View Document Text
ITEM 1 - COVER PAGE
ADV PART 2A
BROCHURE
PRINCIPLED WEALTH
100 EAST RIVERCENTER BLVD., SUITE 810
COVINGTON, KY 41011
P / (859) 957-2737
W / PRINCIPLEDWEALTH.NET
APRIL 22, 2026
This brochure provides information about the qualifications and business practices of Principled Wealth Advisors,
LLC (“PWA”). If you have any questions about this brochure's contents, please contact us at (859) 957-2737. The
information in this brochure has not been approved or verified by the United States Securities and Exchange
Commission (“SEC”) or any state securities authority. PWA is a Registered Investment Adviser (“RIA”). Registration as
an Investment Adviser with the SEC or any state securities authority does not imply a certain level of skill or training.
Additional information about PWA is available on the SEC's website at http://www.adviserinfo.sec.gov/. You can
search this site by a unique identifying number called an IARD number. The IARD number for PWA is 138143.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 1 OF 36
ITEM 2 - MATERIAL CHANGES
SUMMARY OF MATERIAL CHANGES
Under federal and state law, fiduciaries must make full disclosure to Clients of all material facts
relating to the advisory relationship. This brochure provides clients or prospective clients with
information and conflicts of interest about Principled Wealth Advisors, LLC that should be
considered before or when obtaining our investment advisory services. We are required to update
this item to describe the material changes made to this brochure on an annual basis and deliver
to you, within 120 days of the end of the fiscal year, a free updated brochure that includes or is
accompanied by a summary of material changes; or a summary of material changes and an offer
to provide an updated brochure and how to obtain it. We will also provide interim disclosures
regarding material changes, as necessary.
Since our last annual amendment filing on January 30, 2026, the material changes are as follows
are:
• Our firm is transitioning from state registration to SEC registration.
QUESTIONS & CONCERNS
We encourage you to read this document in its entirety. Our Chief Compliance Officer, Jereme
Ransick, remains available to address any questions or concerns regarding this Part 2A Brochure,
including any material change disclosure or information described below.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 2 OF 36
ITEM 3 - TABLE OF CONTENTS
ITEM 1 - COVER PAGE ___________________________________________________________________ 1
ITEM 2 - MATERIAL CHANGES ____________________________________________________________ 2
ITEM 3 - TABLE OF CONTENTS ____________________________________________________________ 3
ITEM 4 - ADVISORY BUSINESS ____________________________________________________________ 4
ITEM 5 - FEES AND COMPENSATION ____________________________________________________ 11
ITEM 6 - PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT ______________________ 15
ITEM 7 - TYPES OF CLIENTS _____________________________________________________________ 15
ITEM 8 - METHODS OF ANALYSIS, STRATEGIES, & RISK OF LOSS ____________________________ 15
ITEM 9 - DISCIPLINARY INFORMATION __________________________________________________ 25
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS ________________________ 25
ITEM 11 - CODE OF ETHICS, PARTICIPATION & INTEREST IN CLIENT TRANSACTIONS, & PERSONAL
TRADING _____________________________________________________________________________ 28
ITEM 12 - BROKERAGE PRACTICES ______________________________________________________ 29
ITEM 13 - REVIEW OF ACCOUNTS _______________________________________________________ 31
ITEM 14 - CLIENT REFERRALS & OTHER COMPENSATION ___________________________________ 31
ITEM 15 - CUSTODY ___________________________________________________________________ 32
ITEM 16 - INVESTMENT DISCRETION _____________________________________________________ 33
ITEM 17 - VOTING CLIENT SECURITIES ___________________________________________________ 34
ITEM 18 - FINANCIAL INFORMATION ____________________________________________________ 34
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 3 OF 36
ITEM 4 - ADVISORY BUSINESS
ABOUT OUR FIRM
Principled Wealth Advisors, LLC is currently registered with the Securities and Exchange Commission
("SEC") as an investment adviser, with its principal place of business located in Kentucky. Principled
Wealth Advisors, LLC has been in business since 2004 and its principal owner is Jereme Ransick. Our
Firm was registered with the SEC as an investment adviser in 2026. Registration as an Investment
Adviser with the United States SEC or any state securities authority does not imply a certain level of
skill or training. Our Firm currently has an office located in 100 East RiverCenter Blvd., Suite 810,
Covington, KY 41011.
This brochure is designed to provide detailed and precise information about each item noted in
the table of contents. Certain disclosures are repeated in one or more items, and other disclosures
are referred throughout to be as comprehensive as possible on the broad subject matters
discussed.
Within this brochure, specific terms in either are used as follows:
PWA refers to Principled Wealth Advisors, LLC.
“Firm,” “we,” “us,” and “our” refer to Principled Wealth Advisors, LLC.
“Advisor,” “Investment Advisor Representative,” and “IAR” refers to our professional representatives
who provide investment recommendations or advice on behalf of Principled Wealth Advisors, LLC.
“You,” “yours,” and “Client” refers to Clients of Principled Wealth Advisors, LLC and its advisors.
“Code” refers to our Firm’s Code of Ethics.
“CCO” refers to our Chief Compliance Officer, Jereme Ransick.
ADVISORY SERVICES WE OFFER
Our Firm offers a variety of advisory services, which include discretionary and non-discretionary
investment management, financial planning, consulting services and assets under advisement,
independent third-party money management and 3(21) retirement services. Before rendering any
preceding advisory services, Clients must enter into one or more written Investment Advisory
Agreements (“Agreements”), setting forth the relevant terms and conditions of the advisory
relationship.
We do not provide tax or legal advice. Clients should consult with an expert on tax or legal issues.
Our Firm manages portfolios for individuals, high-net-worth individuals and families, trusts,
partnerships, retirement plans, corporations, and foundations. With our discretionary relationship,
we will reallocate and rebalance the portfolio as appropriate to help meet the Client’s financial
objectives. We trade Client portfolios based on our Firm’s market views and the Client’s financial
goals. With our non-discretionary relationship, we will provide recommendations to help meet the
Client’s financial objectives, but we must obtain the Client’s approval before making any
transactions in the Client’s account.
With our discretionary relationship, we will reallocate and rebalance the portfolio as appropriate
to help meet your financial objectives. We trade Client portfolios based on our Firm’s market views
and the Client’s financial goals.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 4 OF 36
With our non-discretionary relationship, we will provide recommendations to help meet your
financial objectives, but we must obtain your approval before making any transactions in your
account.
We primarily invest in cash and money markets, equities, American Depositary Receipts (“ADRs”),
fixed income and debt securities, mutual funds, and exchange-traded funds (“ETFs”). A portion of
the account may be held in cash, cash equivalents, or money market funds as part of the overall
investment strategy. Cash balances may have a higher concentration and represent a sizable
portion of the Client’s overall portfolio, depending on the current investment outlook or strategy
A Client’s investment allocation and our strategy will depend on the Client's responses in review
meetings, written questionnaires, stated goals, risk tolerance, objectives, and any Client-directed
preferences for ESG and Impact Investing. Clients are advised to promptly notify the Firm if there
are changes in their financial situation or if they wish to place any limitations on managing their
portfolios.
We do not provide tax or legal advice. Clients should consult with an expert on tax or legal issues.
Any tax or estate planning services provided by the Firm are advisory and consultative in nature
and do not include the preparation of legal documents or tax returns. Our Firm will provide tax
management or planning if engaged to do so.
Our Firm typically requires a minimum account size of $250,000 for advisory accounts. However,
sometimes, at our sole discretion, we may accept smaller accounts based on various criteria, such
as anticipated future assets, related accounts, and other individual Client circumstances.
Clients may impose reasonable restrictions on managing the accounts if the conditions do not impact
the performance of a management strategy.
INVESTMENT GUIDANCE™
Investment Guidance is the baseline level of advisory service provided by PWA. We create
investment strategies that are managed and monitored on an ongoing basis in accordance with
each Client’s stated investment objectives. We use strategies which focus primarily on investment
goals, asset allocation, effective implementation and monitoring.
Investment Guidance™ services may include:
Discovery and documentation of basic Client goals
Basic goal profiling and linking investments to time-horizon and priority categories
Identification of an investment objective profile aligned to portfolios and/or goals
Portfolio construction and asset allocation aligned with stated objectives
Investment manager and strategy selection, including active, passive, and tax efficient approaches
Ongoing investment monitoring and oversight relative to the investment objective profile and Client
goals
Basic portfolio distribution strategies and distribution rate review
Beneficiary designation and account titling recommendations and implementation
Periodic investment reviews and performance reporting in the context of objectives and markets
Investment Guidance™ is included for all advisory Clients regardless of assets under management.
Investment Guidance™ does not include comprehensive financial planning or ongoing
coordination services beyond portfolio management.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 5 OF 36
WEALTH GUIDANCE™
Wealth Guidance™ builds upon Investment Guidance™ by integrating planning, coordination,
and proactive advice across a Client’s broader financial life. At this level, PWA utilizes its principles-
based planning process to align money with what is most important to the Client, emphasizing
progress toward goals rather than investment performance alone while continuing to provide
ongoing investment oversight.
Wealth Guidance™ services may include all Investment Guidance services, plus:
Discovery and documentation of Client goals, values, and financial principles
Comprehensive goal profiling and linking investments to time-horizon, priority categories, and values
Financial condition modeling and Success Likelihood™ Analysis, such as
Tax Planning
Insurance Planning
○ Cash Flow Planning
○
○ Retirement Planning
○ Education Planning
○ Business Owner Planning
○ Social Security & Medicare Strategies
○ Longevity and Health Risk Strategies
○
○ Estate Planning
Ongoing goal progress tracking and reporting
Coordination with outside professionals, including accountants and attorneys
Wealth Guidance™ is generally available to Clients with assets under management of $1,000,000
or more, based on the scope and complexity of the Client’s planning needs. Clients below this
threshold may access Wealth Guidance™ through a separate ongoing services agreement where
the scope of services warrants such engagement.
FAMILY WEALTH GUIDANCE™
Family Wealth Guidance™ represents an expanded level of service offered by PWA. This level is
designed for families with significant wealth, complex planning needs, and intergenerational
considerations requiring enhanced coordination and advisory oversight. Family Wealth Guidance
incorporates Investment Guidance™ and Wealth Guidance™ while addressing both the tangible
and intangible dimensions of family wealth.
Family Wealth Guidance services may include all Wealth Guidance services, plus:
Facilitation and moderation of family and intergenerational meetings
Development and communication of family financial principles and legacy objectives
Inter-family and generational coordination of estate and planning strategies
Coordination of tax planning and execution with the family’s accounting professionals
Advisor roundtable meetings to align attorneys, accountants, and other Advisors
Support for philanthropic planning and charitable strategies
Family Wealth Guidance is generally available to Clients with assets under management of
$10,000,000 or more, based on the scope and complexity of the Client’s planning needs. Clients
with assets below this level may engage Family Wealth Guidance through a separate ongoing
services agreement.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 6 OF 36
SEPARATE FINANCIAL PLANNING, CONSULTING, AND ONGOING SERVICES
In addition to investment advisory services, Clients may engage PWA for financial planning,
consulting services, or ongoing planning services through a separate written agreement. These
services are designed to address specific needs or to provide ongoing planning support
independent of assets under management.
Such services may include:
Standalone or project-based financial planning engagements
Ongoing planning, coordination, and monitoring services
Cash flow, tax coordination, estate planning coordination, and family meetings
Access to PWA planning tools, modeling systems, and Client portals
FINANCIAL PLANNING
The financial planning process is guided by generally accepted financial planning principles and may
address, as applicable and appropriate to the Client’s circumstances, areas such as cash flow and
budgeting, risk management and insurance planning, investment planning, tax planning
coordination, retirement planning, education planning, estate planning coordination, and charitable
or legacy planning.
The scope and depth of analysis within each area will vary based on Client needs, priorities, and the
information provided and does not require that every planning area be addressed in every
engagement. Financial Planning Services do not include ongoing monitoring, updating, or ongoing
coordination services.
CONSULTING SERVICES (PROJECT-BASED OR LIMITED SCOPE)
Consulting services are typically limited in scope and may be provided on a one-time or project
basis. These engagements are designed to address specific questions, decisions, or planning needs
and do not constitute comprehensive or ongoing financial planning unless expressly agreed upon in
writing.
Consulting services are provided on a project-based basis as set forth in the applicable consulting
agreement.
ONGOING WEALTH GUIDANCE™ AND FAMILY WEALTH GUIDANCE™ (NON-AUM
BASED)
Clients may also engage PWA for ongoing Wealth Guidance™ or Family Wealth Guidance™
through a separate ongoing services agreement when such services are not included in the Client’s
investment advisory fee based on assets under management, or when the Client does not maintain
assets under management with the Firm.
Ongoing services agreements are not contingent upon maintaining a minimum level of assets under
management unless expressly stated in the agreement.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 7 OF 36
LEGACY MANAGEMENT SERVICES
Our Firm may advise a Client about legacy positions or other investments in Client portfolios. Clients
can limit or restrict our trading and/or billing in these positions.
INDEPENDENT THIRD-PARTY MANAGER SERVICES
the Client’s accounts.
If deemed appropriate, our Firm will utilize the services of an Independent Third-Party Manager
(“ITPM” or “Investment Managers”)
Investment
to manage
recommendations and securities trading will only be offered by or through the chosen ITPM. Our
Firm will not advise on any specific securities when an account is managed by an ITPM.
Before referring a Client, our Firm will conduct initial due diligence on ITPMs and ongoing reviews
of their management of the Client’s accounts. To assist in selecting an ITPM, our Firm will gather
information about the Client’s financial situation, investment objectives, and reasonable
restrictions to be imposed upon the account management.
Our Firm will periodically review the Investment Manager reports provided to the Client. We will
periodically contact the Client to review their financial situation and objectives, communicate
information to the Investment Manager as warranted, and assist the Client in understanding and
evaluating the services provided. The Client will be expected to notify our Firm of any changes in
their financial situation, investment objectives, or account restrictions that could affect their
financial standing.
By executing an Investment Advisory Agreement with our Firm, the Client gives our Firm the
discretionary authority to select and replace the Investment Manager and to allocate assets
among Investment Managers without obtaining additional Client consent.
The services provided by the ITPM may include:
Assessment of Client investment needs and objectives
Implementation of an asset allocation
Delivery of suitable style allocations (e.g., Income, Large Cap, Small Cap, Growth, Value, etc.)
Facilitation of portfolio transactions
Ongoing monitoring of investment vehicles’ performance
Review of accounts for adherence to policy guidelines and asset allocation
Reporting of the Client’s portfolio activity.
Each Investment Manager has minimum account requirements that will vary between Investment
Managers. Account minimums are typically higher for fixed-income accounts than for equity-
based accounts. A complete description of the Investment Manager’s services, fee schedules,
and account minimums will be disclosed in the Investment Manager’s disclosure brochure, which
will be provided to the Client before or when an agreement for services is executed, and the
account is established.
When an ITPM is engaged, Clients will enter into a separate agreement directly with the Investment
Manager and will receive the Investment Manager’s Form CRS, if applicable, and Form ADV Part
2A. Clients should review the Investment Manager’s disclosure documents carefully to understand
the scope of services, fees, risks, and conflicts associated with the arrangement.
FINANCIAL PLANNING SERVICES
Our Firm offers financial planning services, which involve preparing a written financial plan
covering specific or multiple topics. We provide full written financial plans, which may address one
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 8 OF 36
or several topics: Investment Planning, Retirement Planning, Insurance Planning, Tax Planning,
Education Planning, Portfolios, and Allocation Review.
Unless otherwise agreed to in writing, the Client is solely responsible for determining whether to
implement our financial planning recommendations. Our financial planning services do not involve
implementing transactions on your behalf nor include active and ongoing monitoring or
management of your investments or accounts.
The Client must execute a separate written agreement if the Client elects to implement any of our
investment recommendations through our Firm or retain our Firm to monitor and manage
investments actively.
RETIREMENT PLAN FIDUCIARY AND NON-FIDUCIARY SERVICES
When providing any non-discretionary investment advisory services, we will solely be making
investment recommendations to the Sponsor, and the Sponsor retains full discretionary authority or
control over assets of the retirement plan. We agree to perform any non-discretionary investment
advisory services to the retirement plan as a fiduciary, as defined in ERISA Section 3(21)(A)(ii). The
Sponsor may accept or reject any recommendation. We will act in good faith and with the degree
of diligence, care, and skill that a prudent person rendering similar services would exercise under
similar circumstances.
When providing administrative services, we may support the Sponsor with plan governance and
committee education; vendor management and service provider selection and review;
investment education; or plan participant non-fiduciary education services. We agree to perform
any administrative services solely in a capacity that would not be considered a fiduciary under
ERISA or any other applicable law. Participant education is general in nature and does not include
individualized investment advice unless otherwise agreed in writing.
When we provide investment models and related recommendations to a plan or its fiduciaries for
a fee pursuant to a written agreement, we will act as a “fiduciary” as defined under Section 3(21)
of ERISA and Section 4975 of the Code with respect to such advice. If we provide only general
information or non-fiduciary tools, we will not be acting as an ERISA or Code fiduciary for those
services.
ROLLOVER RECOMMENDATION DISCLOSURE
Our Firm is considered a fiduciary under the Investment Advisers Act of 1940. When we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. We must act in your best interest and not put our interests ahead of yours. At the same
time, how we make money conflicts with Client interests.
A Client leaving an employer typically has four options regarding an existing retirement plan (and
may engage in a combination of these options):
leave the money in the former employer’s plan, if permitted,
roll over the assets to the new employer’s plan, if one is available and rollovers are permitted,
rollover to an Individual Retirement Account (“IRA”), or
cash out the account value (which depending upon the Client’s age, could result in adverse tax
consequences).
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 9 OF 36
Our Firm may recommend a Client rollover plan assets to an IRA for which our Firm provides
investment advisory services. As a result, our Firm and its advisors may earn an asset-based fee on
the rolled assets. In contrast, a recommendation that a Client leave their plan assets with their
previous employer or rollover the assets to a plan sponsored by a new employer will result in no
compensation to our Firm. Therefore, our Firm has an economic incentive to encourage a Client
to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To
mitigate the conflict of interest, there are numerous factors that our Firm will consider before
recommending a rollover, including but not limited to:
the investment options available in the plan versus the investment options available in an IRA,
fees and expenses in the plan versus the fees and expenses in an IRA,
the services and responsiveness of the plan’s investment professionals versus those of our Firm,
protection of assets from creditors and legal judgments,
required minimum distributions and age considerations, and
employer stock tax consequences, if any.
The Chief Compliance Officer remains available to address client questions regarding the
supervision and oversight of rollover and transfer assets.
529 PLAN SERVICE
The Firm offers discretionary investment management for qualified tuition programs (“529 plans”).
Under this service, Clients authorize the Firm in writing to select and manage the investment options
available within the chosen 529 plan without obtaining Client approval prior to each change.
Management generally includes initial allocation selection, periodic monitoring, and rebalancing
or reallocations among available plan options as the beneficiary’s time horizon and the Client’s
objectives evolve.
The Firm’s authority is limited to the investment choices and rules of the selected 529 plan. The Firm
does not have authority to withdraw funds, change account ownership, or change the
beneficiary. Clients are responsible for notifying the Firm of material changes affecting the
account’s management.
CLIENT OBJECTIVES & RESTRICTIONS
Our Firm tailors our investment management and advisory services continuously to meet the needs
of our Clients. We seek to ensure Client portfolios are managed consistently with those needs and
objectives in mind. We meet with Clients on an initial and ongoing basis to assess their specific risk
tolerance, time horizon, liquidity constraints, and other related factors relevant to managing their
portfolios. Clients may impose reasonable restrictions on managing the accounts if the conditions
do not impact the performance of a management strategy.
WRAP FEE PROGRAM
Our Firm does not sponsor or participate in a Wrap Program.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 10 OF 36
REGULATORY ASSETS UNDER MANAGEMENT
As of April 1, 2026, our Firm had $252,109,486 in regulatory assets under management,
approximately $247,420,994 of which was managed on a discretionary basis and $4,688,492 on a
non-discretionary basis.
ITEM 5 - FEES AND COMPENSATION
In addition to the information provided in Item 4 – Advisory Business, this section details our Firm’s
services and each service’s fees and compensation arrangement. The Client and Principled
Wealth Advisors, LLC’s Investment Advisory Agreement will outline and agree upon the exact costs
and other terms related to the Client’s Accounts.
INVESTMENT MANAGEMENT FEE
Our Firm offers investment management services for an annual fee based on the amount of assets
under management. Our maximum annual advisory fee is 1.0%, and we have a minimum account
size of $250,000. We retain the right to waive the minimum account size at our discretion.
Our annual fee is reasonable in relation to (1) the services provided and (2) the fees charged by
other investment advisers offering similar services/programs.
Our annual fee is prorated and charged monthly or quarterly, in arrears, based on the value of the
Client’s assets under management as of the close of business on the last business day of the
previous month or quarter. Cash and cash equivalents, including money market funds, are subject
to the agreed-upon advisory fee. Clients should understand that the advisory fees charged on
these balances may exceed the returns provided by cash, cash equivalents, or money market
funds, especially in low-interest rate environments.
Our Firm retains complete discretion to negotiate fees and may waive or impose different fees on
any Client. The investment advisory fees will be deducted from the Client’s account and paid
directly to our Firm by the qualified Custodian(s) of the Client’s account. The Client will authorize
the Client’s account's qualified Custodian(s) to deduct fees from the account and pay such fees
directly to our Firm. All account assets, transactions, and advisory fees will be shown on the monthly
or quarterly statements provided by the Custodian. The Client should review the Client’s account
statements received from the qualified Custodian(s) and verify that appropriate investment
advisory fees are being deducted. The qualified Custodian(s) will not verify the accuracy of the
investment advisory fees deducted. We may aggregate related Client accounts to calculate the
advisory fee applicable to the Client. The investment management agreement will outline the fee
charged to a Client and any breakpoints based on the level of assets managed. The fees are
subject to change with prior written notice to the Client.
Our annual investment advisory fee may be higher than that of other investment advisers that offer
similar services and programs. In addition to our compensation, the Client may incur charges
imposed at the mutual fund level (e.g., advisory fees and other fund expenses).
Accounts initiated or terminated during a calendar month will be charged a prorated fee based
on the days the Client account was open during that month. Any prepaid, unearned fees will be
refunded upon termination of any account.
Unless identified below under a different service offering, advisory fees shall be subject to the
maximum outlined under this provision. PWA may negotiate this fee at their discretion. Some
accounts will qualify for a lower advisory fee as determined by PWA.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 11 OF 36
LEGACY MANAGEMENT FEE
Managed legacy positions are included within our Firm’s standard investment management fee
and are outlined in the executed investment management agreement.
FINANCIAL PLANNING FEE
Our Firm provides standalone financial planning services under a flat fee arrangement. This
arrangement charges a mutually agreed-upon fee for financial planning services. The range for a
standalone financial plan typically ranges from $2,000 to $30,000 based on the scope and
complexity of the plan.
Fees charged for our financial planning services are negotiable based upon the type of Client, the
services requested, the investment adviser representative providing advice, the complexity of the
Client's situation, the composition of the Client's account, other advisory services provided, and
the relationship of the Client and the investment adviser representative.
The fee for the Client’s engagement is specified in the Client’s financial planning agreement with
us. At our sole discretion, the Client may be required to pay the fee at the time the agreement is
executed with our Firm; however, our Firm does not require or solicit prepayment of more than
$1,200 in fees per Client, six months or more in advance. The fee is considered earned upon delivery
of the financial plan, and any unpaid amount is immediately due.
The Client may pay the fees owed for the financial planning services by submitting payment
directly via a payment processor, check, or by deducting the fee from an existing investment
account. If the Client elects to pay by automatic deduction from an existing investment account,
they will provide written authorization to our Firm for such a charge.
If the Client terminates the financial planning services after entering into an agreement with our
Firm, the Client will be invoiced and responsible for immediate payment of any financial planning
services performed by the Firm before receiving notice of termination.
CONSULTING SERVICES & ASSETS UNDER ADVISEMENT FEE
Our Firm provides consulting services based on a flat fee based on the scope and complexity of
the project. Fees charged for consulting services are negotiable based on the type of Client, the
services requested, the investment adviser representative providing advice, the complexity of the
Client's situation, the composition of the Client's account, other advisory services provided, and
the relationship of the Client and the investment adviser representative. This arrangement charges
a mutually agreed-upon fee for consulting services.
INDEPENDENT SUB-ADVISORY & THIRD-PARTY MANAGER SERVICE FEES
A complete description of the ITPM’s services, fee schedules, and account minimums will be
disclosed in the Investment Manager's disclosure brochure, which will be provided to the Client
before or when an agreement for services is executed, and the account is established. Each third-
party investment adviser is required under federal securities laws to provide their Clients, including
ITPM Clients, with a Form ADV Part 2A (“Adviser Brochure”) that includes disclosures, and among
other things, the fees charged to their Clients.
The actual fee charged to the Client will vary depending on the ITPM. However, the total annual
advisory fee charged by the ITPM will not exceed 1.15%. Fees charged by an Investment Manager
are calculated in accordance with the applicable investment management agreement and may
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 12 OF 36
be deducted from the Client’s account either by the Investment Manager or by the qualified
custodian on behalf of the Investment Manager, depending on the custodial platform or
investment program used.
Our Firm’s advisory fee is separate from and in addition to the fee charged by the Investment
Manager, and our Firm does not receive any portion of the Investment Manager’s advisory fee.
Accordingly, when both our Firm and an Investment Manager are engaged, the Client may pay
combined advisory fees of up to 2.15% annually.
With ITPMs, the Client may incur additional charges, including mutual fund sales loads, 12b-1 fees
and surrender charges, and IRA and qualified retirement plan fees.
Our Firm is committed to always working in the Client's best interest. There may be other Managers
not affiliated with our Firm that may be suitable for a Client or may be more or less costly. As with
any investment adviser, no guarantees can be made that the ITPM will achieve the Client’s
financial goals or objectives. Further, no guarantees of performance can be offered.
Clients should review the ITPM’s Brochure in its entirety, along with this Brochure, to fully understand
the services, fees, agreements, and risks surrounding these arrangements and that these types of
arrangements have layers of fees that may or may not be apparent without reading the ITPM’s
Brochure and this Brochure, along with the offering document/prospectus for underlying
investments.
Schwab does receive other revenues in connection with the automated investment program.
RETIREMENT PLAN FIDUCIARY AND NON-FIDUCIARY FEE
For Retirement Plan Advisory Services compensation, we charge an advisory fee as negotiated
with the Plan Sponsor and as disclosed in the Employer-Sponsored Retirement Plans Consulting
Agreement (“Plan Sponsor Agreement”).
Typically, the billing period for these fees is paid quarterly. This fee is negotiable, but the terms and
the advisory fee are agreed upon in advance and acknowledged by the Plan Sponsor Agreement
or Plan Provider’s account agreement. Fee billing methods vary depending on the Plan Provider.
Our Firm or the Plan Sponsor may terminate the Agreement upon 30 days written notice to the
other party. The Plan Sponsor is responsible for paying for the services rendered until the termination
of the Agreement.
529 PLAN SERVICE FEE
Advisory fees for 529 Plan accounts are assessed using one of the following billing methods,
depending on the capabilities of the applicable 529 Plan program or custodian:
ASSET-BASED ADVISORY FEE (WHERE SUPPORTED)
When the 529 Plan program permits advisory fee deduction directly from the account, the
Firm charges an asset-based advisory fee of up to 0.50% annually, calculated as a percentage
of the market value of the 529 Plan assets under management. This fee is generally billed
quarterly in arrears and deducted directly from the 529 Plan account.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 13 OF 36
FIXED ADVISORY FEE (WHERE ASSET-BASED BILLING IS NOT SUPPORTED)
Certain 529 Plan programs do not support the deduction of advisory fees directly from the
account. In such cases, the Firm charges a fixed annual advisory fee, typically $200 per 529
Plan account, billed directly to the Client outside of the 529 Plan account (e.g., via invoice or
electronic payment) or deducted from another brokerage account.
The advisory services provided to 529 Plan accounts are substantially similar regardless of the
billing method utilized. Differences in billing structure are driven solely by administrative and
operational limitations of the applicable 529 Plan program or custodian.
ADMINISTRATIVE SERVICES PROVIDED BY SERVICE PROVIDERS
Our Firm has contracted with certain portfolio management service providers to utilize their
technology platforms to support data reconciliation, performance reporting, fee calculation,
Client relationship maintenance, quarterly performance evaluations, and other functions related
to managing Client accounts' administrative tasks. Due to this arrangement, these service
providers will have access to Client accounts, but they will not serve as an investment adviser to
our Clients or bill the accounts. Service providers charge Our Firm an annual fee for each account
administered by its software. Please note that our Firm’s annual fee to the service provider will not
increase the Client's fee. Our Firm will pay the annual fee from the portion of the management fee
retained by Our Firm. Our Firm and third-party service providers are non-affiliated companies.
in your Statement from the Custodian. Our firm has the ability to produce billing summaries, which
can be provided upon request.
ADDITIONAL FEES & EXPENSES
In addition to the advisory fees paid to our Firm, Clients also incur certain charges imposed by other
third parties, such as broker-dealers, Custodians, trust companies, banks, and other financial
institutions. These additional charges include securities, transaction fees, custodial fees, fees
charged by the SMA, ITPM, and Investment Manager charges imposed by a mutual fund or ETF in
a Client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other
fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Our brokerage practices are described at length in Item 12 below.
Our Firm’s investment strategies may include mutual and ETFs. Our policy is to purchase institutional
share classes of those mutual funds selected for the Client’s portfolio. The institutional share class
generally has the lowest expense ratio. The expense ratio is the annual fee that all mutual funds or
ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for
funds expenses, including 12b-1 fees, management fees, administrative fees, operating costs, and
all other asset-based costs incurred by the fund. Some fund families offer different classes of the
same fund, and one share class may have a lower expense ratio than another. Mutual fund
expense ratios are in addition to our fees; we do not receive any portion of these charges. If an
institutional share class is not available for the mutual fund selected, the Advisor will purchase the
least expensive share class available for the mutual fund. As share classes with lower expense ratios
become available, we may use them in the Client’s portfolio or convert the existing mutual fund
position to the lower-cost share class. Clients who transfer mutual funds into their accounts with our
Firm would bear the expense of any contingent or deferred sales loads incurred upon selling the
product. If a mutual fund has a frequent trading policy, the policy can limit a Client’s transactions
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 14 OF 36
in fund shares (e.g., for rebalancing, liquidations, deposits, or tax harvesting). All mutual fund
expenses and fees are disclosed in the respective mutual fund prospectus.
When selecting investments for our Clients’ portfolios, we might choose mutual funds on the Client’s
account Custodian’s Non-Transaction Fee (NTF) list. This means that the Client’s account Custodian
will not charge a transaction fee or commission associated with the purchase or sale of the mutual
fund.
The mutual fund companies that choose to participate in the Client’s Custodial NTF fund program
pay a fee to the Custodian to be included in the NTF program. The mutual fund owners bear the
fee that a company pays to participate in the program, as captured in the fund’s expense ratio.
When choosing a fund from the Client’s Custodial NTF list, our Firm considers the expected holding
period, position size, and expense ratio versus alternative funds. Depending on our Firm’s analysis
and future events, NTF funds might not always be in the Client’s best interest.
ITEM 6 - PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT
Performance-based fees are based on a share of capital gains on or appreciation of the assets in
a Client’s account.
Our Firm does not accept performance-based or other fees based on a share of capital gains or
appreciation of a Client's assets.
ITEM 7 - TYPES OF CLIENTS
Our Firm provides investment management, investment advice, financial planning, consulting and
advisement, and third-party portfolio management to individuals, high-net-worth individuals and
families, trusts, partnerships, retirement plans, corporations, and foundations.
Our Firm requires a minimum account value of $250,000 for advisory services. Clients have the
option to aggregate all household accounts to meet this minimum. Exceptions to the minimum
account requirement may be granted based on the Client's relationship with their representative.
For fee calculation purposes, unless instructed or identified otherwise, we may aggregate related
Client accounts, a practice commonly known as "householding" portfolios. Householding may
result in lower fees than if each account were billed separately, as the combined value is used to
determine the account size and the corresponding annualized fee.
Our approach to householding considers the overall family dynamic and relationship. Additionally,
if applicable, and as noted in the Investment Management Agreement, legacy positions may be
excluded from the fee calculation.
Clients must execute a written agreement with our Firm specifying the advisory services to establish
a Client arrangement with us.
ITEM 8 - METHODS OF ANALYSIS, STRATEGIES, & RISK OF LOSS
METHODS OF ANALYSIS
Our basis for investment recommendations is the Nobel Prize-winning concept known as Modern
Portfolio Theory. This theory models how risk may be estimated and how assets may behave in
relation to one another. We focus on the risk of the entire portfolio by considering how each
investment may contribute to the overall risk of the Client’s portfolio. Through this process we
construct an "efficient portfolio" – one which has a high expected return for a given level of risk.
Asset allocation is the process of allocating portfolio funds among various asset classes. Extensive
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 15 OF 36
analysis has been performed which indicates this is by far the most important investment decision.
Asset allocation decisions are derived from broad-based investment research into multiple asset
classes.
Asset allocation recommendations will be by asset classes. At a high level, there are three main
asset classes – equities (stocks), fixed income (bonds), and cash/cash equivalents – each of which
has different risk and reward profiles/behaviors. Asset classes are often further divided into
domestic and foreign investments, and equities are often divided into small, intermediate, and
large capitalization. In addition to the main asset classes we consider real estate investment trusts,
multi-asset objective-based strategies and diversified alternatives (including commodity funds,
hedge funds and managed future funds).
INDEPENDENT THIRD-PARTY MANAGER (ITPM OR INVESTMENT MANAGER)
Our Firm examines the Investment Manager's experience, expertise, investment philosophies, and
past performance to determine if that Investment Manager has demonstrated an ability to invest
over time and in different economic conditions. Our Firm monitors the Investment Manager’s
underlying holdings, strategies, concentrations, and leverage as part of our Firm’s periodic risk
assessment. Additionally, as part of our due diligence process, our Firm surveys the Investment
Manager’s compliance and business enterprise risks.
MUTUAL FUND OR ETF
Our Firm examines the experience and track record of the Investment Manager of the mutual fund
or ETF to determine if that Investment Manager has demonstrated an ability to invest over a period
of time and in different economic conditions.
Our Firm also looks at the underlying assets in a mutual fund or ETF to determine if there is a
significant overlap in the underlying investments held in other funds in the Client’s portfolio. Our
Firm also monitors the funds or ETFs to determine if they continue to follow their stated investment
strategy.
INVESTMENT STRATEGIES
Our Firm may use any of the following investment strategies when managing Client assets and
providing investment advice:
LONG-TERM HOLDING
Our Firm purchases securities with the intent to hold them in the Client's account long-term
(longer than one year). In extreme circumstances, we may be forced to sell a fund completely
within a year of buying it. An example would be a fund Manager resigns, and we do not have
confidence in the new management. Also, fund positions may be trimmed occasionally to
rebalance the portfolio.
A risk in a long-term purchase strategy is that holding the security for this length of time may
decline in value before we decide to sell. We do not guarantee the future performance of
the account or any specific level of performance, the success of any investment decision or
strategy we may use, or the success of the overall management of the account. The Client
understands that the investment decisions our Firm makes for the Client’s account are subject
to various market, currency, economic, political, and business risks and that those investment
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 16 OF 36
decisions will not always be profitable. Clients are reminded that investing in any security
entails the risk of loss, which they should be willing to bear.
STRATEGIC ASSET ALLOCATION
The primary investment strategy used by our Firm is based on the diversification of the Client's
assets among various investment vehicles and asset classes, popularly termed "Asset
Allocation." Our Firm's recommendations focus primarily on achieving a diversified portfolio of
investment assets with desirable risk and return characteristics. We meet regularly to evaluate
new and reevaluate existing investment opportunities. During these meetings, we deliberate
on issues regarding the proper allocation of Client assets based on current conditions.
TACTICAL ASSET ALLOCATION
in various categories
to
is an active management portfolio strategy that shifts the
Tactical asset allocation
percentage of assets held
take advantage of market
pricing anomalies or strong market sectors. This strategy allows portfolio Managers to create
extra value by taking advantage of certain situations in the marketplace. It is a moderately
active strategy since Managers return to the portfolio's original asset mix once reaching the
desired short-term profits.
USE OF ALTERNATIVE INVESTMENTS
If deemed appropriate for your portfolio, our Firm may recommend "alternative investments.”
Alternative investments may include a broad range of underlying assets including hedge
funds, private equity, venture capital, registered, publicly traded securities, structured notes,
and private real estate investment trusts. Alternative investments are speculative, not suitable
for all Clients, and intended for only experienced and sophisticated investors who are willing
to bear the high risk of the investment, which can include: loss of all or a substantial portion of
the investment due to leveraging, short-selling, or other speculative investment practices; lack
of liquidity in that there may be no secondary market for the fund and none expected to
develop; volatility of returns; potential for restrictions on transferring an interest in the fund;
potential lack of diversification and resulting higher risk due to concentration of trading
authority with a single adviser; absence of information regarding valuations and pricing;
potential for delays in tax reporting; less regulation and often higher fees than other investment
options such as mutual funds. The SEC requires investors to be accredited to invest in these
more speculative alternative investments. Investing in a fund concentrating on a few holdings
may involve heightened risk and greater price volatility.
DESCRIPTION OF MATERIAL, SIGNIFICANT OR UNUSUAL RISKS
Our Firm generally invests Client cash balances in money market funds, FDIC Insured Certificates
of Deposit, high-grade commercial paper and/or government backed debt instruments.
Ultimately, our Firm tries to achieve the highest return on Client cash balances through relatively
low-risk conservative investments. In most cases, at least a partial cash balance will be maintained
in a money market account so that our Firm may debit advisory fees for our services related to our
Asset Management and Comprehensive Portfolio Management services, as applicable.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 17 OF 36
RISK OF LOSS
A Client’s investment portfolio is affected by general economic and market conditions, such as
interest rates, availability of credit, inflation rates, economic conditions, changes in laws, and
national and international political circumstances.
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. Our Firm will assist Clients in
determining an appropriate strategy based on their tolerance for risk.
While we are alert to indications that data may be incorrect, there is always a risk that our analysis
may be compromised by inaccurate or misleading information.
ACTIVE MANAGEMENT RISK
Due to its active management, a portfolio could underperform other portfolios with similar
investment objectives or strategies.
ALLOCATION RISK
A portfolio may use an asset allocation strategy to pursue its investment objective. There is a
risk that a portfolio’s allocation among asset classes or investments will cause a portfolio to
lose value or cause it to underperform other portfolios with a similar investment objective or
strategy or that the investments themselves will not produce the returns expected.
ALTERNATIVE RISK
Alternative investments include other additional risks. Lock-up periods and other terms obligate
Clients to commit their capital investment for a minimum period, typically no less than one or two
years and sometimes up to 10 or more years. Illiquidity is considered a substantial risk and will restrict
the ability of a Client to liquidate an investment early, regardless of the success of the investment.
Alternative investments are difficult to value within a Client’s total portfolio. There may be limited
availability of suitable benchmarks for performance comparison; historical performance data may
also be limited.
In some cases, there may be a lack of transparency and regulation, providing an additional layer
of risk. Some alternative investments may involve the use of leverage and other speculative
techniques. As a result, some alternative investments may carry substantial additional risks, resulting
in the loss of some or all the investment. Using leverage and certain other strategies will result in
adverse tax consequences for tax-exempt investors, such as the possibility of unrelated business
taxable income, as defined under the U.S. Internal Revenue Code.
CAPITALIZATION RISK
Small-cap and mid-cap companies may be hindered due to limited resources or less diverse
products or services. Their stocks have historically been more volatile than the stocks of larger,
more established companies.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 18 OF 36
COMPANY RISK
The risk related to a Firm’s business plans, stock valuation, profitability, accounting practices,
growth strategy, and other factors particular to a company rather than the overall market.
Some of these risks cannot be predicted, such as the retirement or death of a senior executive,
which may lead to negative performance in the future.
CONCENTRATION RISK
Strategies concentrated in only a few securities, sectors or industries, regions or countries, or
asset classes could expose a portfolio to greater risk. They may cause the portfolio value to
fluctuate more widely than a diversified portfolio. Overexposure to certain sectors or asset
classes (e.g., MLPs, REITs, etc.) may be detrimental to an investor if there is a negative sector
move.
CREDIT RISK
The credit rating of an issuer of a security is based on, among other things, the issuer’s historical
financial condition and the rating agencies’ investment analyses at the time of rating. An
actual or perceived deterioration of the ability of an issuer to meet its obligations would harm
the value of the issuer’s securities.
CURRENCY RISK
If an account invests directly in non-U.S. currencies or in securities that trade in and receive
revenues in non-U.S. currencies or in derivatives that provide exposure to non-U.S. currencies,
it will be subject to the risk that those currencies will decline in value relative to the U.S. dollar.
Currency rates in foreign countries may fluctuate significantly over short periods for several
reasons, including changes in interest rates, intervention (or the failure to intervene) by U.S. or
foreign governments, central banks, or supranational entities such as the International
Monetary Fund, or by the imposition of currency controls or other political developments in
the United States or abroad. As a result, an account’s investments in non-U.S. currency-
denominated securities may reduce the account's returns. Foreign currency exchange
transactions are conducted on a spot (i.e., cash) basis at the spot rate prevailing in the foreign
currency exchange market or through entering forward contracts to purchase or sell the
currency.
CYBERSECURITY RISK
Increased Internet use makes a portfolio susceptible to operational and informational security
risks. In general, cyber incidents can result from deliberate attacks or unintentional events.
Cyberattacks include but are not limited to infection by computer viruses or other malicious
software code, gaining unauthorized access to systems, networks, or devices through
“hacking” or other means to misappropriate assets or sensitive information, corrupting data,
or causing operational disruption. Cybersecurity failures or breaches of third-party service
providers may cause disruptions at third-party service providers and impact our business
operations, potentially resulting in financial losses; the inability to transact business; violations
of applicable privacy and other laws, regulatory fines, or penalties; reputational damage;
unanticipated expenses or other compensation costs; or additional compliance costs. Our
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 19 OF 36
Firm has an established business continuity and disaster recovery plan and related
cybersecurity procedures designed to prevent or reduce the impact of such risks; there are
inherent limitations in such plans and systems due in part to the evolving nature of technology
and cyberattack tactics.
DEFLATION RISK
When inflation or expectations are low, the value and income of an account’s investments in
inflation-linked securities could fall, resulting in losses.
DIGITAL ASSET & CRYPTO CURRENCY RISK
Digital assets and the securities derived from them (including ETFs and mutual funds) are highly
speculative and historically subject to extreme price volatility. Prices can fluctuate significantly
over short periods due to market sentiment, regulatory developments, technological
advancements, or macroeconomic events. The legal and regulatory environment for
cryptocurrencies and digital asset investments is rapidly evolving. Changes in regulation -
either domestically or globally - could adversely affect the value, liquidity, or legality of certain
digital asset-based funds. Future actions by regulatory authorities may restrict or otherwise
impact the operation, marketing, or underlying holdings of these funds.
EQUITY RISK
Equity instruments are subject to equity market risk, the risk that common stock prices fluctuate
over short or extended periods. Equity securities have greater price volatility than fixed-income
securities. The market price of equity securities may increase or decrease, sometimes rapidly
or unpredictably. Equity securities may decline in value due to factors affecting markets,
industries, sectors or geographic regions represented in those markets, or individual security
concerns.
EMERGING MARKETS RISK
The risks of foreign investing are heightened for securities of companies in emerging market
countries. In most cases, emerging market countries' economic and political structures do not
compare favorably with the U.S. or other developed countries regarding wealth and stability.
Their financial markets often lack liquidity. In addition to all the risks of investing in foreign
developed markets, emerging market securities are susceptible to governmental interference,
local taxes on investments, restrictions on gaining access to sales proceeds, and less efficient
trading markets. These factors can make emerging market investments more volatile and less
liquid than investments in developed markets.
ETF & ETN RISK
ETFs and ETNs are, by definition, portfolios of securities. Although the unsystematic risk
associated with investments in ETFs and ETNs may be low relative to investments in securities of
individual issuers, some events can trigger sharp, and sometimes adverse, price movements in
ETFs and ETNs unrelated to the markets' general activities. These events include unexpected
dividends, changes to regular dividend amounts, announcements of rights offerings, and
possible unexpected revisions to the net asset values of the ETF and ETN. ETFs are subject to
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 20 OF 36
market risk, whereas ETNs are subject to both market risk and the credit risk of the issuer of the
ETN.
Further, certain Client accounts may hold (or short-sell) positions in volatility-related ETFs and
ETNs. Leveraged ETFs and mutual funds, sometimes labeled “ultra” or “2x,” for example, are
designed to provide a multiple of the underlying index’s return, typically daily. Inverse products
are designed to provide the opposite of the underlying index's return, typically daily. These
products differ and can be riskier than traditional ETFs and mutual funds. Although these
products are designed to provide returns that correspond to the underlying index, they may
not be able to exactly replicate the performance of the index because of fund expenses and
other factors. This is referred to as a tracking error. Continual re-setting of returns within the
product may add to the underlying costs and increase the tracking error. As a result, this may
prevent these products from achieving their investment objective. In addition, compounding
of the returns can produce a divergence from the underlying index over time, particularly for
leveraged products. Return distortions may be magnified in highly volatile markets with
significant positive and negative swings. Some deviations from the stated objectives to the
positive or negative are possible and may or may not correct themselves over time. These
products use various strategies to accomplish their objectives, including swaps, futures
contracts, and other derivatives. These products may not be diversified and can be based on
commodities or currencies. These products may have higher expense ratios and be less tax-
efficient than more traditional ETFs and mutual funds.
FIXED INCOME & DEBT RISK
Debt securities are affected by changes in interest rates. When interest rates rise, the value of
debt securities is likely to decrease. Conversely, when interest rates fall, the values of debt
securities are likely to increase. The values of debt securities may also be affected by changes
in the issuing entities' credit rating or financial condition.
FOREIGN INVESTING RISK
Investments in securities of foreign issuers may involve risks, including adverse fluctuations in
currency exchange rates, political instability, confiscations, taxes, restrictions on currency
exchange, difficulty in selling foreign investments, and reduced legal protection. These risks
may be more pronounced for investments in developing countries.
FREQUENT TRADING RISK
A portfolio Manager may actively and frequently trade investments in a portfolio to carry out
its investment strategies. Frequent trading of investments increases the possibility that a
portfolio, as relevant, will realize taxable capital gains (including short-term capital gains,
which are typically taxable at higher rates than long-term capital gains for U.S. federal income
tax purposes), which could reduce a portfolio's after-tax return. Frequent trading can also
mean higher brokerage and other transaction costs, which could reduce a portfolio's return.
The trading costs and tax effects of portfolio turnover can adversely affect its performance.
GEOGRAPHIC CONCENTRATION RISK
If an account concentrates its investments in a particular geographic region or country, its
performance is closely tied to the market, currency, social, political, economic, environmental,
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 21 OF 36
and regulatory conditions within that country or region. These conditions include anticipated
or actual government budget deficits or other financial difficulties, levels of inflation and
unemployment, fiscal and monetary controls, and political and social instability in such
countries and regions. As a result, the account is likely to be more volatile than an account
with more geographically diverse investments.
INDUSTRY OR SECTOR RISK
An account that focuses its investments in specific industries or sectors is more susceptible to
developments affecting those industries and sectors than a more broadly diversified fund.
Issuers in a single industry can react similarly to market, economic, industry, social, political,
regulatory, and other conditions. For example, suppose an account has significant
investments in technology companies. In that case, the account may perform poorly during
a downturn in one or more industries or sectors that heavily impact technology companies.
INTEREST RATE RISK
When interest rates increase, the value of the account’s investments may decline, and the
account’s share value may decrease. This effect is typically more pronounced for
intermediate and longer-term obligations. This effect is also typically more pronounced for
mortgages and other asset-backed securities since the value may fluctuate more significantly
in response to interest rate changes. When interest rates decrease, the account’s current
income may decline.
ISSUER RISK
The risk is that an issuer of a security may perform poorly, and therefore, the value of its
securities may decline. Poor management decisions, competitive pressures, technological
breakthroughs, reliance on suppliers, labor problems or shortages, corporate restructurings,
fraudulent disclosures, natural disasters, or other events, conditions, or factors may cause
inferior performance.
LEGACY HOLDING RISK
Investment advice may be offered on any investment a Client holds at the start of the advisory
relationship. Depending on tax considerations and Client sentiment, these investments will be
sold over time, and the assets invested in the appropriate strategy. As with any investment
decision, there is the risk that timing with respect to the sale and reinvestment of these assets
will be less than ideal or even result in a loss to the Client.
MANAGEMENT RISK
An account is subject to the risk that judgments about the attractiveness, value, or potential
appreciation of the account’s investments may prove to be incorrect. If the selection of
securities or strategies fails to produce the intended results, the account could underperform
other accounts with similar objectives and investment strategies.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 22 OF 36
MARKET RISK
Even a long-term investment approach cannot guarantee a profit. Economic, political, and
issuer-specific events will cause the value of securities to rise or fall. Because the value of
investment portfolios will fluctuate, there is the risk that you will lose money, and your
investment may be worth less upon liquidation. Due to a lack of demand in the marketplace
or other factors, an account may only be able to sell some or all the investments promptly or
may only be able to sell assets at desired prices.
MUNICIPAL BOND RISK
Investments in municipal bonds are affected by the municipal market and the factors in the
cities, states, or regions where the strategy invests. Issues such as legislative changes, litigation,
business and political conditions relating to a particular municipal project, municipality, state,
or territory, and fiscal challenges can impact the value of municipal bonds. These matters can
also impact the ability of the issuer to make payments. Also, the public information about
municipal bonds is less than that for corporate equities or bonds. Additionally, supply and
demand imbalances in the municipal bond market can cause deterioration in liquidity and a
lack of price transparency.
MUTUAL FUND OR ETF RISK
Our models and accounts may use certain ETFs and mutual funds to invest primarily in
alternative investments or strategies. Investing in these alternative investments and strategies
may only be suitable for some of our Clients. These include special risks, such as those
associated with commodities, real estate, and leverage, selling securities short, use of
derivatives, potential adverse market forces, regulatory changes, and potential ill-liquidity.
Special risks are associated with ETFs that invest principally in real estate securities, such as
sensitivity to changes in real estate values or changes in interest rates and price volatility due
to the ETF’s concentration in the real estate market.
The risks with mutual funds include the costs and expenses within the fund that can impact
performance, change of Managers, and the fund straying from its objective (i.e., style drift).
Mutual funds have certain costs associated with underlying transactions and operating costs,
such as marketing and distribution expenses and advisory fees. Mutual fund costs and
expenses vary from fund to fund and will impact a mutual fund’s performance. Additionally,
mutual funds typically have different share classes, as further discussed below, that trade at
different Net Asset Values (“NAV”) as determined at the daily market close and have different
fees and expenses.
PERFORMANCE OF UNDERLYING MANAGER RISK
We select the mutual funds and ETFs in the asset allocation portfolios. However, we depend
on the Manager of such funds to select individual investments in accordance with their stated
investment strategy.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 23 OF 36
REINVESTMENT RISK
The possibility of investing a bond’s cash flows at a rate lower than the expected rate of return
assumed at the time of buying the bond. Reinvestment risk is high for bonds with long maturities
and high coupons.
SECTOR RISK
The danger is that the stocks of many companies in one sector (like health care or technology)
will fall in price simultaneously because of an event that affects the entire industry.
SOCIALLY RESPONSIBLE INVESTING & ESG RISK
Clients utilizing responsible investing strategies and environmental, social responsibility, and
corporate governance (ESG) factors may underperform strategies that do not utilize
responsible investing and ESG considerations. Responsible investing and ESG strategies may
operate by excluding certain issuers' investments or by selecting investments based on
compliance with factors such as ESG. This strategy may exclude certain sectors or industries
from a Client’s portfolio, potentially negatively affecting the Client’s investment performance
if the excluded sector or industry outperforms. Responsible investing and ESG are subjective
by nature. Our Firm may rely on analysis and ‘scores’ provided by third parties in determining
whether an issuer meets our Firm’s standards for inclusion or exclusion. A Client’s perception
may differ from our Firm or a third party on how to judge an issuer's adherence to responsible
investing principles.
THIRD PARTY MONEY MANAGER RISK
When implementing third-party model portfolios, the Firm selects the model and determines
its appropriateness for a client. The Adviser may deviate from a model to accommodate
restrictions, tax considerations, cash flows, or other client circumstances, which may cause
performance to differ from model results. Clients are subject to model risk including the risk that
the model’s assumptions, allocations, or underlying holdings may underperform or be
changed by the model provider without notice.
TIMING RISK
The risk is that the investment needs to perform better after its purchase or sale. Moreover, if
the Client requires redemption, the Client may face a loss due to poor overall market
performance or security performance at that time.
VALUE INVESTING RISK
Value investing risk is the risk that value stocks do not increase in price, not issue the anticipated
stock dividends, or decline in price, either because the market fails to recognize the stock’s
intrinsic value or because the expected value was misgauged. If the market does not
recognize that the securities are undervalued, the prices of those securities might not
appreciate as anticipated. They also may decline in price even though they are already
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 24 OF 36
undervalued in theory. Value stocks are typically less volatile than growth stocks but may lag
behind growth stocks in an up market.
ITEM 9 - DISCIPLINARY INFORMATION
Registered investment advisers are required to provide information about all disciplinary
information that would be material to a Client’s evaluation of our Firm or the integrity of its
management. Clients should refer to the Advisor’s Form ADV Part 2B Brochure Supplement. If the
Client did not receive the Advisor’s Form ADV Part 2B Brochure Supplement, the Client should
contact the Chief Compliance Officer using the information provided on the cover page of this
Brochure. Our Chief Compliance Officer is available to address any questions a Client or
prospective client may have regarding the above or any information outlined in this Brochure.
Our Firm has no legal or disciplinary events that are material to a Client or prospective clients,
evaluation of our advisory business, or the integrity of our management services.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS
INDUSTRY ACTIVITIES
Clients should review our IARs Form ADV Part 2B Brochure Supplement to determine whether the
Client’s IAR is engaged in any of the activities described below that may create a conflict of
interest. If the Client did not receive the Advisor’s Form ADV Part 2B Brochure Supplement, the
Client should contact the Firm’s Chief Compliance Officer using the information on the cover page
of this Brochure. The Chief Compliance Officer is available to address any questions a Client or
prospective client may have regarding any of the below conflicts of interest, or any other
information outlined in this Brochure.
BROKER-DEALER AFFILIATED
Our Firm is not a broker-dealer, but some of the IARs are Registered Representatives of
Commonwealth Financial Network (“Commonwealth”), a full-service broker-dealer, member
FINRA/SIPC, which compensates them for effecting securities transactions. When placing securities
transactions through Commonwealth in their capacity as Registered Representatives, they will
earn sales commissions. Because some of the IARs are dually registered representatives and agents
of Commonwealth and our Firm, Commonwealth, has specific supervisory and administrative
duties under the requirements of FINRA Conduct Rule 3280. Commonwealth and our Firm are not
affiliated companies. Some of our IARs spend a portion of their time in connection with broker-
dealer activities.
As a broker-dealer, Commonwealth engages in various activities normally associated with
securities brokerage firms. Pursuant to the investment advice given by our Firm or its IARs,
investments in securities may be recommended for Clients. If Commonwealth is selected as the
broker-dealer, Commonwealth and its Registered Representatives, including some of the IARs of
our Firm, may individually receive commissions for executing securities transactions.
If Commonwealth is selected as the broker-dealer, the transaction charges may be higher or lower
than the charges the Client may pay if the transactions were executed at other broker-dealers.
The Client should note, however, that the Client is under no obligation to purchase securities
through the IARs of our Firm or Commonwealth.
Moreover, the Client should note that under the rules and regulations of FINRA, Commonwealth
must maintain certain Client records and perform other functions regarding certain aspects of the
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 25 OF 36
investment advisory activities of its Registered Representatives. These obligations require
Commonwealth to coordinate with and have the cooperation of its Registered Representatives
that operate as or are otherwise associated with investment advisers other than Commonwealth.
Accordingly, Commonwealth may limit the use of certain custodial and brokerage arrangements
available to Clients of our Firm, and Commonwealth may collect, as paying agent of our Firm, the
investment advisory fee remitted to our Firm by the account Custodian. Commonwealth may
retain a portion of the investment advisory fee Clients pay as a charge for the functions it performs
and may be further re-allowed to other Registered Representatives of Commonwealth. The charge
will not increase the advisory fee Clients have agreed to pay our Firm.
Some of the IARs, in their capacity as Registered Representatives of Commonwealth or as agents
appointed with various life, disability, or other insurance companies, receive insurance
commissions, fee trails, or other compensation from the respective product sponsors or because of
effecting securities transactions for Clients. However, Clients should note that they are not
obligated to purchase investment products through our IARs.
As a result of the relationship with Commonwealth, they may have access to certain confidential
information (e.g., financial information, investment objectives, transactions, and holdings) about
our Clients, even if the Client does not establish any account through Commonwealth. If a Client
would like a copy of the Commonwealth Privacy Policy, please contact our Firm’s CCO. The
contact information for our Firm can be found on the Cover Page of this Brochure.
THIRD-PARTY MONEY MANAGER (TPMM) AGREEMENTS
Our Firm has TPMM Agreements with other registered investment advisers. These agreements allow
our Firm to allocate Client assets for participation in their Programs. Our Firm is responsible to
determine whether participation in the Program is appropriate for our Clients.
Under the programs, the TPMM provides discretionary investment management services to our Firm
and makes available investment strategy models of investment managers appointed by the
TPMM. These models seek to achieve particular investment goals and are not tailored to individual
Clients. Our Firm may allocate Client assets to one or more of TPMM models which match a Client’s
objectives. The TPMM then invests the allocated funds in accordance with the selected models as
updated from time to time by the TPMM or investment managers appointed by the TPMM. In most
cases, the TPMM will implement those models and execute transactions; in others, the investment
manager will do so.
The TPMMs charge our Firm an investment management fee for participation in the program. Our
Firm has instructed the TPMM to operationally facilitate the deduction of the investment
management fees directly from our Firm’s Clients’ accounts held at the custodian. Other
transaction costs are also charged to the Client, including without limitation execution charges
imposed by unaffiliated broker/dealers or exchanges, wire transfer fees, auction fees, and transfer
taxes.
Clients with assets allocated to the program are subject to certain risks, including the investment
manager implementing its model for its other accounts before implementing it for our Clients. In
that case, securities may be traded by our Clients at prices different than those obtained by the
manager’s other Clients. The risk of price deviations is greater for large orders and thinly traded
securities. Additionally, performance of our Client’s investments in a model may deviate from the
performance of other accounts in such models or those managed by the TPMM or the investment
manager.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 26 OF 36
FUND AND ETF MODELS-BASED PORTFOLIOS
Our Firm may choose to invest its Clients’ assets into model portfolios of mutual funds and ETFs
created by a TPMM. This may include models or programs that consist of allocations to TPMM Funds
and TPMM ETFs and certain families of third-party mutual funds or ETFs.
Under the models and programs, TPMMs provide non-discretionary services to our Firm through the
publication of investment models consisting of allocations to different funds allocated to the
models. Specifically, each TPMM: (1) makes available the models, developed and periodically
updated by the TPMM designed to achieve the model’s stated investment objective or goal based
upon the TPMM’s capital market assumptions and any other criteria that the TPMM, in its sole
discretion, determines is relevant; and (2) periodically publishes for consideration by firm revisions
to a model’s percentage asset allocations among the underlying TPMM Funds, TPMM’s ETFs, third-
party funds, or third-party ETFs, or adds, removes, or otherwise changes the individual TPMM Funds,
TPMM ETFs, third-party funds, or third-party ETFs underlying an existing model.
The TPMM and its affiliates earn fees from the TPMM Funds and TPMM ETFs, which costs are indirectly
borne by Clients invested in these models. As a result, the TPMM does not charge our Firm or its
Clients a direct fee for the use of the TPMM models or programs. Although if the TPMM has an
affiliated custodian, they could charge a custodial platform fee on Client assets invested in TPMM
ETF products. Some models and programs charge direct fees that will be assessed to Clients.
INSURANCE COMPANIES
In their individual capacities, some of our Firm’s IARs are agents for various third-party insurance
companies. As such, these individuals may receive separate yet customary commission
compensation for implementing product transactions on our advisory Clients' behalf. Clients,
however, are not obligated to engage IARs when considering implementing advisory or insurance
recommendations. Implementing any or all recommendations is solely at the Client's discretion.
PERSONAL RELATIONSHIPS
From time to time, our Firm may provide investment advisory services to individuals with whom our
personnel have personal relationships, such as friends or family members. These relationships may
include jointly held accounts, informal financial assistance, or investment management services
provided at a reduced or waived fee.
While these accounts are subject to the same investment process, policies, and procedures as all
other Client accounts, there is a potential for perceived or actual conflicts of interest, including the
possibility of preferential treatment or allocation of investment opportunities. To address this, we
monitor and supervise these accounts as we would any other Client account, and any deviations
in treatment (e.g., fees or access to products) are documented and reviewed by the Chief
Compliance Officer.
Our policies prohibit favoritism and require that investment decisions be made in the best interest
of each Client, regardless of relationship status.
OTHER FINANCIAL INDUSTRY ACTIVITIES
Our Firm, and our IARs, do not have a related company that is a (1) broker-dealer, municipal
securities dealer, government securities dealer or broker, (2) investment company or other pooled
investment vehicle (including a mutual fund, closed-end investment company, unit investment
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 27 OF 36
trust, private investment company or “hedge fund,” and offshore fund), (3) other investment
adviser or financial planner, (4) futures commission merchant, commodity pool operator, or
commodity trading advisor, (5) banking or thrift institution, (6) accountant or accounting firm, (7)
lawyer or law firm, (8) insurance company or agency, (9) pension consultant, (10) real estate broker
or dealer, or (11) sponsor or syndicator of limited partnerships.
ITEM 11 - CODE OF ETHICS, PARTICIPATION & INTEREST IN CLIENT
TRANSACTIONS, & PERSONAL TRADING
Our Firm maintains a Code of Ethics to reinforce the fiduciary principles governing our Firm and its
employees. The Code, among other things, requires all employees to act with integrity and ethics,
and professionalism.
Policies against overreaching, self-dealing, insider trading, and conflicts of interest are outlined in
our Code. Our Code forbids employees from trading, either personally or on behalf of others,
based on non-public material information or communicating non-public material information to
others violating the law.
Additionally, our Code sets forth restrictions and quarterly attestations on receiving gifts, outside
business activities, personal trading activity, maintenance of personal brokerage accounts, and
other matters. The Code is appropriately designed and implemented to prevent or eliminate
potential conflicts of interest between our Firm, our employees and IARs, Clients, and investors. We
always strive to make decisions in our Client's best interest should a conflict of interest arise.
Clients should be aware that no set of rules, policies, or procedures can anticipate, avoid, or
address all potential conflicts of interest.
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING
Our employees, IARs, and our associated persons are not prohibited from owning or trading
securities bought, sold, and recommended to our Clients, provided such personal trading activity
complies with the parameters, limitations, and requirements of the Code. Employees, IARs, and
associated persons must receive approval from our Firm’s CCO when engaging in reportable
securities transactions. Our CCO is responsible for reviewing all employees', IARs, and associated
persons' trading when they occur and periodically reviewing trading activity. Our CCO has broad
discretion to reject employee trading for any reason. Our Firm’s policies and procedures related to
the personal trading activity of employees aim to demonstrate our commitment to placing Clients’
interests ahead of our trading interests.
While our Firm does not maintain a proprietary trading account and therefore does not have a
direct material financial interest in any securities it recommends to Clients, in certain situations, our
Firm’s employees and associated persons may purchase interests in the same securities at the
same or different portfolio percentages or risk levels, in which one or more Clients is investing or has
invested. Conversely, a Client may purchase interests in security where our employees, IARs, and
associated persons are investing or have invested.
Any exceptions to the Code require the prior approval of the CCO. We will provide a copy of the
Code to any Client or prospective client upon such written or verbal request. Such requests should
be directed to our Firm’s CCO at the contact information listed in Item 1 - Cover Page of this
Brochure.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 28 OF 36
ITEM 12 - BROKERAGE PRACTICES
INVESTMENT MANAGEMENT SERVICES
Clients must maintain assets in an account with a “qualified Custodian,” a broker-dealer or bank.
If our Firm is asked to give a recommendation, our recommendation is based on the broker’s cost
and fees, skills, reputation, dependability, and compatibility with the Client. The Client may obtain
lower commissions and fees from other brokers.
CUSTODIANS
We maintain relationships with SEI Private Trust Company (“SPTC”) and Commonwealth Financial
Network (collectively, the “Custodians”) to provide custody, trading, and related services for Client
accounts.
SPTC is a federally chartered limited-purpose trust company that serves as qualified Custodian for
Client accounts and provides custody and related trading services as part of its custodial platform.
Commonwealth is a registered broker-dealer and investment adviser and a member of FINRA and
SIPC that provides brokerage and custodial services for accounts maintained on its platform.
The Custodians offer a variety of services to independent investment advisers, which may include
custody of Client assets, trade execution, clearance and settlement of transactions, account
reporting, billing, and technology and operational support.
There is no direct link between our participation in the custodial platform and the investment
advice we give to our Clients. However, we receive economic benefits through our participation
in the platform that is typically not available to retail clients and may not be available to all
independent investment advisers participating in the platform. These benefits include the following
products and services (provided without cost or at a discount): receipt of duplicate Client
statements and confirmations; research-related products and tools; consulting services; access to
a trading desk serving Advisor participants; access to block trading (which provides the ability to
aggregate securities transactions for execution and then allocate the appropriate shares to Client
accounts); the ability to have advisory fees deducted directly from Client accounts; access to an
electronic communications network for Client order entry and account information; access to
mutual funds with no transaction fees and to certain institutional money Managers; and discounts
on compliance, marketing, research, technology, and practice management products or services
provided to the Firm by third-party vendors. The Custodians may also have paid for business
consulting and professional services received by some of our related persons. Some of the products
and services made available by the Custodians through the program may benefit the Firm but
may not benefit the Client’s account. These products or services may assist the Firm in managing
and administering the Client’s account, including accounts not maintained by the Custodians.
Other services made available by our Custodians are intended to help the Firm manage and
further develop our business enterprise. The benefits our Firm or our personnel receive through
participation in the program do not depend on the amount of brokerage transactions directed to
the Custodians. As a fiduciary, we are obligated to put our Clients’ interests ahead of our own,
and we take that duty seriously in how we select Custodians and products. The Client should be
aware, however, that the receipt of economic benefits by our Firm or our related persons in and
of itself creates a potential conflict of interest and may indirectly influence our choice of
Custodians for custody and brokerage services.
If our Client requests the Firm to recommend a Broker-Dealer Custodian for execution or custodial
services, we recommend that the Client account be maintained at SPTC or Commonwealth. We
recommend establishing accounts with the Custodians to maintain custody of Client assets and
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 29 OF 36
effect trades for our Client accounts. Our Client is under no obligation to act upon any
recommendations. If our Client elects to act upon any recommendations, our Client is not
obligated to place the transactions through any broker-dealer that our Firm recommends. Our
recommendation is based on the firm’s cost and fees, skills, reputation, dependability, and
compatibility with the Client. Our Client may be able to obtain lower commissions and fees from
other brokers, and the value of products, research, and services given to the Firm is not a factor in
determining the broker-dealer selection or the reasonableness of their commissions.
BROKERAGE FOR CLIENT REFERRALS
We do not receive Client referrals from any Custodian or third party in exchange for using that
broker-dealer or third party.
AGGREGATION AND ALLOCATION OF TRANSACTIONS
We may aggregate transactions if we believe that aggregation is consistent with the duty to seek
the best execution for our Clients and is consistent with the disclosures made to Clients and terms
defined in the Client Investment Advisory Agreement. No advisory Client will be favored over any
other Client. Each account in an aggregated order will participate in the average share price (per
Custodian) for all transactions in that security on a given business day.
If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro-
rata basis. If we determine that a pro-rata allocation is not appropriate under the circumstances,
we will base the allocation on other relevant factors, which may include:
When only a small percentage of the order is executed, with respect to purchase allocations,
allocations may be given to accounts high in cash;
Concerning sale allocations, allocations may be given to accounts low in cash;
We may allocate shares to the account with the smallest order, to the smallest position, or to an
account that is out of line concerning security or sector weightings relative to other portfolios with
similar mandates;
We may allocate to one account when that account has limitations in its investment guidelines
prohibiting it from purchasing other securities that we expect to produce similar investment results,
and other accounts can purchase that in the block;
If an account reaches an investment guideline limit and cannot participate in an allocation, we may
reallocate shares to other accounts. For example, this may be due to unforeseen changes in an
account’s assets after an order is placed;
If a pro-rata allocation of a potential execution would result in a de Minimis allocation in one or more
accounts, we may exclude the account(s) from the allocation.
We will document the reasons for any deviation from a pro-rata allocation.
TRADE ERRORS
We have implemented procedures to prevent trade errors; however, trade errors in Client
accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct
trade errors in the best interest of the Client. In cases where the Client causes a trade error, the
Client will be responsible for any loss resulting from the correction. Depending on the specific
circumstances of the trade error, the Client may not be able to receive any gains generated due
to the error correction. In all situations where the Client does not cause the trade error, the Client
will be made whole, and we would absorb any loss resulting from the trade error if our Firm caused
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 30 OF 36
the error. If the Custodian causes the error, the Custodian will be responsible for covering all trade
error costs. We will never benefit or profit from trade errors.
DIRECTED BROKERAGE
We do not routinely recommend, request, or require that the Client direct the Firm to execute
transactions through a specified broker-dealer. Additionally, we typically do not permit the Client
to direct brokerage. We place trades for the Client’s account subject to our duty to seek the best
execution and other fiduciary duties.
ITEM 13 - REVIEW OF ACCOUNTS
CLIENT REVIEWS
Our Firm reviews Client accounts and financial plans periodically. Our IARs will monitor Client
accounts regularly and perform annual reviews with each Client. All accounts are reviewed for
consistency with Client investment strategy, asset allocation, risk tolerance, and performance.
More frequent reviews may be triggered by changes in an account holder’s personal, tax, or
financial status. Geopolitical and macroeconomic-specific events may also trigger reviews. Our
recommendations depend on the information provided by the Client. Our Client must notify our
Firm of any situation that would impair our ability to manage our Client accounts properly.
The Client receives a copy of each trade confirmation (unless the Client has authorized the
Custodian to suppress the confirmations) and the standard written account statement from the
qualified account Custodian every quarter.
ITEM 14 - CLIENT REFERRALS & OTHER COMPENSATION
BROKERAGE PRACTICES
As disclosed under Item 12 Brokerage Practices, we participate in the Custodian’s institutional
customer programs, and we may recommend a Custodian to our Clients for custody and
brokerage services. There is no direct link between our participation in the program and the
investment advice we give to our Clients. However, we receive economic benefits through our
participation in the program that is typically not available to any other independent advisors
participating in the program. These benefits include the following products and services (provided
without cost or at a discount):
Receipt of duplicate Client statements and confirmations.
Research-related products and tools.
Consulting services.
Access to a trading desk serving adviser participants.
Access to block trading (which provides the ability to aggregate securities transactions for execution
and then allocate the appropriate shares to Client accounts);
The ability to have advisory fees deducted directly from Client accounts.
Access to an electronic communications network for Client order entry and account information.
Access to mutual funds with no transaction fees and certain institutional money Managers.
Discounts on compliance, marketing, research, technology, and practice management products or
services provided to us by third-party vendors.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 31 OF 36
Custodians may also have paid for business consulting and professional services received by some
of our IARs. Some of the products and services made available by Custodians through the program
may benefit us but may not benefit your account. These products or services may assist us in
managing and administering Client accounts, including accounts not maintained at our
recommended Custodian. Other services made available by the Custodian are intended to help
us manage and further develop our business enterprise. The benefits our Firm or our IARs receive
through participation in the program do not depend on the amount of brokerage transactions
directed to the Custodian. Due to these arrangements, our Client does not pay more for assets
maintained at SEI or Commonwealth. As part of our fiduciary duties to Clients, we always endeavor
to put our Client's interests first. Clients should be aware, however, that receiving economic benefits
from our Firm or our IARs in and of itself creates a conflict of interest because the cost of these
services would otherwise be borne directly by us. These arrangements could indirectly influence
our choice of Custodian for custody and brokerage services. Clients should consider these conflicts
of interest when selecting a Custodian. The products and services provided by the Custodian, how
they benefit us, and the related conflicts of interest are described above.
CLIENT REFERRALS
OTHER PROFESSIONALS
Our Firm may refer business to estate planning attorneys, accountants, insurance brokers, and
other professionals. However, we do not receive monetary or other material compensation for
referring Clients to such professionals. We also do not pay any person or firm commissions or
other items of material value when referring Clients to us. If we receive or offer an introduction
to a Client, we do not pay or earn a referral fee, nor are there established quid pro quo
arrangements. Each Client can accept or deny such referral or subsequent services.
OTHER COMPENSATION
TRANSITION ASSISTANCE
In connection with the acquisition of Commonwealth Financial Network by LPL Financial LLC,
LPL has offered certain financial incentives, including forgivable loans and other transition
assistance, to some financial professionals associated with Commonwealth. As of the date of
this brochure, neither our Firm nor its investment adviser representatives have accepted any
such incentives. Our Firm and its investment adviser representatives are not registered
representatives or investment adviser representatives of LPL, and we do not currently
recommend LPL as a broker-dealer or custodian.
To the extent any such incentives are accepted by our Firm or its personnel, the receipt or
forgiveness of these benefits may be conditioned on maintaining certain asset levels on LPL’s
platform for a specified period of time. These benefits are not paid by Clients and are separate
from advisory fees. However, they create a potential conflict of interest because they may
provide an incentive to consider or recommend particular custodial or brokerage
arrangements in the future. Clients are under no obligation to maintain accounts on LPL’s
platform and may select any custodian or broker-dealer with whom PWA can reasonably
obtain a relationship.
ITEM 15 - CUSTODY
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 32 OF 36
Regulators have defined custody as having access or control over Client funds or securities. As it
applies to our Firm, we do not have physical custody of funds or securities.
FEE DEDUCTION
Our Firm is deemed to have constructive custody over those Client accounts where it can deduct
our fees directly from the Client account. If we comply with certain regulatory requirements, this
constructive custody does not mandate that our Firm undergo a surprise audit for those accounts.
Our Clients receive account statements directly from the qualified Custodian at least quarterly.
Our Firm may send Clients quarterly reports that our Firm produces using our portfolio accounting
system.
We strongly urge our Clients to compare such reports with the statements received from the
qualified Custodian. Furthermore, when our Firm calculates our investment management fees and
instructs the Custodian to remit these fees to us directly from Clients’ accounts, the Custodian does
not verify our calculation of fees. Our Firm performs quarterly testing to ensure that our fees are
charged per the Client’s Investment Advisory Agreement on file with our Firm.
STANDING LETTERS OF AUTHORIZATION (“SLOA”)
Additionally, our Firm is deemed to have custody of the Client’s funds or securities when you have
standing authorizations with their Custodian to move money from your account to a third-party
Standing Letter of Authorization (“SLOA”) and, under that SLOA, it authorizes us to designate the
amount or timing of transfers with the Custodian. The SEC has set forth standards to protect your
assets in such situations, which we follow. We do not have a beneficial interest in any of the
accounts we are deemed to have Custody of where SLOAs are on file. In addition, account
statements reflecting all activity on the account(s) are delivered directly from the qualified
Custodian to each Client or the Client’s independent representative at least monthly. You should
carefully review those statements and are urged to compare the statements against reports
received from us. When you have questions about your account statements, contact us, your
Advisor, or the qualified Custodian preparing the statement.
ITEM 16 - INVESTMENT DISCRETION
DISCRETIONARY AUTHORITY
Upon receiving written authorization from the Client, our Firm provides discretionary investment
advisory services for Client accounts. For discretionary accounts, before engaging our Firm to
provide investment advisory services, you will enter into a written Investment Advisory Agreement
with us granting our Firm the authority to supervise and direct, on an ongoing basis, investments
per the Client's investment objective and guidelines. In addition, our Client will need to execute
additional documents required by the Custodian to authorize and enable our Firm, in its sole
discretion, without prior consultation with or ratification by our Client, to purchase, sell or exchange
securities in and for your accounts. We are authorized, at our discretion and without prior
consultation with the Client, to (1) buy, sell, exchange, and trade any stocks, bonds, or other
securities or assets and (2) determine the amount of securities to be bought or sold and (3) place
orders with the Custodian. Any limitations to such discretionary authority will be communicated to
our Firm in writing by you, the Client.
The limitations on investment and brokerage discretion held by our Firm are:
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 33 OF 36
For discretionary accounts, we require that we be given the authority to determine which securities
and the amounts to be bought or sold.
Any limitations on this discretionary authority shall be in writing as indicated in the Investment Advisory
Agreement. Clients may change or amend these limitations as required.
NON-DISCRETIONARY AUTHORITY
In some instances, we may not have discretionary authority. For non-discretionary accounts, our
Firm will discuss all transactions with our Client before execution, or the Client will be required to
make the trades in an employer-sponsored account.
ITEM 17 - VOTING CLIENT SECURITIES
PROXY VOTING
Our Firm cannot vote for Client securities. Clients will receive proxies or other solicitations directly
from the Custodian or a transfer agent. Clients are responsible for obtaining and voting proxies for
all securities maintained in their portfolios. We may provide advice to you regarding your voting of
proxies. Clients can contact our Firm with any questions or concerns about a particular solicitation.
For accounts held with an SMA or ITPM and depending on their voting policies and procedures,
the SMA or ITPM could require the Client to appoint them as agent and attorney-in-fact with
discretion to vote proxies on the Client’s behalf. Clients should review the SMA or ITPMs disclosure
brochure to understand their proxy voting policies and procedures.
CLASS ACTION LAWSUITS
Our Firm does not advise or instruct Clients on whether to participate as a member of class action
lawsuits and will not automatically file claims on the Client’s behalf. However, if a Client notifies us
that they wish to participate in a class action, we will provide the Client with transaction information
about the Client’s account that is required to file a proof of claim in a class action.
ITEM 18 - FINANCIAL INFORMATION
FINANCIAL CONDITION
Our Firm has no financial commitment that impairs its ability to meet Client contractual and
fiduciary obligations and has not been the subject of a bankruptcy proceeding. We do not require
or solicit prepayment of more than $1,200 in fees per Client six months or more in advance.
Therefore, we are not required to include a balance sheet for the most recent fiscal year.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 34 OF 36
ADDITIONAL INFORMATION
PRIVACY POLICY
Our Firm collects non-public personal information about Clients from information received on
applications or other forms and information about Client transactions with firm affiliates, others, or
our Firm. We do not disclose any nonpublic personal information about current or former Clients
except as permitted by law or to provide services. Firm employees have limited access to Clients'
data based on their responsibilities to provide products or services to Clients.
Our Firm maintains physical, electronic, and procedural safeguards in compliance with federal
standards to protect Client information. If the IAR servicing a Client account leaves our Firm to join
another firm, the IAR is permitted to retain copies of specific Client information so that the IAR can
assist with transferring the Client account and continue to serve the Client at their new firm.
A copy of our Firm's Privacy Policy is given to each Client at account opening, upon request, and
provided annually.
OPTING OUT
If a Client does not want an IAR to retain copies of the Client's non-public personal information
when the IAR leaves our Firm to join another firm, the Client can contact our Compliance
Department by calling 859-957-2737.
BUSINESS CONTINUITY PLAN
Our Firm has developed a Business Continuity Plan to address how our Firm will respond to events
that significantly disrupt the operation of our business. Since the timing and impact of disasters and
disruptions are unpredictable, our Firm will be flexible in responding to current events as they occur.
Within 24 hours after a significant business disruption, our Firm plans to quickly recover and resume
business operations and respond by safeguarding employees and property, making a financial
and operational assessment, protecting our Firm’s books and records, and allowing Clients to
transact business. Given the scope and severity of the significant business disruption, our business
continuity plan is designed to permit our Firm to resume operations as quickly as possible.
Our Firm’s business continuity plan addresses: data back-up and recovery; all mission critical
systems; financial and operational assessments; alternative communications with customers,
employees, and regulators; alternate physical location of employees; critical supplier, contractor,
bank, and counter-party impact; regulatory reporting; and assuring Clients’ prompt access to their
funds and securities if our Firm is unable to continue as a business.
Our Firm backs up essential records in a geographically separate area. At the same time, every
emergency poses unique problems based on external factors, such as the time of day and the
severity of the disruption. Its objective is to restore operations and be able to complete existing
transactions and accept new transactions and payments within four hours of the disruptive event.
Client orders and requests for funds and securities could be delayed during this period.
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 35 OF 36
CONTACTING METHODS
If a Client cannot contact our Firm via 859-957-2737 after a significant business disruption, please
visit the website at principledwealth.net to review updated contact information.
VARYING DISRUPTIONS
Significant business disruptions can vary in scope, such as disruption that affects only our Firm, a
single building housing our Firm, the business district where our Firm is located, the city where our
Firm is located, or the whole region. Within each area, the disruption's severity can also vary from
minimal to severe. In a disruption to only our Firm or a building housing our Firm, our Firm will transfer
operations to a local site when needed and expect to recover and resume business within 24 hours.
instructions on contacting our Firm
through
In a disruption affecting our Firm’s business district, city, or region, our Firm will transfer operations to
a site outside the affected area and recover and resume business within three (3) days. In either
situation, our Firm plans to continue the business, transfer operations to its clearing firm if necessary,
and provide Clients with
its website:
principledwealth.net. If the significant business disruption is so severe that it prevents our Firm from
remaining in business, our Firm will ensure the Client’s prompt access to their funds and securities.
This information is provided solely to Clients of our Firm, and no further distribution or disclosure is
permitted without the prior written consent of our Firm. No person other than our Firm Clients can
rely on any statement herein. Our Firm’s Business Continuity Plan is reviewed and updated regularly
and is subject to change.
CONTACTING US
Please visit the website at principledwealth.net for the most current copy of this disclosure. You can
request an updated copy by contacting our Firm at (859) 957-2737 or writing our Firm at the
following:
Principled Wealth Advisors, LLC
100 East RiverCenter Blvd., Suite 810
Covington, KY 41011
PRINCIPLED WEALTH ADVISORS, LLC
APRIL 2026 | PAGE 36 OF 36