Regimen Wealth, LLC

FORM ADV PART 2A BROCHURE Item 1 – Cover Page 3300 Riverwood Pkwy, Suite 1030 Atlanta, GA 30339 770.738.8200 www.regimenwealth.com This brochure provides information about the qualifications and business practices of Regimen Wealth, LLC. If you have any questions regarding the contents of this brochure, please contact us at 770.738.8200. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. information about Regimen Wealth, LLC is available on the SEC’s website at Additional www.adviserinfo.sec.gov. June 15, 2026  Item 2 – Material Changes In this Item, Regimen is required to discuss any material changes that have been made to the brochure since the last annual amendment. Following is a summary of material changes to Regimen’s Form ADV Part 2A (the “Brochure”) since the last annual update filing on March 12, 2026: Item 4 – Description of financial planning services, including Core and Discretionary Planning topics, has been revised detailing our financial planning process. Item 4 – Removed ERISA Title I disclosure for clients with retirement accounts. Item 5 – Description of fees for financial planning and investment management services has revised. Fees for financial planning services are separate from and in addition to fees for investment management services. Item 8 – Description of methods of analysis and investment strategies has been revised.  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 ................................................................................................................... 6 Item 6 - Performance-Based Fees and Side-by-Side Management ............................................................... 9 Item 7 - Types of Clients ............................................................................................................................ 10 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss .................................................... 10 Item 9 – Disciplinary Information .............................................................................................................. 15 Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 15 Item 11 – Code of Ethics, Participation or Interest in Client Transactions ................................................. 15 Item 12 – Brokerage Practices .................................................................................................................... 15 Item 13 – Review of Accounts .................................................................................................................... 18 Item 14 – Client Referrals and Other Compensation .................................................................................. 20 Item 15 – Custody ....................................................................................................................................... 20 Item 16 – Investment Discretion ................................................................................................................. 20 Item 17 – Voting Client Securities .............................................................................................................. 20 Item 18 – Financial Information ................................................................................................................. 21  Regimen Wealth Disclosure Brochure Item 4 - Advisory Business A. Description of the Advisory Firm Regimen Wealth, LLC (“Regimen” or the “Firm”) is a limited liability company organized in the State of Georgia. Regimen is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). Regimen has been in business since July 2020. The principal owners of the Firm are Ian Alexandre Weinstein and Aiki Altmets. B. Types of Advisory Services Regimen primarily offers personalized financial planning and discretionary investment management services to individuals and high-net-worth individuals. Regimen specializes in financial planning services and utilizes its financial planning process, analysis, and tools as part of its overall advisory services to clients; however, clients are under no obligation to engage Regimen for financial planning or to implement any recommendations through Regimen. Financial Planning Services Regimen offers financial planning services to set forth goals, objectives, and implementation strategies for the client over the long term. Regimen’s comprehensive financial planning analysis consists of two components: Core Planning topics and Discretionary Planning topics. Unless otherwise stated, review and analysis of Core Planning topics is generally incorporated into the financial planning process for all clients. Additionally, depending upon individual client requirements and life-phase factors (e.g. employment status, marital status, dependent children, retirement status, business professional/owner/executive, etc.), Regimen may include one or more of the Discretionary Planning topics described below: Income/Expense Analysis Core Planning • Net Worth Analysis • Cash Reserve • Cash Flow Analysis and Planning • • Goal Planning/Funding • Retirement Planning • Protection Planning • Risk Profile Review and Goal Alignment • Behavioral Finance Approach • *Tax Planning Strategies *Tax status is reviewed as part of the Core planning process, however, the implementation of tax strategies depends upon the complexity and needs of each client. Discretionary Planning • Life Insurance Needs Analysis • Long Term Care Planning • Education Planning • Debt Management Strategies • Pension Strategies • Employee Benefits Review • Compensation Package Review • Executive Compensation Strategies • Social Security Analysis • Health Care in Retirement • Small Business Owner Strategies • Multigenerational Wealth Discussions • Coordination with CPAs, attorneys, and other relevant professionals Regimen’s financial planning process involves an initial due diligence and data gathering process to create a roadmap tailored to financial situation of each client. Core Planning will be provided to the client on an initial and annual basis and may be tailored further based on client’s specific needs, wishes and/or circumstances. This personalization may include, but is not guaranteed or limited to, adding or eliminating 4  Regimen Wealth Disclosure Brochure topics, ad hoc conversations, multiple updates to the analysis due to major changes mid-process, calls and/or meetings with clients and/or other professionals. Regimen typically conducts mid-year and annual reviews with clients to collect updated information and discuss any changes to the client’s financial goals or circumstances. The specific services and level of analysis of Core and Discretionary Planning topics provided to each client will vary depending on information received from the financial planning process. Clients should notify us promptly anytime there is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the financial information provided to us either initially or between review cycles. On an annual basis, Regimen provides clients with an executive summary detailing its financial planning analysis and recommendations. Clients are under no obligation to implement any of the recommendations provided by Regimen. However, should a client decide to proceed with the implementation of the investment recommendations then the client can either have Regimen implement those recommendations or utilize the services of any investment adviser or broker-dealer of their choice. Regimen cannot provide any guarantees or promises that a client’s financial goals and objectives will be met. Investment Management Services Regimen offers investment management services on a discretionary basis. All investment advice provided is customized to each client’s financial situation, investment objectives, time horizon, risk tolerance, tax considerations, liquidity needs, existing holdings, and any reasonable investment restrictions. The information provided by the client, together with any other information relating to the client’s overall financial circumstances, will be used by Regimen to determine the appropriate portfolio asset allocation and investment strategy for the client. The securities utilized by Regimen for investment in client accounts primarily consist of exchange traded funds (ETFs), but we may also invest in equity securities, mutual funds, corporate bonds, REITS, fixed and variable annuities, insurance products, and private investment vehicles, among others, if we determine such investments fit within a client’s objectives and are in the best interest of our clients. External Managers Regimen may further recommend to clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“External Managers”). The client may be required to enter into a separate agreement with the External Manager(s), which will set forth the terms and conditions of the client’s engagement of the External Manager. Regimen generally renders services to the client relative to the discretionary selection of External Managers. Regimen also assists in establishing the client’s investment objectives for the assets managed by External Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated External Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are exclusive of, and in addition to, the annual advisory fee charged by Regimen. Note Regarding Tax or Legal Advice: In providing services, Regimen does not offer or otherwise provide tax or legal advice. Regimen will, at a client’s direction and approval, work with a client’s existing tax or legal professionals to assist in the provision of the services. Fees charged by any tax, legal, 5  Regimen Wealth Disclosure Brochure or other third-party professionals are the responsibility of the client. Regimen may refer professionals; however, there is no compensation to Regimen for these referrals, and clients are under no obligation to use the referred service providers. C. Client-Tailored Advisory Services Clients may impose reasonable restrictions on the management of their accounts if Regimen determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Regimen’s management efforts. D. Information Received from Clients Regimen will not assume any responsibility for the accuracy or the information provided by clients. Regimen is not obligated to verify any information received from a client or other professionals (e.g. attorney, accountant) designated by a client, and Regimen is expressly authorized by the client to rely on such information provided. Under all circumstances, clients are responsible for promptly notifying Regimen in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. E. Assets Under Management As of December 31, 2025, Regimen had $365,160,462 in assets under management, all of which were managed on a discretionary basis. Item 5 - Fees and Compensation Regimen charges a fixed fee for financial planning services and fees based on a percentage of assets under management for investment management services. Fees vary depending on the particular types of services to be provided. The specific fees charged by Regimen for services provided will be set forth in each client agreement. A. Financial Planning and Investment Management Services Fees for Financial Planning Services Clients receiving financial planning services are charged a fixed annual fee of up to $50,000, depending on the scope, complexity, and level of services provided, including to the extent the client engages Regimen for review and analysis of Discretionary Planning topics described in Item 4. The specific fee and scope of services will be set forth in a written financial planning agreement between Regimen and the client prior to the commencement of services. As a general policy, clients maintaining $3,250,000 or more in billable managed assets with Regimen have the option to receive complimentary financial planning services at no additional charge. • This benefit is subject to change at Regimen’s discretion and will be evaluated at least annually during the client’s service renewal month for the purpose of determining any adjustments to the financial planning fee. 6  Regimen Wealth Disclosure Brochure • A financial planning agreement may still be maintained even if no separate financial planning fee is charged. Fees for Investment Management Services Regimen charges an annual asset-based investment management services fee that is agreed upon with each client and set forth in an agreement executed by Regimen and the client. The management fee varies with breakpoints in accordance with the following schedule: FEE SCHEDULE Market Value of Assets* Up to $1,000,000 $1,000,001 to $3,000,000 $3,000,001 to $5,000,000 $5,000,001 to $10,000,000 Above $10,000,000 Fee Rate** 1.25% 1.00% 0.85% 0.65% 0.50% *Market Value of Assets includes the managed and billable assets of all related client accounts, specifically the accounts of direct family members sharing the same residential address. **Fee Rate only applies to the Market Value of Assets within that range (e.g. for an account with a market value of assets of $2,000,000 – the first $1,000,000 will be subject to a fee rate of 1.25% and the remaining assets will be subject to a fee rate of 1.00%). Regimen’s management fee is prorated and charged monthly, in advance, based upon the market value of managed assets on the last day of the previous month as determined by an independent third party (including the client’s custodian or other third-party source). However, the management fee for the initial month will be paid, in arrears, based on the value of the assets on the date of deposit for the pro rata number of days remaining in the month. Any partial billing periods will be prorated and refunded in the event of unearned fee from account closure. For purposes of fee calculation, the asset value of client accounts includes cash and cash equivalents. Additionally, if cash or securities are deposited to or withdrawn from a client’s account on an individual business day during any month, Regimen will (i) assess investment management services fees to the deposited assets based on the value of the assets on the date of deposit for the pro rata number of days remaining in the month, or (ii) refund unearned, prepaid investment management services fees based on the value of the assets on the date of withdrawal for the pro rata number of days remaining in the month. No additional investment management services fees or adjustments to previously assessed investment management services fees will be made in connection with deposits or withdrawals that occur during the last month of the month. Note on Fee-based Annuities Insurance products billed as part of fees based upon assets under management will be charged either quarterly in advance or quarterly in arrears based on the individual insurance carrier. The fee is based upon the market value of the assets being managed by Regimen on the last day of the previous quarter. If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with 7  Regimen Wealth Disclosure Brochure respect to such assets is adjusted to reflect the interim change in portfolio value as related to the deposit/withdrawal and billed or charged not later than at the time of the next billing. Notwithstanding the foregoing, Regimen and the client may choose to negotiate an annual financial planning or investment management fee that varies from the schedule and ranges set forth above. Factors upon which a different financial planning or management fee may be based include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and complexity of the products and investments involved, time commitments, and travel requirements. The investment management services fee charged by the Firm will apply to all of the client’s assets under management, unless specifically excluded in the client agreement. Although Regimen believes that its fees are competitive, clients should understand that lower fees for comparable services may be available from other sources and firms. The investment advisory agreement between Regimen and the client may be terminated at will by either Regimen or the client upon written notice. Regimen does not impose termination fees when the client terminates the investment advisory relationship, except when agreed upon in advance. B. Payment of Fees Financial Planning Services Financial planning fees are billed monthly in advance. Clients will receive invoices detailing the fee amount due and payable. To the extent fees are paid in advance, unearned fees will be refunded as follows: • The financial planning agreement may be terminated by either party at any time upon written notice. • Upon termination, any unearned portion of prepaid fees will be promptly refunded on a pro rata basis, based on the number of days remaining in the billing period. • Regimen does not impose termination fees unless otherwise disclosed and agreed to in writing in advance. Investment Management Services Regimen generally deducts its investment management services fee from a client’s investment account(s) held at his/her custodian. Upon engaging Regimen to manage such account(s), a client grants Regimen this limited authority through a written instruction to the custodian of his/her account(s). The client is responsible for verifying the accuracy of the calculation of the investment management services fee; the custodian will not determine whether the fee is accurate or properly calculated. Unless otherwise agreed to, clients are generally required to have their investment management services fees deducted from their accounts. The custodian of the client’s accounts provides each client with a statement, at least quarterly, indicating separate line items for all amounts disbursed from the client's account(s), including any fees paid directly to Regimen. Clients may make additions to and withdrawals from their account at any time, subject to Regimen’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets at any time on notice to Regimen, subject to the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term investments and the 8  Regimen Wealth Disclosure Brochure withdrawal of assets may impair the achievement of a client’s investment objectives. Regimen 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. C. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers In connection with Regimen’s management of an account, a client will incur fees and/or expenses separate from and in addition to Regimen’s advisory fee. These additional fees may include transaction charges and the fees/expenses charged by any custodian, subadvisor, mutual fund, ETF, separate account manager (and the manager’s platform manager, if any), limited partnership, or other advisor, transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law, retirement plan account fees (where applicable), margin interest, brokerage commissions, mark-ups or mark-downs and other transaction-related costs, electronic fund and wire fees, and any other fees that reasonably may be borne by a brokerage account. For External Managers, clients should review each manager’s Form ADV 2A disclosure brochure and any contract they sign with the External Manager (in a dual contract relationship). The client is responsible for all such fees and expenses. Please see Item 12 of this brochure regarding brokerage practices. D. Prepayment of Fees As noted in Item 5(B) above, Regimen’s advisory fees generally are paid in advance. Upon the termination of a client’s advisory relationship, Regimen will issue a refund equal to any unearned advisory services fee for the remainder of the month. E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients Regimen generally does not buy or sell securities and does not receive any compensation for securities transactions in any client account, other than the financial planning and investment advisory fees noted above. In limited situations the Firm receives commission-based compensation for the implementation of fixed insurance products (e.g. term life or disability insurance) stemming from financial planning recommendations. This practice presents a conflict of interest because the Firm has an incentive to recommend fixed insurance products to clients for the purpose of generating additional revenue rather than solely based on a client’s needs. The Firm addresses this conflict by requiring its supervised persons to act in the best interests of its clients when making such recommendations (e.g. insurance coverage gap identified). However, clients are under no obligation to purchase insurance products through our Firm and affiliated personnel. Item 6 - Performance-Based Fees and Side-by-Side Management Regimen does not charge performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of capital gains or capital appreciation of a client’s account. 9  Regimen Wealth Disclosure Brochure Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Regimen’s fees are calculated as described in Item 5 above. Item 7 - Types of Clients Regimen offers services primarily to individuals and high-net-worth individuals but may also provide services to corporations and other business entities. Regimen does not impose a minimum portfolio size or a minimum initial investment to open an account. However, Regimen does reserve the right to accept or decline a potential client for any reason in its sole discretion. Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Risk of Loss A primary step in Regimen’s investment management process is to develop an understanding of each client. The Firm works closely with clients to understand their financial condition, investment objectives, time horizon, risk tolerance, tax considerations, liquidity needs, existing holdings, and any reasonable investment restrictions. This information is used to assemble a picture of the client’s financial situation before implementing any investment strategy. Once client goals and constraints are identified, Regimen applies an evidence-driven investment approach informed by academic research and widely accepted investment principles. The Firm seeks to construct diversified portfolios designed to balance risk and return in a manner consistent with each client’s objectives and comfort level. In developing investment strategies, the Firm considers the impact of taxes, fees, and implementation costs on long-term outcomes and seeks to improve after-tax efficiency where appropriate. Portfolio Structure and Implementation Client portfolios are generally constructed using a model-based framework, which may include one or more of the following components, depending on client circumstances: • Core Allocation The core of a portfolio is typically allocated to broadly diversified, low-cost investment vehicles, such as mutual funds and ETFs, designed to provide exposure to domestic and global equity and fixed income markets. This core allocation is intended to serve as the long-term foundation of the portfolio. • Factor-Based or Strategic Tilts Where appropriate, portfolios may include allocations designed to tilt toward certain risk factors or asset classes that academic research has shown may influence long-term returns, such as size, value, quality, or profitability. The inclusion and sizing of such tilts are based on client risk tolerance, time horizon, and ability to maintain the strategy through market cycles. 10  Regimen Wealth Disclosure Brochure • Actively Managed Strategies In certain cases, the Firm may incorporate actively managed mutual funds, ETFs, or separate account strategies when it believes they may be appropriate for specific asset classes, market environments, or client needs. Active strategies are evaluated using a combination of qualitative and quantitative criteria, including investment process, risk management, cost, and consistency. • Alternative or Diversifying Investments For certain clients, and when appropriate based on objectives, risk tolerance, liquidity needs, and net worth, portfolios may include alternative or diversifying investments. These investments are typically intended to provide diversification benefits rather than to enhance short-term returns and may involve higher risks, including liquidity constraints. • Tax-Aware Implications When applicable, the Firm seeks to implement portfolios in a tax-aware manner, which may include asset location strategies, tax-efficient investment selection, and tax-loss harvesting. Tax strategies are applied in coordination with the client’s broader financial and tax planning and are subject to account type and applicable laws. In general, Regimen employs a long-term investment approach designed to support the client’s stated goals and planning horizons. However, the Firm may recommend shorter-term actions when warranted by client- specific circumstances, risk management considerations, or tax planning opportunities. Client portfolios with similar investment objectives and asset allocation goals may own different securities and investments. The client’s portfolio size, tax sensitivity, desire for simplicity, income needs, long-term wealth transfer objectives, time horizon and choice of custodian are all factors that influence Regimen’s investment recommendations. Investing in securities involves a risk of loss. A client can lose all or a substantial portion of his/her investment. A client should be willing to bear such a loss. Some investments are intended only for sophisticated investors and can involve a high degree of risk. B. Material Risks Involved Investing in securities involves a significant risk of loss which clients should be prepared to bear. Regimen’s investment recommendations are subject to various market, currency, economic, political and business risks, and such investment decisions will not always be profitable. Clients should be aware that there may be a loss or depreciation to the value of the client’s account. There can be no assurance that the client’s investment objectives will be obtained and no inference to the contrary should be made. Generally, the market value of equity stocks will fluctuate with market conditions, and small-stock prices generally will fluctuate more than large-stock prices. The market value of fixed income securities will generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed income securities are obligations of the issuer to make payments of principal and/or interest on future dates, and include, among other securities: bonds, notes and debentures issued by corporations; debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a non-U.S. 11  Regimen Wealth Disclosure Brochure government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed and asset-backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration fixed income securities will generally fluctuate more than shorter duration fixed income securities. Investments in overseas markets also pose special risks, including currency fluctuation and political risks, and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for investments in emerging markets. In addition, there is no assurance that a mutual fund or ETF will achieve its investment objective. Past performance of investments is no guarantee of future results. Additional risks involved in the securities recommended by Regimen include, among others: • Stock market risk, which is the chance that stock prices overall will decline. The market value of equity securities will generally fluctuate with market conditions. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend to fluctuate over the short term as a result of factors affecting the individual companies, industries or the securities market as a whole. Equity securities generally have greater price volatility than fixed income securities. • Sector risk, which is the chance that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall stock market. Daily fluctuations in specific market sectors are often more extreme than fluctuations in the overall market. • Issuer risk, which is the risk that the value of a security will decline for reasons directly related to the issuer, such as management performance, financial leverage, and reduced demand for the issuer's goods or services. • Non-diversification risk, which is the risk of focusing investments in a small number of issuers, industries or foreign currencies, including being more susceptible to risks associated with a single economic, political, or regulatory occurrence than a more diversified portfolio might be. • Value investing risk, which is the risk that value stocks 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 in theory they are already undervalued. Value stocks are typically less volatile than growth stocks but may lag behind growth stocks in an up market. • Smaller company risk, which is the risk that the value of securities issued by a smaller company will go up or down, sometimes rapidly and unpredictably as compared to more widely held securities. Investments in smaller companies are subject to greater levels of credit, market and issuer risk. • Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests exclusively in securities of U.S. companies. Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result of political 12  Regimen Wealth Disclosure Brochure and economic instability in the foreign country, less public information about issuers of securities, different securities regulation, different accounting, auditing and financial reporting standards and less liquidity than in the U.S. markets. • Interest rate risk, which is the chance that prices of fixed income securities decline because of rising interest rates. Similarly, the income from fixed income securities may decline because of falling interest rates. • Credit risk, which is the chance that an issuer of a fixed income security will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that fixed income security to decline. • Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying securities it is designed to track. ETFs are also subject to secondary market trading risks. In addition, an ETF may not replicate exactly the performance of the index it seeks to track for a number of reasons, including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the secondary market, or discrepancies between the ETF and the index with respect to weighting of securities or number of securities held. • Management risk, which is the risk that the investment techniques and risk analyses applied by Regimen may not produce the desired results and that legislative, regulatory, or tax developments affect the investment techniques available to Regimen. There is no guarantee that a client’s investment objectives will be achieved. • Real Estate risk, which is the risk that an investor’s investments in Real Estate Investment Trusts (“REITs”) or real estate-linked derivative instruments will subject the investor to risks similar to those associated with direct ownership of real estate, including losses from casualty or condemnation, and changes in local and general economic conditions, supply and demand, interest rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses. An investment in REITs or real estate-linked derivative instruments subject the investor to management and tax risks. • Investment Companies (“Mutual Funds”) risk, when an investor invests in mutual funds, the investor will bear additional expenses based on his/her pro rata share of the mutual fund’s operating expenses, including the management fees. The risk of owning a mutual fund generally reflects the risks of owning the underlying investments the mutual fund holds. • Cybersecurity risk, which is the risk related to unauthorized access to the systems and networks of Regimen and its service providers. The computer systems, networks and devices used by Regimen and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks or devices 13  Regimen Wealth Disclosure Brochure potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow or otherwise disrupt operations, business processes or website access or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or other compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issues of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers and other financial institutions; and other parties. In addition, substantial costs may be incurred by those entities in order to prevent any cybersecurity breaches in the future. • Alternative Investments / Private Funds risk, investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks 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 investment and none expected to develop; volatility of returns; restrictions on transferring interests in the investment; potential lack of diversification and resulting higher risk due to concentration of trading authority when a single adviser is utilized; absence of information regarding valuations and pricing; delays in tax reporting; less regulation and higher fees than mutual funds; risks associated with the operations, personnel, and processes of the manager of the funds investing in alternative investments. There also are risks surrounding various insurance products that are recommended to Regimen clients from time to time. Such risks include but are not limited to loss of premiums. Prior to purchasing any insurance product, clients should carefully read the policy and applicable disclosure documents. Clients are advised that they should only commit assets for management that can be invested for the long term, that volatility from investing can occur, and that all investing is subject to risk. Regimen does not guarantee the future performance of a client’s portfolio, as investing in securities involves the risk of loss that clients should be prepared to bear. Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss. 14  Regimen Wealth Disclosure Brochure Use of External Managers Regimen may select certain External Managers to manage a portion of its clients’ assets. In these situations, the success of such recommendations relies to a great extent on the External Managers’ ability to successfully implement their investment strategies. In addition, Regimen generally may not have the ability to supervise the External Managers on a day-to-day basis. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s evaluation of the adviser and the integrity of the adviser’s management. Regimen has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Recommendation of External Managers Regimen may recommend that clients use External Managers based on clients’ needs and suitability. Regimen does not receive separate compensation, directly or indirectly, from such External Managers for recommending that clients use their services. Regimen does not have any other business relationships with the recommended External Managers. Item 11 – Code of Ethics, Participation or Interest in Client Transactions Regimen has a Code of Ethics (the “Code”) which requires Regimen’s employees (“supervised persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Firm’s clients. Among other things, the Code of Ethics sets forth policies and procedures related to conflicts of interest, outside business activities, gifts and entertainment, compliance with insider trading laws and policies and procedures governing personal securities trading by supervised persons. Personal securities transactions of supervised persons present potential conflicts of interest with the price obtained in client securities transactions or the investment opportunity available to clients. The Code addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a client and requiring, with certain exceptions, supervised persons to report their personal securities holdings and transactions to Regimen for review by the Firm’s Chief Compliance Officer. The Code also requires supervised persons to obtain pre-approval of certain investments, including initial public offerings and limited offerings. Regimen will provide a copy of the Code of Ethics to any client or prospective client upon request. Item 12 – Brokerage Practices A. Factors Used to Select Custodians and/or Broker-Dealers Regimen generally recommends that its investment management clients utilize the custody and brokerage services of an unaffiliated broker/dealer custodian (a “BD/Custodian”) with which Regimen has an institutional relationship. Currently, this includes National Financial Services LLC and Fidelity Brokerage 15  Regimen Wealth Disclosure Brochure Services LLC (together with affiliates, “Fidelity”), which is a “qualified custodian” as that term is described in Rule 206(4)-2 of the Advisers Act. The BD/Custodian provides custody of securities, trade execution, and clearance and settlement of transactions placed on behalf of clients by Regimen. If your accounts are custodied at Fidelity, Fidelity will hold your assets in a brokerage account and buy and sell securities when we instruct them to. Clients will pay fees to Fidelity for custody and the execution of securities transactions in their accounts. In making BD/Custodian recommendations, Regimen will consider a number of judgmental factors, including, without limitation: 1) clearance and settlement capabilities; 2) quality of confirmations and account statements; 3) the ability of the BD/Custodian to settle the trade promptly and accurately; 4) the financial standing, reputation and integrity of the BD/Custodian; 5) the BD/Custodian’s access to markets, research capabilities, market knowledge, and any “value added” characteristics; 6) Regimen’s past experience with the BD/Custodian; and 7) Regimen’s past experience with similar trades. Recognizing the value of these factors, clients may pay a brokerage commission in excess of that which another broker might have charged for effecting the same transaction. In exchange for using the services of Fidelity, Regimen may receive, without cost, computer software and related systems support that allows Regimen to monitor and service its clients’ accounts maintained with Fidelity. Fidelity also makes available to the Firm products and services that benefit the Firm but may not directly benefit the client or the client’s account. These products and services assist Regimen in managing and administering client accounts. These may include investment research, either Fidelity’s own and that of third parties. Regimen may use this research to service all or some substantial number of client accounts, including accounts not maintained at Fidelity. In addition to investment research, Fidelity may also make available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; • • provide pricing and other market data; • • facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. Fidelity may also offer other services intended to help us manage and further develop our business enterprise. These services include: educational conferences and events; technology, compliance, legal, and business consulting; • • • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants, and insurance providers. Fidelity may provide some of these services itself. In other cases, Fidelity will arrange for third-party vendors to provide the services to the Firm. Fidelity may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Fidelity may also provide the Firm with other benefits such as occasional business entertainment of Firm personnel. 16  Regimen Wealth Disclosure Brochure In addition, Regimen receives financial support from Fidelity up to capped dollar amount to be used toward qualifying marketing, technology, consulting and/or research expenses incurred by Regimen in registering and launching the operations of Regimen. This financial support is available to Regimen during the first 12 months from the start of Regimen clients having assets custodied at Fidelity, and the ultimate amount payable by Fidelity is dependent upon the amount of Regimen client assets custodied at Fidelity. Furthermore, Fidelity has agreed to reimburse account termination fees charged to Regimen clients by the former custodian of the clients’ accounts up to a capped dollar amount. This reimbursement is available during an initial 12-month period. The benefits received by Regimen through its participation in the Fidelity custodial platform does not depend on the amount of brokerage transactions directed to Fidelity. In addition, there is no corresponding commitment made by Regimen to Fidelity to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of participation in the programs. While as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients maintain their assets in accounts at Fidelity will be based in part on the benefit to Regimen of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by Fidelity. The receipt of these benefits creates a potential conflict of interest and may indirectly influence Regimen’s choice of Fidelity for custody and brokerage services. Regimen will periodically review its arrangements with the BD/Custodians and other broker-dealers against other possible arrangements in the marketplace as it strives to achieve best execution on behalf of its clients. 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 broker- dealer’s services, including, but not limited to, the following: • • • • • a broker-dealer’s trading expertise, including its ability to complete trades, execute and settle difficult trades, obtain liquidity to minimize market impact and accommodate unusual market conditions, maintain anonymity, and account for its trade errors and correct them in a satisfactory manner; a broker-dealer’s infrastructure, including order-entry systems, adequate lines of communication, timely order execution reports, an efficient and accurate clearance and settlement process, and capacity to accommodate unusual trading volume; a broker-dealer’s ability to minimize total trading costs while maintaining its financial health, such as whether a broker-dealer can maintain and commit adequate capital when necessary to complete trades, respond during volatile market periods, and minimize the number of incomplete trades; a broker-dealer’s ability to provide research and execution services, including advice as to the value or advisability of investing in or selling securities, analyses and reports concerning such matters as companies, industries, economic trends and political factors, or services incidental to executing securities trades, including clearance, settlement and custody; and a broker-dealer’s ability to provide services to accommodate special transaction needs, such as the broker-dealer’s ability to execute and account for client-directed arrangements 17  Regimen Wealth Disclosure Brochure and soft dollar arrangements, participate in underwriting syndicates, and obtain initial public offering shares. Brokerage for Client Referrals Regimen does not select or recommend BD/Custodians based solely on whether or not it may receive client referrals from a BD/Custodian or third party. Client Directed Brokerage Generally, in the absence of specific instructions to the contrary, for brokerage accounts that clients engage Regimen to manage on a discretionary basis, Regimen has full discretion with respect to securities transactions placed in the accounts. This discretion includes the authority, without prior notice to the client, to buy and sell securities for the client’s account and establish and affect securities transactions through the BD/Custodian of the client’s account or other broker-dealers selected by Regimen. In selecting a broker- dealer to execute a client’s securities transactions, Regimen seeks prompt execution of orders at favorable prices. Regimen does not accept instructions to custody a client account at a specific BD/Custodian other than Fidelity, or for the historical client accounts referenced above Pershing, and/or direct some or all of his/her brokerage transactions to a specific broker/dealer. Trade Errors Regimen’s goal is to execute trades seamlessly and in the best interests of the client. In the event a trade error occurs, Regimen endeavors to identify the error in a timely manner, correct the error so that the client’s account is in the position it would have been had the error not occurred, and, after evaluating the error, assess what action(s) might be necessary to prevent a recurrence of similar errors in the future. Trade errors generally are corrected through the use of a “trade error” account or similar account at Fidelity, or if applicable another B/D Custodian. In all cases, Regimen will take the appropriate measures to return the client’s account to its intended position. B. Trade Aggregation To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which the Firm’s supervised persons may invest, the Firm will generally do so in a fair equitable manner in accordance with applicable rules promulgated under the Advisers Act and guidance provided by the staff of the SEC and consistent with policies and procedures established by the Firm. Item 13 – Review of Accounts A. Periodic Reviews Financial Planning Services Account Reviews – Financial Planning Clients Upon completion of the initial analysis and recommendations, any ongoing reviews and the frequency of those reviews are established, if provided for in the client agreement. The nature of client reviews is to evaluate the client’s progress during the period based on the provided recommendations / action items. Regimen will collaborate with the financial planning services client to update their financial information 18  Regimen Wealth Disclosure Brochure (i.e. insurance, investments, assets, income, and expenses) and craft any additional or revised recommendations. Investment Management Account Reviews Client portfolios are monitored on an ongoing basis and reviewed periodically in seeking to ensure continued alignment with client objectives, risk tolerance, and financial circumstances. The Firm may recommend portfolio rebalancing or other adjustments due to economic, market or security considerations, changes in client goals, cash flows, tax considerations, or other material life events. Such adjustments are intended to maintain appropriate risk exposure and alignment with the client’s overall strategy rather than to respond to short-term market fluctuations. Generally, Regimen’s investment adviser representatives seek to have at least one annual meeting with clients to conduct a review of clients’ accounts. Accounts are reviewed for consistency with the investment strategy and other parameters set forth for the account and to determine if any adjustments need to be made. For certain clients, depending upon such factors as client account size or agreed upon service levels, Regimen will provide written materials to the client including current portfolio information and the client financial and related information provided. The client is instructed to review such materials and to contact Regimen if there are any required changes or additions to the materials or if the client requests an in-person meeting with a Regimen financial professional. B. Other Reviews and Triggering Factors In addition to the periodic reviews described above, reviews may be triggered by changes in an account holder’s personal, tax, or financial status. Other events that may trigger a review of an account are material changes in market conditions as well as macroeconomic and company-specific events. Clients are encouraged to notify Regimen of any changes in his/her personal financial situation that might affect his/her investment needs, objectives, or time horizon. C. Regular Reports Written brokerage statements are generated no less than quarterly and are sent directly from the qualified custodian. These reports list the account positions, activity in the account over the covered period, and other related information. Additionally, clients are sent confirmations following each brokerage account transaction unless confirmations have been waived. Regimen may also determine to provide account statements and other reporting to clients on a periodic basis. Clients are urged to carefully review all custodial account statements and compare them to any statements and reports provided by Regimen. Regimen statements and reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 19  Regimen Wealth Disclosure Brochure Item 14 – Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients Regimen does not receive benefits from third parties for providing investment advice to clients. B. Compensation to Non-Supervised Persons for Client Referrals Regimen does not enter into agreements with individuals or organizations for the referral of clients. Item 15 – Custody All clients must utilize a “qualified custodian” as detailed in Item 12. Clients are required to engage the custodian to retain their funds and securities and direct Regimen to utilize the custodian for the client’s securities transactions. Regimen’s agreement with clients and/or the clients’ separate agreements with the B/D Custodian may authorize Regimen through such BD/Custodian to debit the clients’ accounts for the amount of Regimen’s fee and to directly remit that fee to Regimen in accordance with applicable custody rules. The BD/Custodian recommended by Regimen has agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to Regimen. Regimen encourages clients to review the official statements provided by the custodian, and to compare such statements with any reports or other statements received from Regimen. For more information about custodians and brokerage practices, see “Item 12 - Brokerage Practices.” Item 16 – Investment Discretion Clients have the option of providing Regimen with investment discretion on their behalf, pursuant to a grant of a limited power of attorney contained in Regimen’s client agreement. By granting Regimen investment discretion, a client authorizes Regimen to direct securities transactions and determine which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be effected. Clients may impose reasonable limitations in the form of specific constraints on any of these areas of discretion with the consent and written acknowledgement of Regimen if Regimen determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Regimen. See also Item 4(C), Client-Tailored Advisory Services. Item 17 – Voting Client Securities Regimen does not accept authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for all and any securities maintained in client portfolios. 20  Regimen Wealth Disclosure Brochure Item 18 – Financial Information Regimen is not required to disclose any financial information pursuant to this item due to the following: a) Regimen does not require or solicit prepayment of more than $1,200 in fees six months or more in advance of rendering services; b) Regimen is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts; and c) Regimen has never been the subject of a bankruptcy petition. 21