SCULATI WEALTH MANAGEMENT, LLC

Form ADV Part 2A Narrative Brochure Sculati Wealth Management, LLC (CRD #: 158783) Address: 7457 Franklin Rd., Suite 222, Bloomfield Hills, MI 48301 Phone: (248) 325-9947 February 16, 2026 This Brochure provides information about the qualifications and business practices of Sculati Wealth Management. If you have any questions about the contents of this Brochure, please contact us at (248) 325-9947. 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. Sculati Wealth Management is a registered investment adviser. Registration as an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information from which you can determine whether to hire or retain an adviser.  Form ADV Part 2A 2026 Item 2. Material Changes This Brochure dated February 16, 2026, represents the annual amendment to the Brochure for Sculati Wealth Management. Since the filing of the annual update Brochure dated March 27, 2025, we updated detail about our brokerage practices and have made other minor updates but no other material changes were made. Pursuant to SEC Rules, we will deliver to you a summary of any material changes to this and subsequent Brochures within 120 days of the close of our fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. All such information will be provided to you free of charge. Currently, our Brochure may be requested by contacting us at (248) 325-9947. Additional information about the firm is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with the firm who are registered as investment adviser representatives of the firm. S c u l a t i W e a l t h M a n a g e m e n t Page i  Form ADV Part 2A 2026 Item 3. Table of Contents Item 2. Material Changes ............................................................................................... i Item 3. Table of Contents ............................................................................................ ii Item 4. Advisory Business ............................................................................................ 1 Item 5. Fees and Compensation .................................................................................. 3 Item 6. Performance-Based Fees and Side-By-Side Management .............................. 5 Item 7. Types of Clients ............................................................................................... 5 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ....................... 6 Item 9. Disciplinary Information .................................................................................. 8 Item 10. Other Financial Industry Activities and Affiliations .................................... 8 Item 12. Brokerage Practices ....................................................................................... 9 Item 13. Review of Accounts ..................................................................................... 11 Item 14. Client Referrals and Other Compensation ................................................. 12 Item 15. Custody ......................................................................................................... 12 Item 16. Investment Discretion ................................................................................. 13 Item 17. Voting Client Securities ............................................................................... 13 Item 18. Financial Information .................................................................................. 14 S c u l a t i W e a l t h M a n a g e m e n t Page ii  Form ADV Part 2A 2026 Item 4. Advisory Business Firm Description SWM was founded in 2011. SWM provides personalized and confidential financial planning and wealth management to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, and small businesses. Advice is provided through consultation with the client and may include determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance reviews, wealth management, education funding, retirement planning, and estate planning. SWM is a fee-only wealth management firm. For all fee-only accounts, financial planning is included at no cost to the client. For all prospective fee-only clients, financial planning is included at no cost to the prospect. It is SWM’s standard practice to furnish a financial plan for all current and prospective clients, unless the current or prospective client has opted to not complete the financial planning process. The completion of a financial plan is at the discretion of the current or prospective client, but it is highly encouraged by SWM. Investment advice is an integral part of financial planning. In addition, SWM advises clients regarding cash flow, college planning, retirement planning, tax planning and estate planning. Investment advice is provided, with SWM making the final decision on investment selection. SWM will provide general advice around cryptocurrencies and the risks associated with them but does not have the ability to invest client money in cryptocurrencies. SWM does not act as a custodian of client assets. The client always maintains asset control. SWM places trades for clients under a limited power of attorney. A written evaluation of each client's initial situation is provided to the client, often in the form of an Investment Policy Statement. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. The initial meeting, which may be by telephone, is free of charge and is considered an exploratory interview to determine the extent to which financial planning and wealth management may be beneficial to the client. SWM has 6 employees, 4 of which provide investment advisory functions. These 4 employees are registered with one or more state securities authorities as investment adviser representatives. S c u l a t i W e a l t h M a n a g e m e n t Page 1  Form ADV Part 2A 2026 Principal Owners David J. Sculati is the sole member of the LLC. Types of Advisory Services SWM provides investment supervisory services, also known as asset management services and furnishes investment advice through consultations. On more than an occasional basis, SWM furnishes advice to clients on matters not involving securities, such as financial planning matters; taxation issues; trust services that include estate planning, etc. Tailored Relationships The goals and objectives for each client are documented in our Investment Policy Statements for each client. Generally, these Investment Policy Statements are based around the Client’s financial plan. Clients may impose restrictions on investing in certain securities or types of securities. Because SWM is a registered investment adviser, we are required to meet certain fiduciary standards when providing investment advice to clients. Additionally, when we provide investment advice related to a retirement plan account or an individual retirement account, we are considered fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. As such, we are required to act in your best interest and not put our interest ahead of yours, even though our compensation creates some conflicts with your interests in that the more you have us manage, the more we can earn. Our clients, however, are under no obligation to use services recommended by our associated persons. Furthermore, we believe that our recommendations are in the best interests of our clients and are consistent with our clients’ needs. Wrap Fee Programs SWM does not participate in wrap fee programs. Separately managed accounts SWM offers Separately Managed Accounts (SMAs) through third-party managers. These SMAs consist of customized investment portfolios designed to meet clients' objectives and risk profiles. Clients have the option to allocate a portion or all of their investment assets to SMAs. While SWM does not directly manage the underlying investments in these SMAs, it acts as a discretionary advisor, providing guidance on asset allocation and financial planning. Importantly, we do not receive any compensation or fees for using or recommending these SMAs, and we have no affiliation with the providers. The fees associated with SMAs are determined by the providers themselves and are separate from our firm's fees. S c u l a t i W e a l t h M a n a g e m e n t Page 2  Form ADV Part 2A 2026 Assets Managed Client regulatory assets under management for SWM as of December 31, 2024 are as follows: Type of Management US Dollar Amount $381,475,086 Discretionary: Non-Discretionary: $0 Total: $381,475,086 Item 5. Fees and Compensation Description of Compensation SWM bases its fees on a percentage of assets under management for investment management. The asset amount on which the fee is calculated is the closing value of the last business day of the previous quarter. SWM uses the following fee schedule when generating bills: Breakpoints First $1 Million Next $1 Million Next $1 Million Above $3 Million All Assets 1.00% .80% .60% .40% The minimum household account size is $500,000 and the minimum annual fee is $5,000. Current client relationships may exist where the fees are higher or lower than the fee schedule above. Lower fees for comparable services may be available from other sources. Fee Deduction Fees are usually deducted from a designated client account to facilitate billing. Fee deduction authorization is generally provided to the custodian upon account opening. Payment in full is expected within 15 days of invoice presentation whether deducted from the client’s account or directly billed. Other Fees Custodians may charge transaction fees on purchases or sales of certain mutual funds and exchange- traded funds. These transaction charges are usually small and incidental to the purchase or sale of a security and are separate from SWM management fees. S c u l a t i W e a l t h M a n a g e m e n t Page 3  Form ADV Part 2A 2026 Mutual funds generally charge a management fee for their services as investment managers. The management fee is called an expense ratio. For example, an expense ratio of 0.50 means that the mutual fund company charges 0.5% annually for their services. These fees are in addition to the fees paid by you to SWM. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted. Clients will incur brokerage and other transaction costs. Payment in Advance SWM will invoice clients quarterly in advance (i.e. at the beginning of the service quarter.) The fee structure is applied each quarter to determine the amount billed to each client. SWM reserves the right to stop work on any account that is more than 30 days overdue. In addition, SWM reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in SWM’s judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded within 30 days of termination. If the relationship between Client and Advisor is terminated, Advisor’s management fees will be charged through the end of the month in which the termination occurred. Any unearned fees paid in advance will be refunded to the client on a pro-rata basis upon termination of the client’s investment advisory contract and either credited to Client’s account or mailed via check. New clients are not prorated an investment management fee. In other words, if a client opens an account in the middle of a billing period, they will not pay a fee until the next billing is assessed. For Example: 1. Client A has $500,000 in assets at SWM that are being managed. The client would pay a total amount (if assets stayed at $500,000) $5,000 for the year assessed and paid each quarter. In this scenario, Client A would pay $1,250 each quarter (1% divided by 4, multiplied by $500,000). 2. Client B is a new client to SWM with $500,000 in assets. At the end of the first quarter the assets amount to $500,000 for a bill totaling $1,250 (1.00% divided by 4, multiplied by $500,000). The next quarter, the client transferred $750,000 more assets to SWM. The client now has total assets of $1.25 Million at SWM. This quarter the fee assessed on the value of assets up to $1 Million was 1.00%, and the fee assessed on the value of assets over $1 Million was .80%. This amounts to a fee of $2,500 on the $1 Million (1.00% divided S c u l a t i W e a l t h M a n a g e m e n t Page 4  Form ADV Part 2A 2026 by 4, multiplied by $1 Million), and $500 (.80% divided by 4, multiplied by $250,000) on the $250,000. This client would have an effective fee of .24% for the quarter, or .96% annualized ($500 added to $2,500, divided by $1.25 Million). The total bill for this quarter was $3,000. Compensation for the Sale of Securities or Other Investment Products SWM does not accept compensation for the sale of securities or other investment products. 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. SWM does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. There is no side-by-side management of accounts at SWM, meaning no accounts have performance- based fees along with another type of fee. All fees are asset-based, as disclosed in the section labeled, “Fees and Compensation”. Item 7. Types of Clients Description SWM generally provides investment advice to individuals, high net worth individuals, trusts, estates, or charitable organizations, corporations, or business entities. Client relationships vary in scope and length of service. SWM has a minimum account size of $500,000 and this is negotiable. SWM does have a minimum annual fee of $5,000 and is negotiable. When this minimum annual fee results in a fee charge that is greater than 3%, this fee charge is reduced so that this fee charge will not exceed 3%. When an account falls below $500,000 in value, the minimum annual fee of $5,000 is charged unless this annual fee results in a fee charge that exceeds 3%. If the fee charge exceeds 3%, the annual fee is reduced so that this fee charge will not exceed 3%. S c u l a t i W e a l t h M a n a g e m e n t Page 5  Form ADV Part 2A 2026 SWM has the discretion to alter the account minimum. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. Definitions: Charting & Technical Analysis: Displaying several technical indicators of a single security on a “chart”. This allows comparisons of technical measures using different charting methods to analyze investments and performance. Security analysis focused around past trends, price and volume. This is sometimes referred to as supply and demand analysis. There are various statistical measures used to forecast a security’s future performance. Fundamental Analysis: Determining a security’s true value (sometimes called the intrinsic value) by focusing on factors that are measurable. This data is analyzed and compared against other securities as well as future prospects. This analysis is used to evaluate whether a security is overvalued or undervalued. Cyclical Analysis: Evaluation of the current economic cycle (sometimes referred to as the business cycle) to help determine proper valuations of companies. This is seen as a macro-economic analysis that helps identify opportunities/concerns in specific industries and furthermore specific companies. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Other sources of information that SWM may use include past and present articles found within Barron’s and The Wall Street Journal; Morningstar Adviser Workstation; Schwab Institutional; Charles Schwab & Company; Value Line; and the World Wide Web. Investment Strategies SWM will buy individual securities in most accounts but does invest client dollars in money market funds, no-load mutual funds or load funds that allow investment advisers to buy their shares at net asset value. These mutual funds are used to meet specific goals as outlined with the client in the Investment Policy Statement. Diversification in a smaller account will often make buying a mutual fund rather than individual securities necessary. S c u l a t i W e a l t h M a n a g e m e n t Page 6  Form ADV Part 2A 2026 Based around either the client’s Investment Policy Statement, the client’s Financial Plan, either, or both, SWM determines which securities and allocations are best fitted for the client. SWM does not utilize a method of analysis or strategy with significant or unusual risks. SWM does not use a strategy that involves frequent trading of securities. There are risks regarding the creation of an Investment Policy Statement or a Financial Plan for a client. The client may not provide adequate or accurate information. The client may not inform SWM around changes in their personal or financial life which would impact either the Investment Policy Statement or the Financial Plan. SWM primarily recommends the following securities (see section “Asset Management” for definitions) with the associated risks listed with them (see section “Risk of Loss” for definitions): Individual Stocks: Interest-rate risk, market risk, inflation risk, currency risk, business risk, liquidity risk, and financial risk Individual Bonds: Interest-rate risk, market risk, inflation risk, currency risk, reinvestment risk, business risk, liquidity risk, and financial risk Mutual Funds: Interest-rate risk, market risk, inflation risk, currency risk, business risk, liquidity risk, and financial risk Money Market Funds: Interest-rate risk, inflation risk, and currency risk Risk of Loss 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: • 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. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • 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. S c u l a t i W e a l t h M a n a g e m e n t Page 7  Form ADV Part 2A 2026 • 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. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • 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. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Item 9. Disciplinary Information Legal and Disciplinary The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Item 10. Other Financial Industry Activities and Affiliations Financial Industry Activities and Affiliations. SWM has no other industry activities or affiliations. Use of Other Investment Advisers SWM utilizes Separately Managed Accounts (SMAs) offered by Third-Party SMA Providers for client investment purposes. Although we use their SMAs as an option for our clients, there are no affiliations or compensation arrangements with the provider, and we do not receive any fees or financial incentives for recommending these services. A conflict of interest may exist, as SWM may have an incentive to recommend BlackRock SMAs if SWM receives indirect benefits, such as research or marketing support. S c u l a t i W e a l t h M a n a g e m e n t Page 8  Form ADV Part 2A 2026 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics SWM has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. The SWM Code of Ethics describes the firm's fiduciary duties and responsibilities to clients, and details practices for reviewing the personal securities transactions of supervised persons with access to client information. The Code also requires compliance with applicable securities laws, addresses insider trading, and details possible disciplinary measures for violations. SWM will provide a complete copy of its Code of Ethics to any client upon request to the Chief Compliance Officer. Trading Conflicts of Interest Individuals associated with SWM are permitted to buy or sell securities for their personal accounts identical to or different than those recommended to clients. However, no person employed by SWM is allowed to favor his or her own interest over that of a client or make personal investment decisions based on the investment decisions of advisory clients. In order to address potential conflicts of interest, SWM requires that associated persons with access to advisory recommendations provide annual securities holdings reports and quarterly transaction reports to the firm's Chief Compliance Officer. SWM also requires prior approval from the Chief Compliance Officer for investing in any IPOs or private placements (limited offerings). Item 12. Brokerage Practices The Custodian and Brokers We Use We do not maintain custody of client assets. Instead, we require all client assets be maintained in an account at a non affiliated “qualified custodian,” generally a broker-dealer or bank. We are not affiliated with any particular custodian but instead all custodians are independently owned and operated. The custodian will hold your assets in a brokerage account and will be able to buy and sell securities on your behalf. While we may recommend that you use a particular custodian/broker, you will ultimately decide whether to do so and will open your account with the custodian/broker by entering into an account agreement directly with one of them. We cannot actually open accounts for you, but we can assist you in opening an account at whatever custodian/broker you decide to use. How We Select Custodians and Brokers When recommending a custodian or broker for our clients, we consider many different factors including quality of service, types of services offered, overall capability, execution quality, competitiveness of transaction costs, availability of investment research, reputation of the firm, and S c u l a t i W e a l t h M a n a g e m e n t Page 9  Form ADV Part 2A 2026 financial resources, among other things. In determining the reasonableness of a broker’s compensation, we consider the overall cost to you relative to the benefits you receive, both directly and indirectly, from the broker. Your Brokerage and Custody Costs Our clients receive various services directly from our custodians. For our clients’ accounts that they maintain, the custodian generally does not charge separately for custody services but instead is compensated by charging commissions or other fees on trades that it executes or trades that are executed by other brokers to and from the custodial accounts. Fees applicable to our client accounts were negotiated based on the condition that our clients collectively maintain a certain level of assets at the custodian. We feel this commitment benefits you because we expect the overall rates you pay will be lower than they might be otherwise. Since custodians often charge clients a fee for each trade that we have executed by a different broker- dealer, we have the custodians execute most trades for your account in order to minimize your trading costs. We have determined that having the custodians execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means seeking the most favorable terms for a transaction based on all relevant factors, including those listed above. Products and Services Available to Us from Brokers/Custodians The custodians provide us and our clients with access to its institutional brokerage services like trading, custody, reporting, and related services, many of which are not typically available to retail customers. The custodians also make available various support services, some of which may help us manage or administer our clients’ accounts, while others may help us manage and grow our business. Other institutional brokerage services which benefit you directly include access to a broad range of investment products, execution of securities transactions, and asset custody. The investment products available through the custodians include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. The custodians may also make available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both the custodians’ own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at the custodians. In addition to investment research, the custodians may also make available software and other technology that provide access to client account data, facilitates trade execution for multiple client accounts, provides pricing and other market data, facilitates payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. S c u l a t i W e a l t h M a n a g e m e n t Page 10  Form ADV Part 2A 2026 The custodians may also offer other services intended to help us manage and further develop our business. These services include educational conferences and events, consulting on technology, compliance, legal, and business needs, publications and conferences on practice management and business succession, and access to employee benefits providers, human capital consultants, and insurance providers. The availability of these services from the custodians benefits us because we do not have to produce or purchase them. Of course, this may give us an incentive to recommend that you maintain your account with a particular custodian based on our interests rather than yours, which is a potential conflict of interest. We believe, however, that our recommendation of a custodian is in the best interests of our clients, and is primarily supported by the scope, quality, and price of the custodian’s services and not the custodian’s services that benefit only us. Aggregation of Transactions SWM may, from time to time, aggregate client orders into blocks in order to facilitate more efficient account management and execution. When aggregating orders, an average price is given to all participants in the block, or other measures are taken, in order to treat all accounts fairly. Item 13. Review of Accounts Periodic Reviews Account reviews are performed quarterly by advisers: President David J. Sculati; CFP® and Chief Compliance Officer, Nathan Hawrot; Michelle DiNardo and Alan Gildenberg. Account reviews are performed more frequently when market conditions dictate. Along with account reviews, financial plans are reviewed regularly when enacting trades in a client’s account. Financial plans are reviewed when clients have a major life event such as: retirement, death of spouse or relative, college costs, social security eligibility, pension eligibility, etc. These plans are reviewed and updated at this time with the relevant information. Financial plans that have not been updated within 3 to 5 years are also reviewed and a financial plan update is highly encouraged and the decision to update is at the client’s discretion. Review Triggers Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's own situation. Regular Reports Account reviewers are members of the firm's Investment Committee. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. S c u l a t i W e a l t h M a n a g e m e n t Page 11  Form ADV Part 2A 2026 Clients receive periodic communications on at least an annual basis. Investment Advisory/Management Agreement clients receive electronic or written quarterly updates. The electronic or written updates may include individual performance reports as well as an aggregate report for all the clients’ accounts. Annual ADV offer & Annual Privacy Policy are provided after Form ADV has been updated. Realized gain and loss report are sent electronically or written for the previous year and other reports are also available upon request. Item 14. Client Referrals and Other Compensation Incoming Referrals SWM will receive client referrals. The referrals that come from current clients will not result in client compensation. SWM does not have any arrangements with an outside person or entities that provides investment advice or other advisory services to clients that results in an economic benefit for SWM. SWM engages in solicitation agreements with licensed or designated professionals who refer clients to SWM. The compensation paid to these other professionals is from SWM. Clients will pay no more than if they had not been directly referred. Referrals Out SWM does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Other Compensation SWM does not receive any forms of other direct compensation. SWM does however receive economic benefits from our custodian in the form of the support products and services that are made available to us and to other independent investment advisors. These products and services, how they benefit us, and the related conflicts of interest are described in Item 12 above. The firm may also on limited occasions receive travel expense reimbursements for industry meetings related to market analysis, investment strategies, and practice management. The availability to us of these economic benefits is not based on us giving particular investment advice, such as buying or recommending particular securities for our clients. Furthermore, our representatives are required to make all investment decisions and recommendations based solely on the interests of the applicable client. Item 15. Custody Account Statements All assets are held at qualified custodians. This means the custodians provide account statements directly to clients at their address of record at least quarterly. S c u l a t i W e a l t h M a n a g e m e n t Page 12  Form ADV Part 2A 2026 Performance Reports Clients are urged to compare the account statements received directly from their custodians to the performance report statements provided by SWM. SWM does not provide SWM’s own account statement to Client. Advisory Fees SWM is considered by regulators to have limited custody of client assets because of its authority to make withdrawals from client accounts to pay its advisory fee, along with the authority to move money electronically for each client. Item 16. Investment Discretion Discretionary Authority for Trading SWM accepts discretionary authority to manage securities accounts on behalf of clients. SWM has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. Since all SWM clients give discretionary authority via the client’s account application and investment advisory agreement, SWM does not consult with the client before each trade to obtain concurrence if a blanket trading authorization has been given. The Client approves the custodian to be used. SWM negotiates the commission rates paid to the custodian. SWM does not receive any portion of the transaction fees or commissions paid by the Client to the custodian on certain trades. Discretionary trading authority facilitates placing trades in Client accounts on the behalf of clients so that SWM may promptly implement the investment policy that clients of SWM have approved in writing. Limited Power of Attorney A limited power of attorney is a trading authorization for this purpose. You sign a limited power of attorney so that we may execute the trades that you have approved. Item 17. Voting Client Securities Proxy Votes SWM does not vote proxies on behalf of its clients. It is the client's responsibility to ensure that they receive, review, and respond to any proxy materials they receive from the issuers of the securities in which they are invested If clients seek assistance with proxy voting, SWM may provide general information to clients about how to exercise their proxy voting rights, but the firm does not provide guidance or recommendations on how to vote proxies. S c u l a t i W e a l t h M a n a g e m e n t Page 13  Form ADV Part 2A 2026 Item 18. Financial Information Financial Condition Registered investment advisers are required in some cases to provide certain financial information and or disclosures about their financial condition. For example, if the firm requires prepayment of fees for six months in advance, has custody of client funds, or has a condition that is reasonably likely to impair its ability to meet it contractual commitments to its clients, it must provide financial information and make disclosures. SWM has no financial or operating conditions which trigger such additional reporting requirements. S c u l a t i W e a l t h M a n a g e m e n t Page 14