigate through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 11 mitigated by PWP requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While PWP allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will PWP, or any Supervised Person of PWP, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] PWP does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer or custodian (herein the "Custodian") to safeguard Client assets and authorize PWP to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, PWP does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where PWP does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by PWP. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. PWP may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, its reputation and/or the location of the Custodian’s offices. PWP will generally recommend that Clients establish their account[s] at Fidelity Clearing & Custody Solutions and other divisions or affiliates of Fidelity Investments, Inc. (“Fidelity”) a FINRA-registered broker-dealers and members SIPC. Fidelity will serve as the Client’s “qualified custodian”. PWP maintains an institutional relationship with the Custodian, whereby the Advisor receives economic benefits from the Custodian. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. PWP does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - PWP does not receive any compensation from any third-party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where PWP will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s] at the Custodian. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). PWP will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the designated Custodian. B. Aggregating and Allocating Trades Although PWP does not aggregate or “batch” trades, the primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the broker. PWP will execute each transaction through the Custodian designated by the Client. PWP will seek to execute securities transactions by the close of each business day in a manner that does not consistently advantage or Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 12 disadvantage any particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of PWP. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A. above, each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account. The Client is encouraged to notify PWP if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by PWP PWP is a fee-only advisory firm, that is compensated solely by its Clients and not from any investment product. PWP does not receive commissions or other compensation from product sponsors, broker-dealers or any un- related third party. PWP may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, PWP may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform As referenced in Item 12 above, the Advisor receives certain economic benefits from the Custodian including support services or products without cost or at a discount. The Advisor’s clients do not pay more for investment transactions effected and/or assets maintained at Custodian as result of this arrangement. There is no corresponding commitment made by the Advisor to Custodian or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products because of the above arrangements. The Advisor’s Chief Compliance Officer, Michael J. Castiello, remains available to address any questions that a client or prospective client may have regarding the above arrangement and the conflicts of interest presented. B. Compensation for Client Referrals PWP does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct PWP to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by PWP to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 13 If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Custody The Advisor is deemed to have custody of certain Client accounts. The Advisor is required to engage an independent accounting firm to perform an annual surprise examination of those assets and accounts over which the related persons maintain custody. Any related opinions issued by an independent accounting firm are filed with the SEC and are publicly available on the SEC’s Investment Adviser Public Disclosure website (http://adviserinfo.sec.gov). Item 16 – Investment Discretion PWP has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by PWP. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by PWP will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities PWP does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information PWP is not required to provide financial information in this Brochure since it does not require the prepayment of more than $1,200 in fees six months or more in advance. PWP, or its management, does not have a financial condition or commitment that would impair the Advisor’s ability to meet contractual and fiduciary obligations to Clients. PWP has never been the subject of a bankruptcy proceeding. Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 14 Privacy Policy Effective: April 21, 2025 Our Commitment to You Principle Wealth Partners (“PWP” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. PWP (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. PWP does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 15 How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Yes Yes No Not Shared Marketing Purposes PWP does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where PWP or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients PWP does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (203) 318-8892 or via email at mcastiello@principlewealthpartners.com. Principle Wealth Partners, LLC Principal Location 670 Boston Post Road Madison, CT 06443 Mailing Address PO Box 1007 Madison, CT 06443 Phone: (203) 318-8892 * Fax: (203) 318-8898 https://principlewealthpartners.com Page 16