SARVER VROOMAN WEALTH ADVISORS LLC

F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Sarver Vrooman Wealth Advisors LLC Office Address: 9237 Ward Parkway Suite 320 Kansas City, MO 64114 Tel: 816-601-1153 Email: peter.vrooman@svwealthadvisors.com Website: www.svwealthadvisors.com April 21, 2026 This brochure provides information about the qualifications and business practices of Sarver Vrooman Wealth Advisors LLC. Being registered as an investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 248-634-7720. 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. A D D I T I O N A L I N F O R M A T I O N A B O U T S A R V E R V R O O M A N W E A L T H A D V I S O R S L L C ( C R D # 3 3 2 6 9 9 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update Since the last filing of this brochure on January 19, 2026, the following has been updated: • We have updated our ownership, Jonathan Sarver is no longer an owner of the firm. • Item 4 has been updated to disclose our most recent calculation for client assets under management. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm.  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Full Brochure Available .................................................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 3 Wrap Fee Programs ......................................................................................................................................................... 3 Client Assets under Management .............................................................................................................................. 3 Item 5: Fees and Compensation ....................................................................................................... 3 Method of Compensation and Fee Schedule .......................................................................................................... 3 Client Payment of Fees ................................................................................................................................................... 4 Additional Client Fees Charged ................................................................................................................................... 4 Prepayment of Client Fees ............................................................................................................................................ 4 External Compensation for the Sale of Securities to Clients ........................................................................... 5 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 5 Sharing of Capital Gains ................................................................................................................................................. 5 Item 7: Types of Clients ....................................................................................................................... 5 Description .......................................................................................................................................................................... 5 Account Minimums .......................................................................................................................................................... 5 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 5 Methods of Analysis ......................................................................................................................................................... 5 Investment Strategy ........................................................................................................................................................ 6 Security Specific Material Risks .................................................................................................................................. 6 Item 9: Disciplinary Information ..................................................................................................... 8 Criminal or Civil Actions ................................................................................................................................................ 8 Administrative Enforcement Proceedings ............................................................................................................. 8  Self- Regulatory Organization Enforcement Proceedings ............................................................................... 8 Item 10: Other Financial Industry Activities and Affiliations ............................................... 8 Broker-Dealer or Representative Registration .................................................................................................... 8 Futures or Commodity Registration ......................................................................................................................... 9 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 9 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 9 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................................................................................................................................... 9 Code of Ethics Description ............................................................................................................................................ 9 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 10 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 10 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest .................................................................................................................. 10 Item 12: Brokerage Practices ......................................................................................................... 10 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 10 Aggregating Securities Transactions for Client Accounts ............................................................................. 11 Item 13: Review of Accounts ........................................................................................................... 11 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 11 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 12 Content of Client Provided Reports and Frequency ........................................................................................ 12 Item 14: Client Referrals and Other Compensation ................................................................ 12 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 12 Advisory Firm Payments for Client Referrals .................................................................................................... 12 Item 15: Custody .................................................................................................................................. 12 Account Statements ...................................................................................................................................................... 12 Item 16: Investment Discretion ..................................................................................................... 13 Discretionary Authority for Trading...................................................................................................................... 13 Item 17: Voting Client Securities ................................................................................................... 13 Proxy Votes ...................................................................................................................................................................... 13 Item 18: Financial Information ...................................................................................................... 14 Balance Sheet .................................................................................................................................................................. 14  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 14 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 14  Item 4: Advisory Business Firm Description Sarver Vrooman Wealth Advisors LLC (“SVWA”) was founded in 2019 and became registered as an investment advisor in 2024. SVWA is owned by the following entites: PAV, LLC (60% owner) owned 100% by Peter Vrooman, TPK, LLC (20% owner) owned 100% by Thomas King, and R3D3, LLC (20% owner) owned 100% by Ronald Dietz. Peter Vrooman is the Chief Compliance Officer. Types of Advisory Services ASSET MANAGEMENT SVWA offers discretionary and non-discretionary asset management services to advisory Clients. SVWA will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize SVWA discretionary authority or non-discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Discretionary When the Client provides SVWA discretionary authority the Client will sign a limited trading authorization or equivalent. SVWA will have the authority to execute transactions in the account without seeking Client approval on each transaction. Non-Discretionary When the Client elects to use SVWA on a non-discretionary basis, SVWA will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, SVWA will obtain prior Client approval on each and every transaction before executing any transaction. ERISA PLAN SERVICES SVWA provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. SVWA will act as a 3(21) advisor. Limited Scope ERISA 3(21) Fiduciary. SVWA may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions. As an investment advisor SVWA has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using SVWA can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are: • Provide investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. SVWA acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii). - 1 -  • Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS. • Provide investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5. • Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options. • Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are: • Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands SVWA’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, SVWA is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. SVWA will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. • Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. SVWA may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between SVWA and Client. 3. SVWA has no responsibility to provide services related to the following types of assets (“Excluded Assets”): • Employer securities; • Real estate (except for real estate funds or publicly traded REITs); • Stock brokerage accounts or mutual fund windows; • Participant loans; • Non-publicly traded partnership interests; • Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or • Other hard-to-value or illiquid securities or property. - 2 -  Excluded Assets will not be included in the calculation of Fees paid to SVWA on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. FINANCIAL PLANNING Financial planning services are available for any applicable topics that the Client would like reviewed. Typical topics reviewed may include but are not limited to: financial goals, personal financial consulting, investment analysis, retirement strategy, cash flow analysis, risk management, long-term investment and estate preservation. If a conflict of interest exists between the interests of SVWA and the interests of the Client, the Client is under no obligation to act upon any recommendation. Implementation of any recommendations will be at the discretion of the Client. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through SVWA. Financial plans will be completed and delivered inside of sixty (60) days contingent on the timely delivery of all applicable documents from the Client. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs SVWA does not sponsor any wrap fee programs. Client Assets under Management Discretionary Amounts: Non-discretionary Amounts: $381,817,165 $70,343,181 Date Calculated: April 15, 2026 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT SVWA charges an annual investment advisory fee based on the total assets under management as follows: Assets Under Management Up to $999,999.99 $1,000,000 to $1,999,999.99 $2,000,000 and Over Annual Fee 1.25% 1.00% 0.75% The annual fee is negotiable. The fees are charged quarterly in advance and are based on the amount of assets managed as of the close of business on the last business day of the previous quarter. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial five (5) business days, the agreement may be terminated by SVWA with thirty (30) days written notice to Client and by the Client at any time with written notice to SVWA. For accounts - 3 -  opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to SVWA. Additionally, all unearned fees will be refunded to the Client. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. ERISA PLAN SERVICES The annual fees are based on the market value of the Included Assets and will not exceed 0.50%. The annual fee is negotiable and may be charged as a percentage of the Included Assets or as a flat fee. Fees may be charged quarterly or monthly in arrears or in advance based on the assets as calculated by the custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets). If the services to be provided start any time other than the first day of a quarter or month, the fee will be prorated based on the number of days remaining in the quarter or month. If this Agreement is terminated prior to the end of the billing cycle, SVWA shall be entitled to a prorated fee based on the number of days during the fee period services were provided or Client will be due a prorated refund of fees for days services were not provided in the billing cycle. The fee schedule, which includes compensation of SVWA for the services is described in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees deducted from Plan Assets. SVWA does not reasonably expect to receive any additional compensation, directly or indirectly, for its services under this Agreement. If additional compensation is received, SVWA will disclose this compensation, the services rendered, and the payer of compensation. SVWA will offset the compensation against the fees agreed upon under the Agreement. FINANCIAL PLANNING SVWA does not charge for financial planning services. Client Payment of Fees Fees for asset management services are deducted from a designated Client account to facilitate billing. The Client must consent in advance to direct debiting of their investment account. Fees for ERISA services will either be deducted from Plan assets or paid directly to SVWA. The Client must consent in advance to direct debiting of their investment account. Additional Client Fees Charged Custodians may charge transaction fees and other related costs on the purchases or sales of mutual funds, equities, bonds and exchange-traded funds. Mutual funds, money market funds and exchange-traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. SVWA does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to SVWA. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Client Fees Asset management fees are billed quarterly in advance. - 4 -  Fees for ERISA 3(21) services may be billed in advance. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to SVWA. External Compensation for the Sale of Securities to Clients SVWA does not receive any external compensation for the sale of securities to Clients, nor do any of the investment advisor representatives of SVWA. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. Item 7: Types of Clients Description SVWA generally provides investment advice to individuals, high net worth individuals, trusts, estates, corporations or business entities. Client relationships vary in scope and length of service. Account Minimums SVWA does not require a minimum to open an account. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis, technical analysis, charting analysis and cyclical analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. - 5 -  Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Investment Strategy The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to SVWA. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Security Specific Material Risks All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with SVWA: • Market Risk: The prices of securities in which Clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Management Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. • Equity Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a - 6 -  whole. This volatility affects the value of the Client’s overall portfolio. Small- and mid- cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • Fixed Income Risk: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. • Investment Companies Risk: When a Client invests in open end mutual funds or ETFs, the Client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, which may be duplicative. In addition, the Client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which Client invests. • Foreign Securities Risk: Funds in which Clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Private Equity/Placement Risk: Because offerings are exempt from registration requirements, no regulator has reviewed the offerings to make sure the risks associated with the investment and all material facts about the entity raising money are adequately disclosed. Securities offered through private placements are generally illiquid, meaning there are limited opportunities to resell the security. Risk of the underlying investment may be significantly higher than publicly traded investments. - 7 -  • Alternative Investments Risk: Alternative investments involve a high degree of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They can be highly leveraged, speculative and volatile, and an investor could lose all or a substantial amount of an investment. • REIT Risk: To the extent that a client invests in REITs, it is subject to risks generally associated with investing in real estate, such as (i) possible declines in the value of real estate, (ii) adverse general and local economic conditions, (iii) possible lack of availability of mortgage funds, (iv) changes in interest rates, and (v) environmental problems. In addition, REITs are subject to certain other risks related specifically to their structure and focus such as: dependency upon management skills; limited diversification; the risks of locating and managing financing for projects; heavy cash flow dependency; possible default by borrowers; the costs and potential losses of self- liquidation of one or more holdings; the possibility of failing to maintain exemptions from securities registration; and, in many cases, relatively small market capitalization, which may result in less market liquidity and greater price volatility. • Long-term purchases: Long-term investments are those vehicles purchased with the intension of being held for more than one year. Typically, the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. • Short-term purchases: Short-term investments are typically held for one year or less. Generally, there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. Item 9: Disciplinary Information Criminal or Civil Actions SVWA and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings SVWA and its management have not been involved in administrative enforcement proceedings. Self- Regulatory Organization Enforcement Proceedings SVWA and its management have not been involved in any self-regulatory organizational enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of SVWA or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration SVWA is not registered as a broker-dealer and no affiliated representatives of SVWA are registered representatives of a broker-dealer - 8 -  Futures or Commodity Registration Neither SVWA nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest SVWA provides services to Halo Securities, LLC and Halo Investing Insurance Services, LLC (“Halo”). Halo provides administrative services to Registered Investment Advisors to facilitate Broker of Record changes on eligible insurance policies. SVWA may recommend Client annuities move to Halo as “broker of record”. In these situations, SVWA will manage the relationship and engagement with the Client, while using reasonable efforts to comply with any investment restrictions and guidelines, in accordance with industry practice. SVWA will provide Halo with investment management and advice based on the Client’s needs and objectives and will monitor the accounts on a continuous basis. Halo will compensate SVWA for their consulting services based on the quarter-end Contracts’ value. This creates a conflict of interest since SVWA will receive compensation from Halo if your contract moves to Halo as broker of records. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest SVWA does not select or recommend other investment advisors. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or independent The affiliated persons (affiliated persons contractors) of SVWA have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of SVWA affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of SVWA. The Code reflects SVWA and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. SVWA’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of SVWA may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. SVWA’s Code is based on the guiding principle that the interests of the Client are our top priority. SVWA’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. - 9 -  The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. SVWA will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest SVWA and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest SVWA and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide SVWA with copies of their brokerage statements. The Chief Compliance Officer of SVWA is Peter Vrooman. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not front run or disadvantage trading for Clients. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest SVWA does not have a material financial interest in any securities being recommended. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide SVWA with copies of their brokerage statements. The Chief Compliance Officer of SVWA is Peter Vrooman. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not front run or disadvantage trading for Clients. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions SVWA will require the use of a particular broker-dealer based on their duty to seek best execution for the Client, meaning they have an obligation to obtain the most favorable terms for a Client under the circumstances. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to affect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. SVWA will select appropriate brokers based on a number of factors including but not limited to their - 10 -  relatively low transaction fees and reporting ability. SVWA relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by SVWA. SVWA does not receive any portion of the trading fees. SVWA will require the use of Trade-PMR Inc. • Research and Other Soft Dollar Benefits The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by SVWA from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. Although SVWA has no formal soft dollar arrangements, SVWA may receive products, research and/or other services from custodians or broker-dealers connected to Client transactions or “soft dollar benefits”. As permitted by Section 28(e) of the Securities Exchange Act of 1934, SVWA receives economic benefits as a result of commissions generated from securities transactions by the custodian or broker-dealer from the accounts of SVWA. SVWA cannot ensure that a particular Client will benefit from soft dollars or the Client’s transactions paid for the soft dollar benefits. SVWA does not seek to proportionately allocate benefits to Client accounts to any soft dollar benefits generated by the accounts. A conflict of interest exists when SVWA receives soft dollars which could result in higher commissions charged to Clients. This conflict is mitigated by the fact that SVWA has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. • Brokerage for Client Referrals SVWA does not receive Client referrals from any custodian in exchange for using that broker-dealer. • Directed Brokerage SVWA does not allow Client directed brokerage accounts. Aggregating Securities Transactions for Client Accounts SVWA is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of SVWA. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. If aggregation is not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-lot trades, etc.) an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by an Investment Advisor Representative of SVWA. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, suitability criteria - 11 -  and reviewing target allocations of each asset class to identify if there is an opportunity for rebalancing. Financial plans are updated as requested by the Client. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information and changes in a Client's own situation. Content of Client Provided Reports and Frequency Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by the Client’s custodian. Client receives confirmations of each transaction in account from custodian and an additional statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest SVWA does not receive any economic benefits from external sources. Advisory Firm Payments for Client Referrals SVWA does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to carefully compare the account statements received directly from their custodians to any documentation or reports prepared by SVWA. SVWA is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of SVWA and due to Third-Party Standing Letters of Authorization (“SLOA”). SVWA and its qualified custodian meet the following seven (7) conditions in order to avoid maintaining full custody and be subject to the surprise exam requirement: 1. The Client provides an instruction to the qualified custodian, in writing, that includes the Client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The Client authorizes SVWA, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The Client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Client’s authorization and provides a transfer of funds notice to the Client promptly after each transfer. - 12 -  4. The Client has the ability to terminate or change the instruction to the Client’s qualified custodian. 5. SVWA has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the Client’s instruction. 6. SVWA maintains records showing that the third party is not a related party nor located at the same address as SVWA. 7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion Discretionary Authority for Trading When authorized with discretionary authority, SVWA will determine the securities to be bought or sold and the amount of the securities to be bought or sold, without obtaining specific Client consent. Client will authorize SVWA discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. If consent for discretion is not given, SVWA will obtain prior Client approval before executing each transaction. SVWA allows Clients to place restrictions on their discretionary authority, as outlined in the Client’s Investment Policy Statement or similar document. These restrictions must be provided to SVWA in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. SVWA does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes SVWA may assume authority to vote proxies for certain client accounts, depending on account type, custodian relationship, and client preference. As of  X date, when SVWA exercises proxy voting authority, it does so in partnership with Broadridge Financial Solutions, which provides proxy voting technology and due-diligence support. SVWA determines how proxies solicited by issuers of securities beneficially owned by clients will be voted in accordance with SVWA’s Proxy Voting Guidelines. A copy of these guidelines, referred to as the Shareholder Value Model, is available upon request. SVWA will instruct Custodian to direct all proxies and shareholder communications to Broadridge’s ProxyEdge voting platform. In coordination with Broadridge, SVWA monitors corporate actions of individual issuers and investment companies consistent with its fiduciary duty to act in clients’ best interests. Once SVWA assumes the authority to vote a client’s securities, the client will no longer have the option to direct individual vote decisions for specific solicitations. Clients may, however, contact SVWA at any time to obtain information about how their securities were voted. SVWA also recognizes that securities held in client accounts may at times be subject to class action lawsuits. Under SVWA  ’s agreement with Broadridge Financial Solutions, Broadridge - 13 -  conducts a comprehensive review of potential settlement claims, identifies open and eligible class action cases, and manages the filing, monitoring, and distribution of settlement proceeds in compliance with SEC guidelines. Clients who choose to opt out may notify SVWA; in such cases, SVWA and Broadridge will not monitor or file class action claims on that client’s behalf. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided to Clients because SVWA does not serve as a custodian for Client funds or securities and SVWA does not require prepayment of fees of more than $1200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients SVWA has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years SVWA has not had any bankruptcy petitions in the last ten years. - 14 -