REDE WEALTH, LLC

Disclosure Brochure March 18, 2025 600 Peter Jefferson Parkway, Suite 250 Charlottesville, VA 22911 (434) 974-3500 This brochure provides information about the qualifications and business practices of Rede Wealth, LLC (hereinafter “Rede Wealth” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at this telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training.  Disclosure Brochure Item 2. Material Changes • • • • • • The material changes in this brochure from the last annual updating amendment in February of 2024 of Rede Wealth, LLC are described below. Material changes relate to Rede Wealth, LLC’s policies, practices or conflicts of interests. Item 4 has been amended to clarify that while independent managers may utilize and sponsor wrap fee programs, we are not a sponsor to a wrap fee program. Item 5 has been amended to reflect our current fees as well as the fact that our representatives are not registered brokers and do not receive compensation for the sale of securities. Item 10 has been amended to state that we do recommend independent managers at times and are not compensated for such recommendations. Item 12 has been amended to state that we do not accept client-directed brokerage outside of our recommended custodian. Item 15 has been amended to state that we do maintain Standing Letters of Authorization for some of our clients’ assets and do follow the regulatory safeguards required. Item 17 has been amended to reflect the fact that we do not vote proxies on behalf of our clients. Page | 2  Disclosure Brochure Item 3. Table of Contents Item 2. Material Changes....................................................................................................................................................... 2 Item 3. Table of Contents....................................................................................................................................................... 3 Item 4. Advisory Business ..................................................................................................................................................... 4 Item 5. Fees and Compensation ............................................................................................................................................. 6 Item 6. Performance-Based Fees and Side-by-Side Management ............................................................................................ 8 Item 7. Types of Clients ......................................................................................................................................................... 8 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................................... 8 Item 9. Disciplinary Information .......................................................................................................................................... 12 Item 10. Other Financial Industry Activities and Affiliations ................................................................................................ 12 Item 11. Code of Ethics ....................................................................................................................................................... 12 Item 12. Brokerage Practices ............................................................................................................................................... 13 Item 13. Review of Accounts ............................................................................................................................................... 16 Item 14. Client Referrals and Other Compensation............................................................................................................... 17 Item 15. Custody .................................................................................................................................................................. 18 Item 16. Investment Discretion ............................................................................................................................................ 19 Item 17. Voting Client Securities ......................................................................................................................................... 19 Item 18. Financial Information ............................................................................................................................................ 19 Page | 3  Disclosure Brochure Item 4. Advisory Business Rede Wealth offers a variety of advisory services, which include financial planning, investment management and wealth management services. In dealing with clients, the Firm seeks first to evaluate a client’s current, holistic financial situation prior to managing their investments. Rede Wealth then designs and implements an investment plan aimed at achieving a client’s financial objectives. Prior to Rede Wealth rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Rede Wealth setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Rede Wealth started conducting business as an investment adviser in January 2015 and is owned by Stephen McNaughton and Matthew Dawson. As of December 2023, Rede Wealth had $313,317,703 in assets under management, $230,658,877 of which was managed on a discretionary basis, and $82,658,826 of which was managed on a non-discretionary basis. While this brochure generally describes the business of Rede Wealth, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Rede Wealth’s behalf and is subject to the Firm’s supervision or control. Investment and Wealth Management Services The Firm generally provides clients with wealth management services which may include financial planning services, as well as the discretionary management of investment portfolios. Under a wealth management engagement, Rede Wealth primarily allocates client assets among various exchange-traded funds (“ETFs”), stocks and independent investment managers (“Independent Managers”). On a limited basis, the Firm may also utilize mutual funds, bonds, options, real estate investment trusts (“REITs”) and master limited partnerships (“MLPs”). Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios to achieve their stated investment objectives. Clients may also engage Rede Wealth to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, the Firm directs or recommends the allocation of client assets among the various investment options available within the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Page | 4  Disclosure Brochure Rede Wealth tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. The Firm consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Rede Wealth if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Rede Wealth determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Use of Independent Managers As mentioned above, Rede Wealth may select certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Rede Wealth evaluates a variety of information about Independent Managers, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Rede Wealth also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers, and seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Wrap Program Fees When appropriate and in the client’s best interest, clients’ assets, or a portion of their assets may be allocated to an independent manager that utilizes or sponsors a wrap fee program. A wrap program is an arrangement where brokerage commissions and transaction costs are absorbed by the Firm. Participants in wrap programs may pay a higher aggregate fee to the independent manager than if investment management and brokerage services were purchased separately. This will not increase client’s advisory fee paid. Because clients in wrap programs are not charged transaction fees, this creates a disincentive for the manager to Page | 5  Disclosure Brochure trade in your account as transaction fees lower the fees retained by the manager. However, when we select independent managers, we monitor their activities in alignment with our fiduciary duty to you, and ensure all actions taken in your account are completed with your best interest in mind. Item 5. Fees and Compensation Rede Wealth offers services on a fee basis, which may include fixed fees, as well as fees based upon assets under management or advisement. Investment Management Fees Rede Wealth offers investment management services for an annual fee based on the amount of assets under the Firm’s management. This management fee generally varies between 30 and 100 basis points (0.30 % – 1.00 %), depending upon the size and composition of a client’s portfolio and the type of services rendered. Alternatively, clients may pay a flat fee for management ranging from $0 - $5,000 annually, depending upon the size and composition of a client’s portfolio and the type of services rendered. The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by Rede Wealth on the last day of the previous billing period. For the initial period of an engagement, the fee may be calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), Rede Wealth may negotiate a fee rate that differs from the range set forth above. Fee Discretion Rede Wealth may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, account retention and pro bono activities. In addition, certain legacy clients may be subject to a different fee schedule Page | 6  Disclosure Brochure Additional Fees and Expenses In addition to the advisory fees paid to Rede Wealth, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges may include securities brokerage commissions and transaction fees (for any services outside of a wrap fee program, if any), custodial fees, fees attributable to alternative assets, reporting charges, fees charged by the Independent Managers, margin costs, charges imposed directly 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. The Firm’s brokerage practices are described at length in Item 12, below. Direct Fee Debit Clients generally provide Rede Wealth and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to Rede Wealth. Alternatively, clients may elect to have Rede Wealth send a separate invoice for direct payment. Account Additions and Withdrawals Clients may make additions to and withdrawals from their account at any time, subject to Rede Wealth’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients may withdraw account assets on notice to Rede Wealth, subject to the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Rede Wealth may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Commissions and Sales Charges for Recommendations of Securities Neither the firm nor any of its supervised persons accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Page | 7  Disclosure Brochure Item 6. Performance-Based Fees and Side-by-Side Management Rede Wealth does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets), and does not engage in side-by-side account management. Item 7. Types of Clients Rede Wealth generally offers services to individuals, trusts, estates, charitable organizations, corporations and business entities. Minimum Account Requirements Rede Wealth does not impose a stated minimum fee or minimum portfolio value for starting and maintaining an advisory relationship. Certain Independent Managers may, however, impose more restrictive account requirements and billing practices from the Firm. In these instances, Rede Wealth may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies The client experience begins with the Firm’s proprietary investment process. This process requires an inventory of the client’s individual circumstances, establishes an allocation based on that inventory, hones the investment discipline for the asset allocation and sets parameters so that the Firm can track and monitor the overall process. Rede Wealth utilizes a combination of fundamental, technical and cyclical analysis while employing an asset allocation strategy based on a derivative of Modern Portfolio Theory (“MPT”). Fundamental analysis involves an evaluation of the fundamental financial condition and competitive position of a particular fund or issuer. For Rede Wealth, this process typically involves an analysis of an issuer’s management team, investment strategies, style drift, past performance, reputation and financial Page | 8  Disclosure Brochure strength in relation to the asset class concentrations and risk exposures of the Firm’s model asset allocations. A substantial risk in relying upon fundamental analysis is that while the overall health and position of a company may be good, evolving market conditions may negatively impact the security. Technical analysis involves the examination of past market data rather than specific issuer information in determining the recommendations made to clients. Technical analysis may involve the use of mathematical based indicators and charts, such as moving averages and price correlations, to identify market patterns and trends which may be based on investor sentiment rather than the fundamentals of the company. A substantial risk in relying upon technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Rede Wealth will be able to accurately predict such a reoccurrence. Cyclical analysis is similar to technical analysis in that it involves the assessment of market conditions at a macro (entire market or economy) or micro (company specific) level, rather than focusing on the overall fundamental analysis of the health of the particular company that Rede Wealth is recommending. The risks with cyclical analysis are similar to those of technical analysis. Modern Portfolio Theory (“MPT”) is a mathematical based investment discipline that seeks to quantify expected portfolio returns in relation to corresponding portfolio risk. The basic premise of MPT is that the risk of a particular holding is to be assessed by comparing its price variations against those of the market portfolio. However, MPT disregards certain investment considerations and is based on a series of assumptions that may not necessarily reflect actual market conditions. As such, the factors for which MPT does not account (e.g., tax implications, regulatory constraints and brokerage costs) may negate the upside or add to the actual risk of a particular allocation. Nevertheless, Rede Wealth’s investment process is structured in such a way to integrate those assumptions and real life considerations for which MPT analytics do not account. As stated in Item 4, Rede Wealth primarily allocates client assets among ETFs, stocks and Independent Managers. On a limited basis, the Firm may also utilize mutual funds, bonds, options, REITs and MLPs. Rede Wealth tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. The Firm consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Risk of Loss Page | 9  Disclosure Brochure Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of Rede Wealth’s recommendations and/or investment decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. There can be no assurance that the Firm will be able to predict those price movements accurately or capitalize on any such assumptions. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Use of Independent Managers As stated above, the Firm may retain certain Independent Managers to manage a portion of its clients’ assets. In these situations, Rede Wealth continues to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, Rede Wealth generally may not have the ability to supervise the Independent Managers on a day-to-day basis. Page | 10  Disclosure Brochure Master Limited Partnerships (MLPs) MLPs are collective investment vehicles, the partnership interests of which are publicly traded on national securities exchanges. MLPs invest primarily in companies within the energy sector that engage in qualifying lines of business, such as natural resource production and mineral refinement. MLPs are therefore subject to the underlying volatility of the energy industry and may be adversely affected by changes to supply and demand, regional instability, currency spreads, inflation and interest rate fluctuations, among other such factors. In addition, MLPs operate as pass-through tax entities, meaning that investors are liable for their pro rata share of the partnership taxes, regardless of the types of accounts where the interests are held. Options Options allow investors to buy or sell a security at a contracted “strike” price or within a specific period of time. Clients may pay or collect a premium for buying or selling an option. Investors transact in options to either hedge (i.e., limit) losses in an attempt to reduce risk or to speculate on the performance of the underlying securities. Options transactions contain a number of inherent risks, including the partial or total loss of principal in the event that the value of the underlying security or index does not increase/decrease to the level of the respective strike price. Holders of options contracts are also subject to default by the option writer which may be unwilling or unable to perform its contractual obligations. Real Estate Investment Trusts (REITs) Rede Wealth may recommend an investment in, or allocate assets among, various REITs the shares of which exist in the form of either publicly traded or privately placed securities. REITs are collective investment vehicles with portfolios comprised primarily of real estate and mortgage related holdings. Many REITs hold heavy concentrations of investments tied to commercial and/or residential developments, which inherently subject REIT investors to the risks associated with a downturn in the real estate market. Investments linked to certain regions that experience greater volatility in the local real estate market may give rise to large fluctuations in the value of the vehicle’s shares. Mortgage related holdings may give rise to additional concerns pertaining to interest rates, inflation, liquidity and counterparty risk. Management through Similarly Managed “Model” Accounts The Firm manages certain accounts through the use of similarly managed “model” portfolios, whereby the Firm allocates all or a portion of its clients’ assets among various mutual funds and/or securities on a discretionary basis using one or more of its proprietary investment strategies. In managing assets through the use of models, the Firm remains in compliance with the safe harbor provisions of Rule 3a-4 of the Investment Company Act of 1940. Page | 11  Disclosure Brochure The strategy used to manage a model portfolio may involve an above average portfolio turnover that could negatively impact clients’ net after tax gains. While the Firm seeks to ensure that clients’ assets are managed in a manner consistent with their individual financial situations and investment objectives, securities transactions effected pursuant to a model investment strategy may be done without regard to a client’s individual tax ramifications. Clients should contact the Firm if they experience a change in their financial situation or if they want to impose reasonable restrictions on the management of their accounts. Item 9. Disciplinary Information In November 2023, a regulatory action was initiated against Rede Wealth LLC based on allegations that the firm violated VAC-5-800A by allowing an investment adviser representative to continue servicing client accounts despite the adviser’s pattern of unprofessional and concerning conduct. The matter was settled in November 2023, wherein Rede Wealth LLC paid $30,000 in monetary penalties and $5,000 to defray the cost of investigation of the matter. Rede Wealth neither admitted nor denied the allegations made in the order. Item 10. Other Financial Industry Activities and Affiliations Neither Rede Wealth nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. Neither Rede Wealth nor its representatives are registered or have applications pending to register as futures commission merchants, or commodity pool operators/advisors. As described in Items 4 and 5, Rede Wealth selects and recommends other investment advisers (Independent Managers). Rede Wealth does not receive direct or indirect compensation from independent managers. The compensation Rede Wealth receives in connection with Independent Managers is paid in the form of the advisory fees paid by the Client, not any of such advisers. Rede Wealth and its management persons have no other relationships that are material to its advisory business. Item 11. Code of Ethics Rede Wealth has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Rede Wealth’s Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. Page | 12  Disclosure Brochure The Code of Ethics also requires certain of Rede Wealth’s personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless: • the transaction has been completed; • the transaction for the Supervised Person is completed as part of a batch trade with clients; or • a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. Clients and prospective clients may contact Rede Wealth to request a copy of its Code of Ethics. Item 12. Brokerage Practices Recommendation of Broker/Dealers for Client Transactions Rede Wealth generally recommends that clients utilize the custody, brokerage and clearing services of Schwab Advisor ServicesTM (“Schwab”) for investment management accounts. Factors which Rede Wealth considers in recommending Schwab or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Schwab may enable Page | 13  Disclosure Brochure the Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Schwab may be higher or lower than those charged by other Financial Institutions. The commissions paid by Rede Wealth’s clients to Schwab comply with the Firm’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where Rede Wealth determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. Rede Wealth seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. Consistent with obtaining best execution, brokerage transactions may be directed to certain broker/dealers in return for investment research products and/or services which assist Rede Wealth in its investment decision-making process. Such research generally will be used to service all of the Firm’s clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because Rede Wealth does not have to produce or pay for the products or services. Rede Wealth periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Software and Support Provided by Financial Institutions Rede Wealth may receive without cost from Schwab computer software and related systems support, which allow the Firm to better monitor client accounts maintained at Schwab. Rede Wealth may receive the software and related support without cost because the Firm renders investment management services to clients that maintain assets at Schwab. The software and support is not provided in connection with securities transactions of clients (i.e., not “soft dollars”). The software and related systems support may benefit the Firm, but not its clients directly. In fulfilling its duties to its clients, Rede Wealth endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the Firm’s receipt of economic benefits from a broker/dealer creates a conflict of interest since these benefits may influence the Firm’s choice of broker/dealer over another that does not furnish similar software, systems support or services. Page | 14  Disclosure Brochure Specifically, Rede Wealth may receive the following benefits from Schwab: • A certain amount of funding in credits to be used toward qualifying third-party service providers used in connection with the initial set up of the Firm’s research, technology and software platforms; • Receipt of duplicate client confirmations and bundled duplicate statements; • Access to a trading desk that exclusively services its institutional traders; • Access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and • Access to an electronic communication network for client order entry and account information. Brokerage for Client Referrals Rede Wealth does not consider, in selecting or recommending broker/dealers, whether the Firm receives client referrals from the Financial Institutions or other third party. Directed Brokerage We do not accept client-directed brokerage, but utilize our recommended custodian Charles Schwab. Commissions or Sales Charges for Recommendations of Securities Rede Wealth nor its representatives are registered as, or have pending applications to become, a broker/dealer Or a representative of a broker/dealer. Trade Aggregation Transactions for each client generally will be effected independently, unless Rede Wealth decides to purchase or sell the same securities for several clients at approximately the same time. Rede Wealth may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Page | 15  Disclosure Brochure Under this procedure, transactions will generally be averaged as to price and allocated among the Firm’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which Rede Wealth’s Supervised Persons may invest, the Firm generally does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Rede Wealth does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Item 13. Review of Accounts Account Reviews Rede Wealth monitors client portfolios on a continuous and ongoing basis while regular account reviews are conducted on at least a quarterly basis. Such reviews are conducted by the Firm’s Investment Committee or one of its investment adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals and objectives with Rede Wealth and to keep the Firm informed of any changes thereto. The Firm contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations, and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. Account Statements and Reports Page | 16  Disclosure Brochure Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from Rede Wealth and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from Rede Wealth or an outside service provider. Item 14. Client Referrals and Other Compensation Client Referrals The Firm does not currently provide compensation to any third-party solicitors for client referrals. In the event a client is in the future introduced to Rede Wealth by either an unaffiliated or an affiliated solicitor, the Firm may pay that solicitor a referral fee in accordance with applicable state securities laws. Unless otherwise disclosed, any such referral fee is paid solely from Rede Wealth’s investment management fee and does not result in any additional charge to the client. If the client is introduced to the Firm by an unaffiliated solicitor, the solicitor is required to provide the client with Rede Wealth’s written brochure(s) and a copy of a solicitor’s disclosure statement containing the terms and conditions of the solicitation arrangement. Any affiliated solicitor of Rede Wealth is required to disclose the nature of his or her relationship to prospective clients at the time of the solicitation and will provide all prospective clients with a copy of the Firm’s written brochure(s) at the time of the solicitation. Services that Generally Benefit Us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Education conferences and events • Technology, compliance, legal, and business consulting; • Publications and conferences on practice management and business success; and • Access to employee benefits providers, human capital consultants and insurance providers. Page | 17  Disclosure Brochure Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab has and/or may provide discounts or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab has and/or may provide us with other benefits such as occasional business entertainment of our personnel. Other Economic Benefits The Firm may also receive an economic benefit from other third parties (non-clients) for providing advisory services, such as those described in Item 12 (above). Item 15. Custody The Advisory Agreement and/or the separate agreement with any Financial Institution generally authorize Rede Wealth and/or the Independent Managers to debit client accounts for payment of the Firm’s fees and to directly remit those funds to the Firm in accordance with applicable custody rules. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to Rede Wealth. Under government regulations, we are deemed to have custody of your assets if you authorize us to instruct Schwab to deduct our advisory fees directly from your account. Schwab maintains actual custody of your assets. You will receive account statements directly from Schwab at least quarterly. They will be sent to the email or postal mailing address you provided to Schwab. You should carefully review those statements promptly when you receive them. Rede Wealth also has custody due to the authorized deduction of the advisor’s fee. Rede Wealth follows the safeguards concerning authorized fee deductions and is not required to conduct client account audits. Custody is also disclosed in Part 1A of Form ADV because Rede Wealth has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). In addition, as discussed in Item 13, Rede Wealth may also send periodic supplemental reports to clients. We urge you to compare to carefully review the statements sent directly by the Financial Institution (Schwab) and compare them to any supplemental reports received from Rede Wealth Page | 18  Disclosure Brochure Item 16. Investment Discretion Rede Wealth is given the authority to exercise discretion on behalf of clients. Rede Wealth is considered to exercise investment discretion over a client’s account if it can effect and/or direct transactions in client accounts without first seeking their consent. The Firm is given this authority through a power-of-attorney included in the agreement between Rede Wealth and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). The Firm may take discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; and • The Independent Managers to be hired or fired. Item 17. Voting Client Securities Acceptance of Proxy Voting Authority Rede Wealth does not perform proxy voting services on the client’s behalf. Clients are encouraged to read through the information provided with the proxy voting documents and to make a determination based on the information provided. Upon the client’s request, Firm representatives may provide limited clarifications of the issues presented in the proxy voting materials based on his or her understanding of issues presented in the proxy voting materials. However, clients have the ultimate responsibility for making all proxy voting decisions. Item 18. Financial Information Rede Wealth is not required to disclose any financial information due to the following: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and Page | 19  Disclosure Brochure • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. Page | 20