SIGNIFICANT WEALTH PARTNERS LLC

Significant Wealth Partners, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Significant Wealth Partners, LLC (the “Advisor” or “Firm”). If you have any questions about the contents of this brochure, please contact us at (847) 639-7830 or by email at brian@swp360.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. The Advisor is a registered investment advisor. Registration of an Investment Advisor does not imply any level of skill or training. The oral and written communications of an Advisor provide you with information to assist you when determining to hire or retain an advisor. Additional information about Significant Wealth Partners, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Significant Wealth Partners, LLC’s CRD number is: 293060. 117 W. Main St. Cary, IL 60013 (847) 639-7830 brian@swp360.com https://www.mysignificantwealth.com Registration does not imply a certain level of skill or training. Version Date: 04/28/2025 i  Item 2: Material Changes Initially, we will provide you with this brochure which highlights information about our qualifications, business practices, and potential conflicts of interest. Thereafter, on an annual basis, if there have been any material changes to the information in the brochure during the previous year, we will provide you with one of the following: • An updated annual brochure along with a summary of material changes which will be provided within 120 days of the close of our business fiscal year. Our business fiscal year-end is December 31st. • A summary of material changes within 120 days of the close of our business fiscal year-end that includes an offer to provide a copy of the full annual updated brochure and information on how you may obtain the brochure from us. Throughout any calendar year, we will also provide you with an updated interim amendment to our brochure under the following circumstances: • We report any new information in response to Item 9 of Part 2A regarding disciplinary information about the Firm or any of its management personnel. • Any material change that could affect the relationship between you and us. We will provide, free of charge, a new brochure any time at your request, or as may become necessary based on material changes as outlined above. You may request our brochure by contacting us at (847) 639-7830. You may also receive this and any other disclosure documents via electronic delivery, where allowed, by signing and returning to us an authorization to deliver disclosure and other documents electronically. This authorization may be included in any agreement you enter into with the Firm. Additional information about the Firm is also available via the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with the Firm who are registered, or are required to be registered, as investment adviser representatives of the Firm. 1. Item #4B – Types of Advisory Services – This section was amended to remove the selection of other advisors as a service offered by SWPL. SWPL may recommend third-party investments; however, SWPL no longer selects other third-party advisors or managers to manage client assets. 2. Item #5A – Fee Schedule was updated to reflect the Advisor’s amended fee schedule. This includes removing the fee schedules for third-party advisors, as previously mentioned, SWPL no longer utilizes the third-party advisors. Under the Financial Planning Fees section of Item #5A, the use of hourly fees for financial planning was removed, as that is no longer applicable. 3. Item #8C – Risks of Specific Securities Utilized, specifically Annuities, was amended to further defined both fixed and variable annuities, and to better tailor the definitions and explanation of SWPL’s use of such annuities. ii  4. Item #12 – Brokerage Practices, specifically the Research and Other Soft-Dollar Benefits section, was updated to clarify SWPL’s policy and practice regarding the use of soft dollars. SWPL does not maintain any third-party soft dollar arrangements or agreements with any broker-dealer. 5. Item #14B – Compensation to Non-Advisory Personnel for Client Referrals, was updated to more accurately reflect SWPL’s practices and to cite the correct rule, which is the Marketing Rule as set forth under 206(4)-1 under the Investment Advisers Act of 1940. iii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iv Item 4: Advisory Business ......................................................................................................................................7 A. Description of the Advisory Firm ................................................................................................................7 B. Types of Advisory Services ...........................................................................................................................7 Financial Planning ...........................................................................................................................................8 Educational Seminars/Workshops ...............................................................................................................8 Written Acknowledgement of Fiduciary Status ..........................................................................................9 C. Client Tailored Services and Client Imposed Restrictions ........................................................................9 D. Wrap Fee Programs ........................................................................................................................................9 E. Assets Under Management .......................................................................................................................... 10 Item 5: Fees and Compensation ........................................................................................................................... 10 A. Fee Schedule .................................................................................................................................................. 10 Financial Planning Fees ................................................................................................................................ 10 Educational Seminars/Workshops ............................................................................................................. 11 Investments in Our Affiliated Firm’s Sub-Advised ETF .......................................................................... 11 B. Payment of Fees ............................................................................................................................................. 11 Payment of Financial Planning Fees ........................................................................................................... 11 C. Fees Charged by Financial Institutions ..................................................................................................... 12 D. Fees for Management for Partial Periods of Service ................................................................................ 12 E. Outside Compensation for the Sale of Securities to Clients .................................................................... 12 Item 6: Performance-Based Fees and Side-By-Side Management .................................................................. 13 Item 7: Types of Clients ........................................................................................................................................ 13 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ............................................................. 13 A. Methods of Analysis and Investment Strategies ................................................................................ 13 B. Material Risks Involved ......................................................................................................................... 14 C. Risks of Specific Securities Utilized ...................................................................................................... 15 Item 9: Disciplinary Information ......................................................................................................................... 18 iv  A. Criminal or Civil Actions ....................................................................................................................... 18 B. Administrative Proceedings .................................................................................................................. 18 C. Self-regulatory Organization (SRO) Proceedings ............................................................................... 18 Item 10: Other Financial Industry Activities and Affiliations ......................................................................... 18 A. Registration as a Broker/Dealer or Broker/Dealer Representative ................................................ 18 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity B. Trading Advisor ................................................................................................................................................ 18 Registration Relationships Material to this Advisory Business and Possible Conflicts of C. Interests ............................................................................................................................................................... 18 D. Selection of Alternative Outside Investments and Compensation for Those Selections .............. 20 E. Affiliated Advisors and Affiliated Funds ............................................................................................ 20 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 21 A. Code of Ethics .......................................................................................................................................... 21 B. Recommendations Involving Material Financial Interests ............................................................... 22 C. Investing Personal Money in the Same Securities as Clients ............................................................ 22 D. Trading Securities At/Around the Same Time as Clients’ Securities ............................................. 22 Item 12: Brokerage Practices ................................................................................................................................ 23 A. Factors Used to Select Custodians and/or Broker/Dealers ............................................................. 23 1. Research and Other Soft-Dollar Benefits .......................................................................................... 23 2. Brokerage for Client Referrals ........................................................................................................... 23 3. Clients Directing Which Broker/Dealer/Custodian to Use .......................................................... 23 B. Aggregating (Block) Trading for Multiple Client Accounts ............................................................. 23 Item 13: Review of Accounts ................................................................................................................................ 24 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews .............................. 24 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts............................................ 24 C. Content and Frequency of Regular Reports Provided to Clients ..................................................... 24 Item 14: Client Referrals and Other Compensation .......................................................................................... 24 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales A. Awards or Other Prizes) ................................................................................................................................... 24 B. Compensation to Non–Advisory Personnel for Client Referrals ..................................................... 25 Item 15: Custody .................................................................................................................................................... 26 Item 16: Investment Discretion ............................................................................................................................ 26 v  Item 17: Voting Client Securities (Proxy Voting) .............................................................................................. 27 Item 18: Financial Information ............................................................................................................................. 27 vi  Item 4: Advisory Business A. Description of the Advisory Firm Significant Wealth Partners, LLC (hereinafter “SWPL”) is a Limited Liability Company organized in the State of Illinois. The firm was formed in January 2018, and the principal owners are Brian William Atkins and Stephen Richard Smith. B. Types of Advisory Services Portfolio Management Services SWPL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SWPL creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring SWPL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SWPL will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. SWPL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SWPL’s economic, investment or other financial interests. To meet its fiduciary obligations, SWPL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SWPL’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is SWPL’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. SWPL may recommend a third-party investment for clients. If a client wishes to pursue a third-party investment, SWPL will refer the client to the third-party and the investment may be made directly with the third-party or allocated through a separately managed account managed by SWPL. SWPL may receive compensation for such recommendation 7  and investment from the third-party. The compensation received by SWPL from the third- party, pursuant to a fee sharing agreement or other compensation agreement with the third-party, is not related to and does not impact the fees charged to the client and the client account(s). SWPL may also allocate among one or more private equity funds or private equity fund advisers. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; education planning; debt/credit planning and profit sharing. Investment planning involves working with clients to make sure their investments match their respective risk tolerance and goals. Tax concerns are addressed by working with the client to determine and compare effective tax rates for income, capital gains and other earnings or investments, then attempting to allocate the client’s resources accordingly. Life insurance planning entails reviewing the life insurance and/or disability insurance needs of the client, together with any applicable dependents, spouse or other relatives, and assessing appropriate coverage for these individuals. College planning entails helping clients save for higher education, whether for the client or his/her children or other dependents, in the ideal manner to suit the client’s overall financial goals and means. Financial planning to address retirement entails making sure clients are financially equipped for retirement in light of the client’s anticipated income and expenses, investments, and other assets. Debt/credit planning consists of breaking down client budgets and aiding clients in decision-making as to current debt, anticipated significant expenses and potential debt, and avoiding excessive debt. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client if the client is charged for the financial planning services provided by SWPL in addition to any investment management services already provided to the client. However, unless the client is only receiving financial planning services, the client will generally not be charged for such financial planning services, as those services are provided in conjunction with SWPL’s portfolio management services. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. Educational Seminars/Workshops SWPL provides periodic educational seminars and workshops to prospective clients. Services Limited to Specific Types of Investments SWPL generally limits its investment advice to mutual funds, ETFs (including ETFs in the gold and precious metal sectors), fixed income securities, real estate funds, insurance products including annuities, equities, hedge funds, private equity funds, treasury inflation protected/inflation linked bonds, private placements, and the TrueShares Active 8  Yield ETF, which is an ETF sub-advised by an affiliated advisor, Wealth Builder Funds, LLC. SWPL may use other securities as well to help diversify a portfolio when applicable. Brian is also principle owner of Atkins & Associates, LLC and any recommendations made to clients regarding insurance products will be offered by Mr. Atkins and any commissions paid for those services and products are made to Atkins & Associates, LLC. Please see item 10.C for more detail. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions SWPL offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SWPL from properly servicing the client account, or if the restrictions would require SWPL to deviate from its standard suite of services, SWPL reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. SWPL does not currently, and has no plans to participate in any wrap fee programs. 9  E. Assets Under Management SWPL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 0.00 March 2025 $ 247,984,227.00 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $1,000,000 1.00% $1,000,001 - And Up 0.75% Fees are based on a straight tier schedule. Lower fees for comparable services may be available from other sources. SWPL uses the value of the account as of the last business day of the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of SWPL's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. SWPL may direct clients to third-party investment advisers. SWPL will be compensated via a fee share from the advisers to which it directs those clients. The fees shared are negotiable and will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. Financial Planning Fees Fixed Fees The fixed rate for creating client financial plans is up to 1.00% of the plan assets. 10  The fees are negotiable, and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. This fixed rate for financial planning is for standalone financial planning, and may not apply for those clients that are receiving both financial planning and portfolio management services. Educational Seminars/Workshops Educational seminars and workshops are offered free of charge. Investments in Our Affiliated Firm’s Sub-Advised ETF As a part of your investment strategy, we may use the ETF sub-advised by an affiliate of SWPL’s. The name of the affiliate is Wealth Builder Funds, LLC (“Wealth Builder Funds”, “WBF”, our “Affiliated Firm”, or our “Affiliate”), an SEC registered investment advisor. Wealth Builder Funds acts as the sub-advisor to the TrueShares Active Yield ETF (“Affiliated ETF”), as mentioned in Item 4. When the Affiliated ETF is used as part of your investment strategy, our Affiliate will receive a management fee that is described in the fund’s prospectus. This fee will be paid to our Affiliate in accordance with the fund’s prospectus and the Affiliated Firm’s specific investment advisory agreement with the Affiliated ETF. In addition, when invested in the Affiliated ETF, you will indirectly bear your pro rata share of the fees, expenses, and charges described in the fund’s prospectus. Such fees, expenses, and charges may include, but are not limited to, investment management fees, shareholder service fees, fees incurred for legal, audit, and custodial services provided to the Affiliate ETF, and the cost of transactions effected for the Affiliated ETF such as brokerage and execution charges, markups, and commissions. In addition to the fee you pay us as a part of your advisory agreement with SWPL, which will generally be based on the amount of assets in your account(s) that we manage on your behalf (or the otherwise enumerated methods listed above), including our Affiliated ETF, you will incur the expenses of the Affiliated ETF, including a separate investment management fee, which will be deducted directly from the account balance of the Affiliated ETF. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in arrears. Payment of Financial Planning Fees 11  Fixed Financial Planning fees are paid via check, cash, or wire. These fees are either charged in arrears upon completion or in advance, but never more than six months in advance. C. Fees Charged by Financial Institutions As further discussed in response to Item 12 (below), SWPL will generally utilize Charles Schwab (“Schwab”) with respect to broker and custodian services for the Firm. SWPL may only implement its investment management strategy after the client has arranged for and furnished SWPL with all information and authorization regarding accounts it establishes with the broker and custodian (“Financial Institutions”). Clients may incur certain charges imposed by the Financial Institutions and other third parties such as custodial fees, charges imposed directly by a mutual fund or ETF in the account, which are disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Additionally, for assets outside of any wrap fee programs, clients may incur brokerage commissions and transaction fees. Such charges, fees and commissions are exclusive of and in addition to SWPL’s fee. SWPL’s Agreement and the separate agreement with any Financial Institution may authorize the Financial Institution to debit your account for the amount of SWPL’s fee and to directly remit that management fee to SWPL. The Financial Institution has agreed to send a statement to the client, at least quarterly, identifying all amounts disbursed from the account including the amount of management fees paid directly to SWPL. Alternatively, clients may elect to have SWPL send an invoice for payment. D. Fees for Management for Partial Periods of Service For all asset-based fees paid in advance, the refunded fee will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. *The daily rate is calculated by dividing the annual asset-based fee by 365. E. Outside Compensation for the Sale of Securities to Clients Certain representatives of the firm in their outside business activities (see Item 10 below for more details) are licensed to accept compensation for the sale of investment products to SWPL clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of securities or investment products for which the supervised persons receive compensation, SWPL will document the conflict of interest in the client file and inform the client of the conflict of interest. Clients always 12  have the right to decide whether to purchase SWPL recommended products and, if purchasing, have the right to purchase those products through other brokers or agents that are not affiliated with SWPL. Commissions are not SWPL’s primary source of compensation for advisory services. Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. As discussed in more detail in Item 10 below, the commissions received by SWPL are only related to the sale of fixed annuities or insurance products. SWPL does not receive commissions on other securities or investment products, and under no circumstances does SWPL receive 12b-1 fees. Item 6: Performance-Based Fees and Side-By-Side Management SWPL does not accept performance-based fees or other fees based on a share of capital gains or on capital appreciation of the assets of a client. Item 7: Types of Clients SWPL generally provides advisory services to the following types of clients: Individuals High-Net-Worth Individuals ❖ ❖ There is no account minimum for any of SWPL’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis SWPL’s methods of analysis include Charting analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. SWPL uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. 13  Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies SWPL uses long term trading and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, 14  the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Investment Strategies SWPL's use of options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Selection of Other Advisers: Although SWPL will seek to select only money managers who will invest clients' assets with the highest level of integrity, SWPL's selection process cannot ensure that money managers will perform as desired and SWPL will have no control over the day-to-day operations of any of its selected money managers. SWPL would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulatory breaches or fraud. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized SWPL's use of options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment 15  returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are long-term financial products issued by insurance companies that are primarily used for retirement planning and income generation. They are contracts between you and an insurance company that require the insurer to make payments to 16  you, either immediately or in the future. You buy an annuity by making either a single lump-sum payment or a series of payments. This is in exchange for future income, either for a specified period or for the rest of your life. An annuity is not a life insurance policy. Fixed annuities, which are the type of annuity offered through our insurance-licensed representatives, provide a guaranteed rate of return and predictable income, making them appealing to risk-averse investors seeking stability. The guarantees are backed by the financial strength and claims-paying ability of the issuing insurance company and are not insured by the FDIC or any federal government agency. Unlike variable annuities, which are regulated by the SEC, involve investment risks similar to mutual funds, and may be subject to market volatility, the rate of return on your investments, and expenses, fixed annuities do not fluctuate in value based on market performance. However, fixed annuities still carry certain risks, such as inflation risk (the potential that fixed payments may lose purchasing power over time), liquidity risk (penalties and surrender charges for early withdrawal), and issuer risk (reliance on the solvency of the insurance company). As referenced in Item 10 – Other Financial Industry Activities and Affiliations, certain SWPL employees are licensed insurance agents who may recommend fixed annuity products when appropriate to help clients address specific income needs or risk management objectives. These individuals only sell insurance products and fixed annuities and do not sell variable annuities. Hedge funds often engage in leveraging and other speculative investment practices that may increase the risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; May involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. 17  Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither SWPL nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Brian William Atkins and Stephen Richard Smith are associated persons at Wiens Walk (commodity). C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Brian William Atkins is 100% owner of Atkins & Associates, LLC. Atkins & Associates is the general partner of one exempt hedge fund; Global Currency Reserve, LP; a fund of funds. Significant Wealth Partners, LLC does not manage Global Currency Reserve, LP. From time to time, he may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. SWPL always acts in the best interest of the client and clients always have the right to decide whether or not to utilize the services of any SWPL representative in such individuals outside capacities. 18  Brian William Atkins operates as a commodity pool for Global Currency Reserve, LP.; a fund of funds. From time to time, he may offer clients advice or products from those activities. SWPL always acts in the best interest of the client. Clients are in no way required to utilize the services of any representative of SWPL in their capacity as a futures commission merchant, commodity pool operator, or commodity trading adviser. Brian William Atkins is a licensed insurance agent. From time to time, he will offer clients advice or products from this activity. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. SWPL always acts in the best interest of the client; including in the sale of commissionable products to advisory clients. The commissions earned by Mr. Atkins are paid to Atkins & Associates, LLC. This is the only role Atkins & Associates, LLC plays in any insurance business that Mr. Atkins conducts. Clients are in no way required to implement the plan through any representative of SWPL in their capacity as a licensed insurance agent. Stephen Richard Smith is an independent licensed insurance agent, and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. SWPL always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of SWPL in connection with such individual's activities outside of SWPL. Scott Robert Smith does insurance and fixed annuity sales. From time to time, he may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. SWPL always acts in the best interest of the client and clients always have the right to decide whether or not to utilize the services of any representative of SWPL in such individuals outside capacities. Alayna Leuze and David Christopher Leuze are licensed insurance agents. These activities create a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of SWPL are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. SWPL addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. SWPL periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. SWPL will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any 19  insurance product. Insurance products recommended by SWPL’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. Joshua Lynn Lang is a licensed insurance agent. From time to time, he will offer clients advice or products from this activity. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. SWPL always acts in the best interest of the client; including in the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of SWPL in their capacity as a licensed insurance agent. All material conflicts of interest under California Code of Regulations Section 260.238(k) are disclosed regarding the investment adviser, its representatives or any of its employees, which could be reasonable expected to impair the rendering of unbiased and objective advice. D. Selection of Alternative Outside Investments and Compensation for Those Selections SWPL may direct clients to alternative outside investments. SWPL will be compensated via a fee share from the third-party to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. This creates a conflict of interest in that SWPL has an incentive to direct clients to the third-party for the client’s direct investment with that third-party as SWPL has entered into a fee sharing agreement or other compensation arrangement with said third-party. SWPL will always act in the best interests of the client, including when determining which third-party investment to recommend to clients. E. Affiliated Advisors and Affiliated Funds At no time is your advisory agreement to work with our Firm conditioned upon using the Affiliated ETF. While we feel we understand this fund well and believe it can be an integral part of your investment strategy, you are free to decide against utilizing the Affiliated ETF or any other investments we may recommend for your portfolio. We also reserve the right to not accept working with you both at the beginning of our potential relationship and at any other point in our relationship if we feel we cannot implement the strategy we recommend due to restrictions you may require or subsequently impose. Wealth Builder Funds, LLC, is an affiliated advisor of SWPL through common control and ownership. As discussed in Item 4 and Item 5, Wealth Builder Funds acts as the sub- advisor to one ETF, the TrueShares Active Yield ETF. A potential conflict of interest exists when we invest your assets into a proprietary fund of an affiliate in that our affiliate will receive a fee on those same assets as described in the Affiliated ETF’s prospectus. Specifically, the use of the Affiliated ETF will result in you paying investment 20  management fees to both SWPL and Wealth Builder Funds. Because we receive both the fees you pay SWPL and the fees you pay our Affiliate for investing in the Affiliated ETF it sub-advises, you should understand that we have an incentive to utilize the Affiliated ETF as part of your overall investment strategy. As previously mentioned, the fees associated with the investment in the Affiliated ETF will be paid to our Affiliate in accordance with the fund’s prospectus and the Affiliated Firm’s specific investment advisory agreement with the Affiliated ETF. In addition, when invested in the Affiliated ETF, you will indirectly bear your pro rata share of the fees, expenses, and charges described in the fund’s prospectus. Such fees, expenses, and charges may include, but are not limited to, investment management fees, shareholder service fees, fees incurred for legal, audit, and custodial services provided to the Affiliate ETF, and the cost of transactions effected for the Affiliated ETF such as brokerage and execution charges, markups, and commissions. In the future, if other conflicts were to arise regarding our current, or any new financial industry activities or affiliations, including the receipt of compensation from those sources, other than as already disclosed in this document, we would: • Disclose in this section the existence of those material conflicts of interest, including the potential for SWPL and our employees to earn compensation in addition to SWPL’s stated advisory fees; • Disclose to you, as we have done in this section, that you are not obligated to purchase recommended investment products from our employees or affiliated companies; • Require that our employees seek prior approval of any outside employment activity, other than has already been outlined herein, so that we may ensure that any conflicts of interest in such activities are properly addressed; and • Periodically monitor outside employment activities, other than those already identified herein, of our employees to verify that any conflicts of interest continue to be properly addressed by our firm. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics SWPL has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. SWPL's Code of Ethics is available free upon request to any client or prospective client. 21  B. Recommendations Involving Material Financial Interests SWPL and its associated persons may have material financial interests in issuers of securities that SWPL may recommend for purchase or sale by clients. For example: Brian William Atkins is 100% owner of Atkins & Associates, LLC. Atkins & Associates in the general partner of one exempt hedge fund; Global Currency Reserve, LP; a fund of funds. Significant Wealth Partners, LLC does not manage Global Currency Reserve, LP. However, SWPL will recommend investments in these private funds to those clients for which investment in the fund is suitable. Also, related persons of SWPL may invest in the funds personally while also recommending clients invest in the funds. This presents a conflict of interest in that SWPL or its related persons may receive more compensation from investment in a security in which SWPL or a related person has a material financial interest than from other investments. Client approval will be sought for client investment in such recommendations and, if granted, such approval will be binding. SWPL always acts in the best interest of the client consistent with its fiduciary duties and clients are not required invest in such investments if they do not wish to do so. Additionally, all Access Persons are required to request and obtain pre-approval for any prospective transaction in the Affiliated ETF. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of SWPL may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of SWPL to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. SWPL will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of SWPL may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of SWPL to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, SWPL will never engage in trading that operates to the client’s disadvantage if representatives of SWPL buy or sell securities at or around the same time as clients. 22  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers the market expertise and research access provided by Custodians/broker-dealers will be recommended based on SWPL’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and SWPL may also consider the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in SWPL's research efforts. SWPL will never charge a premium or commission on transactions beyond the actual cost imposed by the broker- dealer/custodian. SWPL will require clients to use Charles Schwab & Co., Inc. Advisor Services. 1. Research and Other Soft-Dollar Benefits SWPL does not maintain any third-party soft dollar arrangements or agreements with any broker-dealer. However, we may receive research and services from the broker- dealers utilized by SWPL, that, while not covered in a soft dollar agreement, nonetheless may be a benefit to our Firm. 2. Brokerage for Client Referrals SWPL receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use SWPL will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If SWPL buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, SWPL would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. SWPL would determine the 23  appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for SWPL's advisory services provided on an ongoing basis are reviewed at least Quarterly by Brian Atkins, Owner, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at SWPL are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of SWPL's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Charles Schwab & Co., Inc. Advisor Services provides SWPL with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For SWPL client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge 24  separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. information Charles Schwab & Co., Inc. Advisor Services also makes available to SWPL other products and services that benefit SWPL but may not benefit its clients’ accounts. These benefits may include national, regional or SWPL specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of SWPL by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist SWPL in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of SWPL’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of SWPL’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to SWPL other services intended to help SWPL manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to SWPL by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to SWPL. SWPL is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. B. Compensation to Non–Advisory Personnel for Client Referrals SWPL may, from time to time enter into agreements with third-party promoters (formerly referred to as solicitors) to whom we provide compensation for securing clients for us. These agreements require that the promoters meet the disclosure requirements and disqualification provisions in accordance with Prong 2 of the Investment Adviser Marketing Rule 206(4)-1 under the Investment Advisers Act of 1940. At the time of the initial solicitation, the solicited client will receive a copy of SWPL’s promoter disclosure brochure, which includes information such as the nature of the relationship between SWPL and the promoter and any conflicts of interest. Additionally, prior to, or at the time of, entering into an investment management agreement with SWPL, the solicited client will receive SWPL’s Form ADV Part 2A, Privacy Policy, and Form ADV Part 3-CRS, as may be applicable. 25  The compensation paid to a promoter may vary and is detailed in the agreement and the promoter disclosure brochure and is generally based upon a percentage of the fees earned by SWPL from clients solicited through such third-party promoter. Compensation paid to a promoter will not increase the amount of management fees charged to a client. Item 15: Custody We previously disclosed in the “Fees and Compensation” section (Item 5) of this Brochure that we request you direct your custodian to allow our Firm to directly debit your management fees from your account(s). Again, the approval of the direct debit of fees is solely your choice. You have no obligation to allow us to do so. Technically, SEC rules consider the action of direct debiting of fees to be considered maintaining custody. However, if this is the only manner in which we are considered to have custody and certain conditions are met, we will not be subject to the requirements established for true custody of your assets. If you agree to allow us to direct debit fees from your account(s), we will require authorization in writing from you. Each billing period we will notify your custodian of the amount of the fee to be deducted from your account(s). On at least a quarterly basis, the custodian is required to send to you and us a statement showing all transactions, including management fees disbursed from your account during the reporting period. It is important you carefully review the custodial statements to verify the accuracy of the calculation, among other things. You should contact us directly if you believe there may be an error in your statement. In addition to the periodic statements that you receive directly from your custodian, we may send or provide, via electronic format, account statements directly to you. Our Firm does not have physical custody of any client assets. Item 16: Investment Discretion SWPL provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, SWPL generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, SWPL’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to SWPL). 26  Item 17: Voting Client Securities (Proxy Voting) SWPL will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information SWPL does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance. In addition, SWPL is required to disclose any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. SWPL has no disclosures pursuant to this Item. 27