Sky Vision Wealth Management Corp.

Sky Vision Wealth Management Corp. Firm Brochure - Form ADV Part 2A ) - This brochure provides information about the qualifications and business practices of Sky Vision Wealth Management Corp.. If you have any questions about the contents of this brochure, please contact us at ( or by email at: compliance@skyvisionwealthmanagement.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. website at Additional information about Sky Vision Wealth Management Corp. is also available on the CRD number is: 317320. www.adviserinfo.sec.gov. Sky Vision Wealth Management 780 ROOSEVELT, IRVINE, CA 92620 21680 GATEWAY CENTER DR, SUITE 110, DIAMOND BAR, CA 91765 (626) 437­1436 contact@skyvisionwealthmgmt.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 0 9/15/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Sky Vision Wealth Management Corp. on are described below. Material changes relate to Sky Vision Wealth Management Corp. ests. 03/26/2026 Sky Vision Wealth Management Corp. has updated their Assets Under Management (Item 4.E). Sky Vision Wealth Management Corp. has added one more office location in California (Page i). ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes........................................................................................................................................................... ii Item 3: Table of Contents .........................................................................................................................................................iii Item 4: Advisory Business................................................................................................................................................................... 2 Item 5: Fees and Compensation ............................................................................................................................................. 4 Item 6: Performance-Based Fees and Side-By-Side Management ..................................................................................... 6 Item 7: Types of Clients.............................................................................................................................................................. 6 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ....................................................................... 6 Item 9: Disciplinary Information..........................................................................................................................................11 Item 10: Other Financial Industry Activities and Affiliations...................................................................................11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............12 Item 12: Brokerage Practices...........................................................................................................................................................13 Item 13: Review of Accounts .................................................................................................................................................14 Item 14: Client Referrals and Other Compensation .....................................................................................................15 Item 15: Custody .........................................................................................................................................................................16 Item 16: Investment Discretion ......................................................................................................................................................16 Item 17: Voting Client Securities (Proxy Voting) ....................................................................................................................16 Item 18: Financial Information .......................................................................................................................................................16 iii  Item 4: Advisory Business A. Description of the Advisory Firm Sky Vision Wealth Management Corp. (hereinafter SVWMC ) is a Corporation organized in the State of Delaware. The firm was formed in August 2021, and the principal owners are Sky Vision Wealth Management Limited and Cubetech Investment Limited. B. Types of Advisory Services Portfolio Management Services SVWMC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SVWMC creates an Investment Policy Statement for each client, which outlines the client s current situation (income, tax levels, and risk tolerance levels). 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 SVWMC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SVWMC 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. SVWMC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SVWMC s economic, investment or other financial interests. To meet its fiduciary obligations, SVWMC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SVWMC 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 SVWMC s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. SVWMC has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, SVWMC will always ensure those other advisers are properly licensed or registered as an investment adviser. SVWMC conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third- party adviser's performance and investment strategy. SVWMC then makes investments 2  with a third-party investment adviser by investing with the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third party adviser on behalf of SVWMC's client. SVWMC may also allocate among one or more private equity funds or private equity fund advisers. SVWMC will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments SVWMC generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, hedge funds, private equity funds, ETFs, treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds and private placements. SVWMC may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions SVWMC 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 SVWMC from properly servicing the client account, or if the restrictions would require SVWMC to deviate from its standard suite of services, SVWMC reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. SVWMC does not participate in wrap fee programs. E. Assets Under Management SVWMC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 0.00 $ September, 2026 101, 436, 090.00 3  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $5,000,000 1.50% $5,000,000 - $10,000,000 1.20% $10,000,000 - $20,000,000 1.00% $20,000,000 - $50,000,000 0.80% $50,000,000 - AND UP 0.60% SVWMC 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 SVWMC's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 15 days' written notice. Selection of Other Advisers Fees SVWMC will receive its standard fee on top of the fee paid to the third party adviser. This relationship will be memorialized in each contract between SVWMC and each third-party adviser. The fees will not exceed any limit imposed by any regulatory agency. Financial Planning Fees Fixed Fees The negotiated fixed rate for creating client financial plans is between $1,000 and $100,000. Hourly Fees The negotiated hourly fee for these services is between $200 and $800. 4  Clients may terminate the agreement without penalty, for full refund of SVWMC s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. 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 Selection of Other Advisers Fees The timing, frequency, and method of paying fees for selection of third-party managers will depend on the specific third-party adviser selected. Payment of Financial Planning Fees Financial planning fees are paid via wire. Fixed financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Hourly financial planning fees are paid 100% in advance, but never more than six months in advance. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by SVWMC. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees SVWMC collects certain fees in advance and certain fees in arrears, as indicated above. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check or return deposit back into the client s account. Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. 5  For hourly fees that are collected in advance, the fee refunded will be the balance of the fees collected in advance minus the hourly rate times the number of hours of work that has been completed up to and including the day of termination. E. Outside Compensation For the Sale of Securities to Clients Neither SVWMC nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management SVWMC does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients SVWMC generally provides advisory services to High-Net-Worth Individuals. There is no account minimum for any of SVWMC s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis SVWMC s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. SVWMC uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find 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. 6  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 SVWMC uses long term trading, short term trading and margin transactions. 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. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. 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 7  i.e., if for that level of risk an exists with a more favorable risk-expected return profile 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, 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 SVWMC's use of margin transactions 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. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Selection of Other Advisers: Although SVWMC will seek to select only money managers who will invest clients' assets with the highest level of integrity, SVWMC's selection process cannot ensure that money managers will perform as desired and SVWMC will have no control over the day-to-day operations of any of its selected money managers. SVWMC 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. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 8  C. Risks of Specific Securities Utilized SVWMC's use of margin transactions 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 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. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially time the market is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading 9  conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. 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. 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. 10  Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. 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 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither SVWMC nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. 11  C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither SVWMC nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections SVWMC has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. Clients will pay SVWMC its standard fee in addition to the standard fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract between SVWMC and each third-party advisor. The fees will not exceed any limit imposed by any regulatory agency. SVWMC will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. SVWMC will ensure that all recommended advisers are licensed or notice filed in the states in which SVWMC is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics SVWMC 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. SVWMC's Code of Ethics is available freeupon request to any client or prospective client. B. Recommendations Involving Material Financial Interests SVWMC does not recommend that clients buy or sell any security in which a related person to SVWMC or SVWMC has a material financial interest. C. Investing Personal Money in the Same Securities as Clients to clients. This may provide an opportunity From time to time, representatives of SVWMC may buy or sell securities for themselves that they also recommend for representatives of SVWMC to buy or sell the same securities before or after recommending the same 12  securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. SVWMC will always document any transactions that could be construed as conflicts of interest and will never being bought or sold. D. Trading Securities At/Around the Same Time as Securities From time to time, representatives of SVWMC may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of SVWMC 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, SVWMC will never engage disadvantage when similar securities are being bought or sold. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker- terms that are the most favorable to the client under the circumstances. The client will not necessarily pay the lowest commission or commission equivalent, and SVWMC may also consider the market expertise and research access provided by the payment of commissions, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers to aid in the research efforts of SVWMC. SVWMC will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. SVWMC recommends MORGAN STANLEY SMITH BARNEY LLC (CRD #149777) and CHARLES SCHWAB & CO., INC. (CRD #5393). 1. Research and Other Soft-Dollar Benefits While SVWMC has no formal soft dollars program in which soft dollars are used topay for third party services, SVWMC may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions ( soft dollar benefits ). SVWMC may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client s transactions paid forit, and SVWMC does not seek to allocate benefits to client accounts proportionate to 13  any soft dollar credits generated by the accounts. SVWMC benefits by not having to produce or pay for the research, products or services, and SVWMC will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that SVWMC s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals SVWMC 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 SVWMC may permit clients to direct it to execute transactions through a specified broker- dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client s direction with respect to the use of brokers supersedes any authority granted to SVWMC to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts If SVWMC buys or sells the same securities on behalf of more than one client, it might, but would be under no obligation to, aggregate or bunch, to the extent permitted by applicable law and regulations, the securities to be purchased or sold for multiple clients in order to seek more favorable prices, lower brokerage commissions or more efficient execution. In such case, SVWMC 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. SVWMC would determine the appropriate number ofshares to place with brokers and will select the appropriate brokers consistent with duty to seek best execution, except for those accounts with specific brokeragedirection (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for SVWMC's advisory services provided on an ongoing basis are reviewed at least monthly by Jenny Liu, Chief Compliance Officer, with regard to clients 14  respective investment policies and risk tolerance levels. All accounts at SVWMC are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Jenny Liu, Chief Compliance Officer. Financial planning clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. 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). With respect to financial plans, SVWMC s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of SVWMC's advisory services provided on an ongoing basis will receive a monthly report detailing the client s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. 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) SVWMC does not receive any economic benefit, directly or indirectly from any third party for advice rendered to SVWMC's clients. B. Compensation to Non Advisory Personnel for Client Referrals SVWMC may enter into written arrangements with third parties to act as solicitors for SVWMC's investment management services. Solicitor relationships will be fully disclosed to each Client to the extent required by applicable law. SVWMC will ensure each solicitor is exempt, notice filed, or properly registered in all appropriate jurisdictions. All such 15  referral activities will be conducted in accordance with Rule 206(4)-3 under the Advisers Act, where applicable. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, SVWMC will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion SVWMC 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, SVWMC 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. Item 17: Voting Client Securities (Proxy Voting) SVWMC 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 A. Balance Sheet SVWMC neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither SVWMC nor its management has any financial condition that is likely to reasonably impair SVWMC s ability to meet contractual commitments to clients. 16  C. Bankruptcy Petitions in Previous Ten Years SVWMC has not been the subject of a bankruptcy petition in the last ten years. 17