SIEBEN WEALTH PLANNING LLC

Item 1 – Cover Page Sieben Wealth Planning LLC Form ADV Part 2A – Disclosure Brochure Effective: February 24, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Sieben Wealth Planning LLC (“Sieben Wealth Planning” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at 612-720-4637 or by email at support@siebenwp.com. Sieben Wealth Planning is a registered investment advisor with U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Sieben Wealth Planning to assist you in determining whether to retain the Advisor. Additional information about Sieben Wealth Planning and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 315368. Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Sieben Wealth Planning. For convenience, the Advisor has combined these documents into a single disclosure document. Sieben Wealth Planning believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Sieben Wealth Planning encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes • There are no material changes. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 315368. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 612-720-4637 or by email at support@siebenwp.com. Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................. 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Services ........................................................................................................................... 5 A. Firm Information ................................................................................................................................. 5 B. Advisory Services Offered ................................................................................................................. 5 C. Client Account Management ............................................................................................................. 7 D. Wrap Fee Programs ........................................................................................................................... 7 E. Assets Under Management ............................................................................................................... 7 Item 5 – Fees and Compensation ................................................................................................................. 7 A. Fees for Advisory Services ............................................................................................................... 7 B. Fee Billing ........................................................................................................................................... 9 C. Other Fees and Expenses .................................................................................................................. 9 D. Advance Payment of Fees and Termination .................................................................................... 9 E. Compensation for Sales of Securities ............................................................................................ 10 Item 6 – Performance-Based Fees and Side-By-Side Management ......................................................... 10 Item 7 – Types of Clients ............................................................................................................................. 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 10 A. Methods of Analysis ......................................................................................................................... 10 B. Risk of Loss ...................................................................................................................................... 11 Item 9 – Disciplinary Information ................................................................................................................ 12 Item 10 – Other Financial Industry Activities and Affiliations ................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 12 A. Code of Ethics .................................................................................................................................. 12 B. Personal Trading with Material Interest .......................................................................................... 12 C. Personal Trading in Same Securities as Clients ............................................................................ 13 D. Personal Trading at Same Time as Client ...................................................................................... 13 Item 12 – Brokerage Practices .................................................................................................................... 13 A. Recommendation of Custodian[s] .................................................................................................. 13 B. Aggregating and Allocating Trades ................................................................................................ 14 Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 3  Item 13 – Review of Accounts .................................................................................................................... 14 A. Frequency of Reviews ...................................................................................................................... 14 B. Causes for Reviews ......................................................................................................................... 14 C. Review Reports ................................................................................................................................ 15 Item 14 – Client Referrals and Other Compensation ................................................................................. 15 A. Compensation Received by Sieben Wealth Planning ................................................................... 15 B. Compensation for Client Referrals ................................................................................................. 15 Item 15 – Custody ........................................................................................................................................ 15 Item 16 – Investment Discretion ................................................................................................................. 15 Item 17 – Voting Client Securities .............................................................................................................. 16 Item 18 – Financial Information .................................................................................................................. 16 Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 4  Item 4 – Advisory Services A. Firm Information Sieben Wealth Planning LLC (“Sieben Wealth Planning” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Minnesota. Sieben Wealth Planning was founded in August 2021 and became a registered investment advisor in September 2021. Sieben Wealth Planning is owned and operated by David M. Sieben (Principal and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Sieben Wealth Planning. B. Advisory Services Offered Sieben Wealth Planning offers advisory services to individuals, high net worth individuals, families, trusts, estates, businesses, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate conflicts of interest. Sieben Wealth Planning ’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Sieben Wealth Planning provides customized wealth management solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary wealth management and related advisory services. Sieben Wealth Planning works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to design a portfolio strategy. Sieben Wealth Planning will then construct an investment portfolio, consisting of exchange-traded funds (“ETFs”) and/or mutual funds to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, individual bonds, and other types of investments, as appropriate, to meet the needs of the Client. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. Sieben Wealth Planning will select, recommend and/or retain mutual funds on a fund-by-fund basis. Due to specific custodial and/or mutual fund company constraints, material tax consideration, and/or systematic investment plans, Sieben Wealth Planning will select, recommend and/or retain a mutual fund share classes that do not have trading costs when possible. These will in most cases be institutional share classes but, in some cases, may be share classes with higher internal expense ratios than institutional share classes. Sieben Wealth Planning will seek to select the lowest cost share class available that is in the best interest of each Client weighing the expected investment pattern, expense ratios and potential ticket charges, and will ensure the selection aligns with the Client’s financial objectives and stated investment guidelines. Sieben Wealth Planning ’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Sieben Wealth Planning will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Sieben Wealth Planning evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Sieben Wealth Planning may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Sieben Wealth Planning may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against the market movement. Sieben Wealth Planning may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 5  tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Use of Independent Managers – Sieben Wealth Planning may recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into a wealth management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Client’s investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services Sieben Wealth Planning will typically provide a variety of financial planning and consulting services to Clients. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Sieben Wealth Planning may also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For project-based or ad-hoc engagements, the Advisor may not provide a written summary. Project-based financial plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for wealth management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Sieben Wealth Planning provides non-discretionary retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 6  Investment Policy Statement (“IPS”) Design and Monitoring Investment monitoring and oversight • Vendor Analysis • Plan Participant Enrollment and Education Tracking • • • Performance Reporting • Ongoing Investment Recommendation and Assistance • ERISA 404(c) Assistance These services are provided by Sieben Wealth Planning serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Sieben Wealth Planning ’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Sieben Wealth Planning to provide advisory services, each Client is required to enter into a written advisory agreement with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Sieben Wealth Planning, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Sieben Wealth Planning will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client or unique client goal. • Portfolio Construction – Sieben Wealth Planning will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Wealth Management and Supervision – Sieben Wealth Planning will provide wealth management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Sieben Wealth Planning does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Sieben Wealth Planning. E. Assets Under Management As of December 31, 2025, Sieben Wealth Planning manages $161,196,874 in total Client assets on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written advisory agreement with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior calendar quarter. Wealth management fees are based on the following tiered fee schedules. Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 7  Assets Under Management ($) Up to $999,999* $1,000,000 to $2,999,999 $3,000,000 to $4,999,999 Over $5,000,000 Annual Rate (%) 1.00% 0.85% 0.75% 0.65% The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Advisor typically offers a tiered, incremental fee schedule (as detailed above) where the rate is reduced as assets under management increase. In certain circumstances, the Advisor may charge a fixed annual rate or fixed fee for its services. The Client’s fees will take into consideration the aggregate assets under management with the Advisor across all accounts, unless otherwise agreed in writing. All securities held in accounts managed by Sieben Wealth Planning will be independently valued by the Custodian. Sieben Wealth Planning will not have the authority or responsibility to value portfolio securities. Clients may make additions to and withdrawals from their account[s] at any time, subject to Sieben Wealth Planning’s right to terminate an account. Additions may be in cash or securities provided that Sieben Wealth Planning reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw account assets on notice to Sieben Wealth Planning, subject to the usual and customary securities settlement procedures. However, Sieben Wealth Planning designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client’s investment objectives. Sieben Wealth Planning may consult with its Clients about the options and ramifications of transferring securities. However, Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its wealth management fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. When Independent managers are utilized, clients will execute a separate agreement with each independent manager, which allows such managers to calculate and collect fees directly from client accounts. The terms of fee arrangements between the client and Independent Managers are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee ranging from 0.25% to 1.00% based on the size of the Plan and scope of services to be provided. Fees are typically billed in advance of each calendar quarter, pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under management in the Plan at the end of the prior calendar quarter. Fees may be negotiable depending on the size and complexity of the Plan. Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 8  B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] in advance of each calendar quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the market value of assets under management as of the end of the prior calendar quarter. Clients will be provided with a statement, generally monthly, from the Custodian reflecting the deduction of the wealth management fee. Clients provide written authorization permitting advisory fees to be deducted by Sieben Wealth Planning to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. For Client accounts implemented through an Independent Manager, the Client’s overall fees do not typically include Sieben Wealth Planning ’s wealth management fee. In certain instances, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. In other instances the Advisor and the Independent Manager will each assume the responsibility for calculating and deducting their respective fees from the Client’s account[s]. Aggregate fees charged by SWP and Independent Managers may exceed 2% of Assets Under Management. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Sieben Wealth Planning, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Sieben Wealth Planning are separate and distinct from these custody and execution fees. In addition, all fees paid to Sieben Wealth Planning for wealth management services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Sieben Wealth Planning but would not receive the services provided by Sieben Wealth Planning which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Sieben Wealth Planning to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. Additionally, as noted above, the Advisor will select share classes that do not have trading costs when possible. These will in most cases be institutional share classes but in some cases may be share classes with higher internal expense ratios than institutional share classes. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services Sieben Wealth Planning is compensated for its wealth management services in advance of the quarter in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid fees from the effective date of termination through the end of the quarter. The Client’s wealth management agreement with the Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 9  Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest or a Client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the Client or the Advisor and the Independent Manager. Sieben Wealth Planning will assist the Client with the termination and transition as appropriate. Retirement Plan Advisory Services Sieben Wealth Planning is compensated for its services at the beginning of the quarter before advisory services are rendered. Either party may request to terminate a retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for advisory fees up to and including the effective date of termination. Upon termination, the Advisor will refund any unearned, prepaid advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Sieben Wealth Planning does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the wealth management fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Sieben Wealth Planning does not charge performance-based fees for its wealth management services. The fees charged by Sieben Wealth Planning are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Sieben Wealth Planning does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Sieben Wealth Planning offers advisory services to individuals, high net worth individuals, families, trusts, estates, businesses, and retirement plans. Sieben Wealth Planning generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Sieben Wealth Planning primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Sieben Wealth Planning are derived from numerous sources, including financial media companies, third-party research materials, professional data subscriptions, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria generally consists of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 10  Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Sieben Wealth Planning will be able to predict such a reoccurrence accurately. As noted above, Sieben Wealth Planning generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Sieben Wealth Planning will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Sieben Wealth Planning may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Sieben Wealth Planning will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general risks of investing. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals, or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond ETF Risks Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 11  prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bonds time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investors rate of return, (4) credit default risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory, or disciplinary events involving Sieben Wealth Planning or its management persons. Sieben Wealth Planning values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 315368. Item 10 – Other Financial Industry Activities and Affiliations Except as noted below, Sieben Wealth Planning does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more Independent Managers. The Advisor does not receive any compensation, nor does this present a material conflict of interest. The Advisor will only earn its wealth management fee as described in Item 5.A. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Sieben Wealth Planning has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Sieben Wealth Planning (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. Sieben Wealth Planning and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Sieben Wealth Planning’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at 612-720-4637. B. Personal Trading with Material Interest Sieben Wealth Planning allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Sieben Wealth Planning does not act as a principal in any Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 12  transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. Sieben Wealth Planning does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Sieben Wealth Planning allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Sieben Wealth Planning requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Sieben Wealth Planning allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will Sieben Wealth Planning, or any Supervised Person of Sieben Wealth Planning, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Sieben Wealth Planning does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Sieben Wealth Planning to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, Sieben Wealth Planning does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Sieben Wealth Planning does not exercise discretion over the selection of the Custodian, it may recommend the Custodian[s] to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Sieben Wealth Planning. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Sieben Wealth Planning may recommend the Custodian based on criteria such as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Sieben Wealth Planning will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial Services LLC, and Fidelity Brokerage Services LLC (collectively “Fidelity”), a FINRA-registered broker-dealer and member SIPC. Fidelity will serve as the Client’s “qualified custodian.” Sieben Wealth Planning maintains an institutional relationship with Fidelity, whereby the Advisor receives economic benefits from Fidelity. Sieben Wealth Planning has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The Fidelity platform includes brokerage, custody, administrative support, record keeping, technology and related services designed to support registered investment advisors like Sieben Wealth Planning in serving Clients. These services are intended to serve the best interests of the Advisor’s Clients. Fidelity may charge brokerage commissions (securities transaction fees) for effecting certain securities transactions. Fidelity enables the Advisor to obtain certain no-load mutual funds without securities transaction fees and other no-load funds at nominal transaction charges. Fidelity’s commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 13  Fidelity may be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14 below for additional information. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Sieben Wealth Planning does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Sieben Wealth Planning does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis,” where Sieben Wealth Planning will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Sieben Wealth Planning will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. A Client may pay a commission that is higher than another qualified custodian might charge to effect the same transaction. The Advisor has determined in good faith that the commissions charged by Fidelity are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not necessarily the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Custodian’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although the Advisor will seek competitive rates, to the benefit of all Clients, it may not necessarily obtain the lowest possible commission rates for specific Client account transactions. Although the investment research products and services that may be obtained by the Advisor will generally be used to service all of the Advisor’s Clients, they may not equally benefit all Clients. Please also see Item 14. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Sieben Wealth Planning will execute its transactions through the Custodian as authorized by the Client. Sieben Wealth Planning may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Mr. Sieben. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 14  deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Sieben Wealth Planning if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic, or political events. C. Review Reports The Client will receive brokerage statements generally monthly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Sieben Wealth Planning Sieben Wealth Planning is a fee-based advisory firm that is compensated solely by its Clients and not from any investment product. Sieben Wealth Planning does not receive commissions or other compensation from product sponsors, broker-dealers or any unrelated third party. Sieben Wealth Planning may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Sieben Wealth Planning may receive non- compensated referrals of new Clients from various third parties. Participation in Institutional Advisor Platform As noted in item 12, Sieben Wealth Planning has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders wealth management services to Clients that maintain assets at Fidelity The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. B. Compensation for Client Referrals Sieben Wealth Planning does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody All Clients must place their assets with a “qualified custodian.” Clients are required to engage the Custodian to retain their funds and securities and direct Sieben Wealth Planning to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Sieben Wealth Planning to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Item 16 – Investment Discretion Sieben Wealth Planning LLC 200 Southdale Center, Edina, MN 55435 Phone: 612-720-4637 | https://www.siebenwp.com Page 15  Sieben Wealth Planning generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Sieben Wealth Planning. The discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by Sieben Wealth Planning will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Sieben Wealth Planning does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies. However, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Sieben Wealth Planning, nor its management, have any adverse financial situations that would reasonably impair the ability of Sieben Wealth Planning to meet all obligations to its Clients. Neither Sieben Wealth Planning, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Sieben Wealth Planning is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. 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