SKYBOUND WEALTH MANAGEMENT USA, LLC

Part 2A of Form ADV: Firm Brochure Skybound Wealth Management USA, LLC dba Skybound Wealth USA 2700 Post Oak Boulevard, 21st Floor Houston, Texas 77056 Telephone: 1-346-845-0001 Web Address: www.Skyboundwealthusa.com Email: clientservices@Skyboundwealthusa.com December 23, 2025 contents of this brochure, contact us at 1-346-845-0001 This brochure provides information about the qualifications and business practices of Skybound Wealth Management USA, LLC dba Skybound Wealth USA. If you have any questions about the or please clientservices@Skyboundwealthusa.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Registration with the SEC or notice filing with any state securities authority does not imply that Skybound Wealth Management USA, LLC dba Skybound Wealth USA or any of its principals or employees possesses a particular level of skill or training in the investment advisory business. Additional information about Skybound Wealth Management USA, LLC dba Skybound Wealth USA also is available on the SEC’s website at www.adviserinfo.sec.gov. Our Firm’s CRD # is 313358.  Item 2 - MATERIAL CHANGES Since our last Form ADV Part 2A dated March 2025, we have made the following material changes: • Item 4: Updated the company name to reflect the firm’s “doing business as” designation: Skybound Wealth Management USA, LLC dba Skybound Wealth USA • Item 4: Updated the firm’s ownership structure to reflect the transfer of ownership from Victoria Creer to Joshua Burton.  Item 3 - TABLE OF CONTENTS Item 1 – COVER PAGE Cover Page Item 2 - MATERIAL CHANGES ........................................................................................................... 2 Item 3 - TABLE OF CONTENTS .......................................................................................................... 3 Item 4 - ADVISORY BUSINESS ........................................................................................................... 4 Item 5 - FEES AND COMPENSATION ................................................................................................ 9 Item 6 - PERFORMANCE-BASED FEES AND SIDE BY SIDE MANAGEMENT .......................... 14 Item 7 - TYPES OF CLIENTS ............................................................................................................. 14 Item 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ........... 15 Item 9 - DISCIPLINARY INFORMATION ........................................................................................ 17 Item 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................... 17 Item 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ............................................................................................................. 18 Item 12 - BROKERAGE PRACTICES ................................................................................................ 19 Item 13 - REVIEW OF ACCOUNTS ................................................................................................... 22 Item 14 - CLIENT REFERRALS AND OTHER COMPENSATION ................................................. 22 Item 15 - CUSTODY ............................................................................................................................ 23 Item 16 - INVESTMENT DISCRETION ............................................................................................. 23 Item 17 - VOTING CLIENT SECURITIES ......................................................................................... 24 Item 18 - FINANCIAL INFORMATION ............................................................................................. 24  Item 4 - ADVISORY BUSINESS Skybound Wealth Management USA, LLC dba Skybound Wealth USA (“Skybound Wealth USA,” “Skybound USA,” or the “Adviser”) is an investment advisory firm that provides wealth management services customized to your individual needs. Skybound USA (referred to throughout as Adviser, we, us, our, or the Firm) is owned by Skybound Wealth Management Group Limited (Malta) and Joshua Burton. Skybound USA was established in 2017 and has been registered as an investment advisor with the United States Securities and Exchange Commission (“SEC”) since May, 6th 2021. As of December 31st, 2024, Skybound USA managed $160,577,958 of client assets on a nondiscretionary basis. Skybound USA provides investment advisory services through investment adviser representatives (“Adviser Representatives” or “ARs”) to clients. At the outset of its relationship with you, Skybound USA designates a particular Adviser Representative to serve you in all matters regarding the delivery of wealth management services to you. Your designated AR helps you design a financial plan that is most suited to your financial circumstances, investment objectives and strategies, and risk tolerance. In addition, the Adviser Representative discusses with you the fees and costs you may incur for receiving these services. An Adviser Representative conducts all of his investment advisory activities as an associated person and supervised person of Skybound USA. As a supervised person of Skybound USA, an Adviser Representative is subject to the supervision and control of Skybound USA in connection with all matters regarding this relationship. As an investment adviser, Skybound USA is a fiduciary in its dealing with clients. As such, Skybound USA must act at all times in your best interest as its client. It has a duty to be loyal to you and to provide you with full and fair disclosure of, and to mitigate, all material conflicts of interest that may arise in the course of performing its duties to you. It must seek best execution when conducting purchase or sale transactions on your behalf. It must ensure that the investment advice it provides to you is suitable given your financial circumstances, investment objectives, and risk tolerance, and that it has a reasonable, independent basis for this advice. And it, as well as all of its supervised persons and other personnel who are involved in delivering investment advisory services to you, must refrain from engaging in personal securities transactions that are inconsistent with your interests. Skybound USA also has fiduciary responsibilities with respect to retirement accounts of clients that are covered by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). As an ERISA fiduciary, Skybound USA is required to provide advice that is in the best interest of a covered client, charge fees that are reasonable in relation to the services provided to this client, and ensure that a covered client receives full and fair disclosure about recommended transactions, fees and compensation, conflicts of interest, or any other matters relevant to the client’s investment decision-making. Types of Services Investment Management Services Investment Management Services provides clients with continuous and ongoing supervision over their accounts. This means that Skybound USA will provide investment advice to clients on a discretionary or non-discretionary basis. Unless otherwise expressly requested by you, Skybound USA will manage your portfolio on a discretionary basis and will make changes to the allocation, strategy, and/or management as deemed appropriate by Skybound USA. Skybound USA’s management services include one or more of the following depending on assessment of your needs: • Determine the securities to be purchased and sold in the account and alter the securities holdings from time to time, without prior consultation with you. 4  • Determine the managers and strategies to manage your portfolio and replace managers or strategies when appropriate. • Assist you in understanding the services and strategies provided by third party investment advisers who will co-advise your account. • Assist you to determine appropriate managed model portfolio strategy. • Provide suitability updates to any third-party manager engaged to manage your account. • Periodically meet with you to assess your financial situation and review your portfolio. Skybound USA will recommend to Clients that all or a portion of their investment portfolio be implemented by utilizing one or more unaffiliated money managers or investment platforms (collectively “Independent Managers”). Independent Managers may be sourced directly or accessed through an investment management platform. Skybound USA serves as the Client’s primary advisor and relationship manager. However, the Independent Manager[s] will assume discretionary authority for the day-to-day investment management of those assets placed in their control. Skybound USA performs initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with the Client’s investment objectives and overall best interest. The Advisor will assist and advise the Client in establishing investment objectives for their account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s]. If you elect to have your accounts managed on a nondiscretionary basis, no changes will be made to the allocation of your account without prior consultation with you and your expressed agreement. Nondiscretionary is not available when an overlay management strategist or model account management strategy is utilized. There is risk with electing to have your account managed on a non-discretionary basis. The risk is that your Advisory Representative will not be able to conduct transactions in a timely manner. If you have your custom allocated accounts managed on a nondiscretionary basis, your Advisory Representative cannot make changes to the allocations in your account without prior consultation and your expressed agreement. When providing Investment Management Services, the Firm will typically consider, 3rd party investment managers or strategies, bonds, equities, ETFs, mutual funds, and private fund investments to build diversified portfolios to meet each respective client’s financial goals and objectives; however, we are not limited to those investments. It is not our typical investment strategy to attempt to time the market, but we may amend allocations based on the client’s risk tolerance and short- and long-term goals. We may modify our investment strategy to accommodate special situations, including but not limited to special tax situations. Transactions in the account, account reallocations and rebalancing often trigger a taxable event, with the exception of IRA accounts and other qualified retirement accounts. UK Pension Transfer Services If you have previously lived and worked in the United Kingdom and now reside in the United States, you may maintain assets in defined benefit or defined contribution pension accounts that were established while living and working in the U.K. These assets are kept under arrangements with their former employers that involve the use of institutional trustees to safe-keep and administer the assets. Over the years, Skybound USA has found that many individuals desire better arrangements that afford them more flexibility to manage their pension plan assets while they are living and working in the United States. Pension legislation in the United Kingdom has made it possible for individuals to transfer their pension assets to certain approved personal pension schemes so that they can manage those assets on a more flexible basis going forward. Skybound USA helps you, to assess whether a transfer to a Self Invested Personal Pension (SIPP) might be in your best interest. Skybound USA has established a process to elicit the right information in order to help you make this decision and to discuss the options that might be available to you. Additionally, we provide management services over any existing UK pensions including qualified retirement overseas pensions (QROPs). 5  The process of transferring a UK defined benefit or contribution plan is a complex and lengthy process and has many layers of fees. It is important you understand the costs, expenses and that a transfer can take up to or over a year to complete, particularly for defined benefit plans. Further, defined benefit (DB) plan transfers will require you to engage a UK advisor, in addition to Skybound USA, to evaluate your situation and issue an advice report. This is an added cost that can be as high as 5000 GBP. The fee is set the UK advisor and is independent of Skybound USA. Additionally, you will be required to participate in an educational session to help you understand your options. You will be issued a written assessment or report by the UK advisor outlining whether a pension transfer should be considered. The report will outline the advantages and disadvantages of transferring and information on the various costs and expenses. It is important clients considering transferring their UK pension review consumer information provided at https://www.fca.org.uk/consumers. There are advantages and disadvantages to transferring a UK pension as well as costs. A pension transfer is not appropriate for all individuals. When making a transfer, you will be giving up certain guarantees offered by the pension. Skybound USA will provide you with a written assessment, for DB pensions this will be in addition to the assessment by the UK advisor, and if you choose to transfer your UK pension, Skybound USA will provide continuous and ongoing management services for an ongoing fee. Skybound USA will manage the assets or suggest the use of a third- party asset manager. Use of a discretionary fund manager or model manager or strategist will add additional costs which will be fully disclosed to you. It is important to understand that reporting on UK assets is different from the United States. Valuation statements are generally made available on an annual basis (unless otherwise specifically requested). However, most UK platform providers provide online access to your pension. We do not provide tax advice including, without limitation, in relation to any US tax reporting requirements and/or other tax implications arising in relation to clients' pension transfers. We recommend you seek your own tax advice, including in relation to procedures under tax treaties between the United States and the UK (or other applicable jurisdiction) for the avoidance of double taxation on non-US pension arrangements. Financial Planning Services We offer advisory services in the form of financial planning services. Financial planning services can be made available alongside investment management services or as a standalone service that Skybound USA offers for a fee as details in Item 5. Financial planning can be described as helping individuals determine and set their long-term financial goals through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is to find ways to help the client understand their overall financial situation and help them set financial objectives. We analyze and review the client’s financial documentation, which typically includes the client’s assets and liabilities, investment portfolio, retirement plan, education plan, risk management plan, risk tolerance, estate plan, and other areas relevant to the client’s financial health. We then provide an executive summary highlighting the plan of action. Our Wealth Managers are available to assist with implementing the plan and to anSkybounder any client questions. Still, the client is ultimately responsible for implementing or rejecting our recommendations. You are never obligated or required to implement our recommendations. Furthermore, we can implement the plan with the client throughout the year. It remains the client’s responsibility to promptly notify us of any changes in their financial situation or investment objectives to review, evaluate, or revise our previous recommendations and/or services. In the course of designing a financial plan, Skybound USA may enlist the assistance of third parties that are specialists in various disciplines, such as tax and estate planning. Skybound USA does not charge a fee or receive any other compensation or benefit for referring clients to these specialists. As a client, you are free to make your own arrangements with these specialists on terms that are acceptable to you. 6  General Considerations Investment recommendations and advice offered by Skybound USA is not considered and should not be considered legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform Skybound USA promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify Skybound USA of any such changes will result in investment recommendations not meeting your needs. Skybound USA tailors the advisory services it offers to your individual needs. You may impose restrictions and/or limitations on the investing in certain securities or types of securities. Services will begin with an initial consultation and data gathering. Your Advisory Representative will ask you various questions about your financial situation and request certain documents about your financial accounts. You may be asked to complete a fact finder or data gathering document. The information gathered by Skybound USA will assist Skybound USA to provide you with the requested services and customize the services to your financial situation. Depending on the services you have requested, Skybound USA will gather various financial information and history from you including, but not limited to: Investment objectives Investment horizon • Retirement and financial goals • • • Financial needs • Cash flow analysis • Cost of living needs • Education needs • Savings tendencies • Other applicable financial information required by Skybound USA in order to provide the investment advisory services requested. SIPP product providers may be available through other investment advisers under slightly different programs with different fees, charges and restrictions. These should be considered in deciding who you select as your financial advisers and other service providers, including Skybound USA. An external service provider will have separate fee agreements as part of its service level agreement. These agreements will be provided to you for review and sign-off, at the same time as the appointment of your Adviser Representative and as part of your overall investment management agreement and package with us. IRA Rollover Considerations 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. As part of our consulting and advisory services, we offer you recommendations and advice concerning your employer retirement plan or other qualified retirement account. Our recommendations can include you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and rolling the assets over to an individual retirement account ("IRA"). Further, we offer our management services be applied to those funds and securities rolled into an IRA or other account for which we will receive compensation. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as described above under Item 5. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. It is important for you to understand that many employers permit former employees to keep their retirement assets in 7  their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: 1. Leave the funds in your employer's (former employer's) plan. 2. Move the funds to a new employer's retirement plan. 3. Cash out and take a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages. Before making a change, we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage it is important you understand the following: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans often have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the costs of those products and services. c. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee. 3. Our strategy can have higher risk than the option(s) provided to you in your plan. 4. Your current plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost. 5. If you keep your assets titled in a 401k or retirement account, you could delay your required minimum distribution beyond age73. (You must take your first required minimum distribution starting the year in which you turn age 73 (72 if you reach 72 prior to January 1, 2023, or 70 ½ if you reach 70 ½ before January 1, 2020). If you reach 70½ in 2020, you had to take your first RMD by April 1 of the year after you reach the age of 72. For all subsequent years, including the year in which you were paid the first RMD by April 1, you must take the RMD by December 31 of the year. (Source IRS.gov)) 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 8  8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. Persons Residing Outside of the United States Services for clients living outside the United States may be restricted or limited due to custodial rules or other factors. Investment options and strategies may differ from our typical recommendations, including but not limited to the foreign tax treatment of investment transactions in the United States. In addition, foreign laws or requirements may also impact our ability to service accounts or require additional disclosure as determined on an individual country basis. The client will be responsible for satisfying all legal and tax reporting requirements of the United States and all applicable foreign governments. Any person located outside of the United States who wishes to open an account or an existing client who is located outside of the United States will be subject to the custodian’s policy regarding that country (including their right to decline to open or maintain the account), and all applicable customer identification and anti-money laundering regulations. In its sole discretion, Skybound USA reserves the right to decline an engagement with any prospective client outside of the United States, or terminate an engagement with an existing client, if they move outside of the United States. Skybound USA does not participate in wrap-fee programs. Item 5 - FEES AND COMPENSATION While no Advisory Representative can exceed the fees schedules outlined below, each Advisory Representative can negotiate and charge an advisory fee based on the fee schedules below. The amount of the fee is not commensurate with education or tenure in the industry. Therefore, you will find different Advisory Representatives charge more or less than the fee you are being charged for similar services. Your Advisory Representative has a direct interest in the fee charged to you since Skybound USA will pay a portion of the advisory fee charged to you to your Advisory Representative. Investment Management Services We typically charge an annual percentage-based fee for investment management services for US domestic accounts. Adviser Representatives an annual fee shall not to exceed 1.25% annually. The annual fee will begin immediately upon completion of the account funding. The annual fee is based on the fair market value of the client’s account assets determined as of the last day of each calendar month or quarter depending on the provider. Based on specific circumstances, like accrued interest, there may be a discrepancy between the custodial statement value and the client’s assets in the billing software 9  on the last day of the quarter. Advisory fees are annualized and applied monthly or quarterly in arrears based on the number of calendar days in a month or quarter. The value of the assets billed will be calculated using the asset share price on the last day of the month or quarter and the number of shares at the time the account was last connected. If the relationship is terminated, a prorated fee will be due for the number of days you were a client in the quarter. Unless expressly excluded, we calculate our management fee against all assets in the investment account. Therefore, fee calculations include cash balances invested in money market funds, short-term investment funds, ETFs, mutual funds, private fund investments (if any), and all other investment holdings. The account values used to calculate your management fee are obtained from pricing services that we believe are reliable. However, we cannot guarantee their accuracy or that securities may be bought or sold at those prices. We rely on the most recent holding information made available through our aggregation software in relation to reporting, trading, and billing calculations. This may include pricing data gathered from third-party sources other than the custodian of your account(s). Valuation of a fund’s private fund investments may be complex, as there generally is no established market for these assets or for securities of privately held companies that the fund may own directly or indirectly. Therefore, there may be differences in the values we use for reporting, trading, and billing calculations. Any security (or securities) excluded from billing or labelled as “no bill” will not be included in assets under management to determine our investment management fee. The exact services and fees will be agreed on and disclosed before services are provided. Fees and how they are charged are negotiable. At our discretion, we can agree to a different investment advisory fee structure, prorate a fee, or waive a fee entirely based upon specific facts and circumstances including, but not limited to, the client’s financial situation and circumstances, the amount of assets under management and/or anticipated to be under management, account householding arrangements, the complexity of the services provided, negotiations with the client, etc. Third Party Investment Management Fees Skybound Annual Advice Maximum Fee Maximum Fee Manager / Strategist Maximum Total Advisory Fee 1.25% 0.5% 1.75% Additional Fees and Costs: In addition to the fees outlined above, depending on the custodian you may be subject to the following fees and costs: • Transaction fees and/or dealing costs • Investment platform fees • If mutual funds, UCITS, exchange traded funds or other pooled investment vehicles are used, the client will pay a proportionate share of the fund’s management and administrative fees and sales charges as well as the fund adviser’s fee of any fund purchased. Such advisory fees are not shared with Skybound USA and are compensation to the fund-manager. Financial Planning Fees for planning services are strictly for planning services. Therefore, you will pay fees for additional services obtained such as asset management. It is your Advisory Representatives discretion whether or not to waive a 10  portion or all of any financial planning or consulting fee if you implement advice through your Advisory Representative and participate in an asset management program or service. Fees are negotiable. Your fees will be dependent on several factors including time spent with the Advisory Representative, number of meetings, complexity of your situation, amount of research, services requested and staff resources, and your Advisory Representative. Service Fee Payable Financial Planning $2,000 - $10,000 A fee payment schedule will be negotiated and agreed upon between you and your Advisory Representative prior services beginning and will be outline in the client advisory agreement. Fees are: 1. Payable up to one-half (1/2) upon execution of the advisory agreement with Skybound Wealth USA, the balance due at the time of presentation of the plan or recommendations; 2. Quarterly installments with the full amount due upon presentation of the plan or recommendations; or 3. Due in full at the time of presentation of the plan or recommendations. 4. Monthly Payments invoiced at the end of the month $750 Payable as invoiced by Skybound Wealth USA Hourly Fee UK Pension Transfers As previously stated under Item 4, there are multiple fees clients will pay when electing to transfer a U.K. pension to a Self-Invested Personal Pension (“SIPP”) including: • FCA required suitability report costs (required for defined benefit transfers) • Initial planning and analysis fee • Ongoing asset management fees • Discretionary fund manager fees • Investment platform, custodian, and trustee fees, and transaction and dealing fees. Clients will pay Skybound USA two fees if a UK pension transfer progresses. 1) Initial Fee: The initial fee is a percentage fee based on the value of the pension assets to be transferred. 2) Annual Fee: After pension assets are transferred, Skybound USA will receive an ongoing fee for management of assets and continuous review. The fee is based on the value of the account as determined by the UK platform. Fees are further described below. Fees are negotiable and will be determined based on several factors including size of the pension assets, services being provided to the client, complexity of the situation, and consultations. Initial Fee Clients will pay an initial fee covering time and services for analysis and planning, advice, consultation, and review and establishment of a SIPP, or other applicable plan. The initial fee is calculated on and deducted directly from the value of the assets transferred, unless directly paid by the client. The fee is a contingent fee, meaning client will only pay the fee if the client elects to transfer their pension. This is a conflict of interest because there is an incentive to recommend a transfer to receive compensation. To mitigate this conflict of interest this 11  disclosure is provided, and clients should discuss the transfer with another professional. In addition to the initial fee, if the client has a defined benefit plan (DB scheme) the client will pay a fee to a U.K. qualified Advisor to prepare the U.K. suitability report, which can be £5,000 or more, depending on the U.K. Advisor, the value of U.K. pension assets, and the time frame the report is needed. The fee is paid direct to the U.K. Advisor for the report and is not determined or set by Skybound USA or shared with Skybound USA or its advisory representatives. U.K. pension transfers with safeguarded benefits in excess of £30,000 are subject to review and analysis by a U.K. regulated adviser, unaffiliated with us. The suitability report fee is charged to the client and is an added cost incurred by the client, whether or not the client decides to move forward with the pension transfer. The cost of the suitability report will be invoiced to the client or will be deducted directly from the pension asset once the transfer to the SIPP has been completed. In certain circumstances your Advisory Representative can agree to cover the cost of the report fee on your behalf and you will be obligated to reimburse us for the fee. You can elect to pay the fee from transferred assets. However, this will deplete the pension assets and the amount that will be invested. It is important to understand costs before beginning the process of obtaining the report. Typically, U.K. qualified Advisors will advise against a transfer and will outline in their report their opinions. Regardless of the outcome, you will be subject to the report fee. The initial fee is calculated based on the value of the pension assets transferred from a defined benefit or defined contribution scheme to a SIPP. The is calculated by the trustee or platform provider and is agreed on between you and your advisory representative. The agreed upon fee is disclosed in the advisory agreement with Skybound USA and in the trustee or platform application. Initial Fees • If the pension assets to be transferred are between £30,000 to £1,000,000 , the initial fee is a maximum of 3% of the amount to be transferred; • If the pension assets to be transferred are more than £1,000,000, the initial fee is a maximum of 2% of the amount to be transferred. The initial fee will be due upon the decision to transfer pension assets. Initial fees cover the cost of financial planning services as well as the detailed setup process that needs to be followed in order to be able to transfer assets to a SIPP. This work incorporates an initial fact- finding conversation with you and determination of whether or not to proceed with finding out the cash equivalent transfer value of the pension account. If you decide to make a transfer, your Adviser Representative will then initiate a detailed transfer process liaising with the FCA-regulated adviser to obtain an independent assessment of whether you should make the transfer. In addition, your Adviser Representative will conduct a more detailed fact-find as a means of developing a total picture of your current retirement and other assets, as well as current liabilities and desired income and lifestyle at retirement. Based on this information, a series of projections is generated using Skybound USA’s software to develop a proposal for you that is in line with your risk tolerance and suitability profile. If the initial fee is paid out of transferred pension assets, the client is advised the fee will directly reduce the amount of assets available for investment. In the United States the Securities and Exchange Commission requires investment advisers to disclose that when fees exceed 3% the fees are considered excessive in comparison to fees charged by other investment advisers for similar services. UK pension transfers involve several layers of fees as further described below under Additional Fees and Costs. Therefore, considering total fees a client will pay including our advisory fees, UK report writer, trustee, platform provider, etc. the fees can exceed 5% or more. It is important for a client to refer to charging 12  schedules for all providers including investment fund costs. Annual Fee SIPP accounts will be charged an annual fee not to exceed 1.25% annually of the value of assets in the accounts. The annual fee is measured from time of completing the transfer and investing the transferred assets. Fees are normally deducted monthly in arrears and will be calculated based on the value of the account on the last business day of the month. Advisory fees will generally be deducted directly from your account by the custodian for the account. As part of your investment management agreement, you authorize your Adviser Representative to instruct the custodian to deduct fees in accordance with this agreement. Depending on the SIPP provider, fees will be deducted from the account either: 1) quarterly in arrears or 2) monthly in arrears. Fees are calculated by the platform provider and based on the valuation date established by the provider. Platform providers will typically not prorate fees for partial billing periods. Therefore, you will pay the full billing period (i.e., month or quarter) regardless of when assets were deposited to your account. General Disclosure Advisory fees will be collected directly from your account. As stated above, the platform provider or custodian will calculate Skybound USA’s advisory fees. Written authorization is granted to Skybound USA to receive fees direct from the platform provider or custodian by execution of the client agreement. You will be provided with an account valuation reflecting the deduction of the advisory fee direct from the account custodian at a frequency as agreed by the platform provider. Additionally, you can request an account valuation at any time. If the Account does not contain sufficient funds to pay advisory fees, Skybound USA has authority to sell or redeem securities in sufficient amounts to pay advisory fees. Additional Fees and Costs: In addition to the fees outlined above, depending on the investment platform and SIPP provider or trustee, you will be subject to the following fees and costs: • Transaction fees and/or dealing costs • Discretionary Fund Manager or Discretionary Manager fees • Investment platform fees • Establishment or set-up fee and annual fees charged by the SIPP provider • Annual trustee or administrative charges • Income or benefit set-up and annual fees charged by the SIPP provider • If a portfolio bond is utilized there will be set-up fees, ongoing administration fees, and dealing fees per trade • If mutual funds, UCITS, exchange traded funds or other pooled investment vehicles are used, the client will pay a proportionate share of the fund’s management and administrative fees and sales charges as well as the fund adviser’s fee of any fund purchased. Such advisory fees are not shared with Skybound USA and are compensation to the fund-manager. 13  • Exit fees are charged if changing platforms or trustees Discretionary Manager or Third-Party Asset Manager: A discretionary manager (DM) or also referred to as third party asset manager can be engaged to manage some or a portion of the SIPP assets. The DM will charge a fee up to 1.00% on the portion of assets allocated to the DM. Therefore, annual asset management fees can be 2.25% (i.e., 1.25 maximum Skybound USA fee plus 1.00% to the DM). Additionally, such advisory fees are not shared with Skybound USA and are compensation to the fund-manager. Additional Fees and Costs. In addition to the advisory fees above, you will pay transaction or dealing fees for securities transactions executed in your account in accordance with the custodian’s transaction fee schedule. Additionally, you will pay fees for custodial services, account maintenance fees, transaction fees, and other fees associated with maintaining the Account. Skybound USA does not share in any portion of the aforementioned fees. The underlying investments in the SIPP will have internal costs that typically do not exceed 1%. This cost is borne by the investor and you will pay your proportionate share of the fund’s management and administrative fees and sales charges as well as the mutual fund adviser’s fee of any exchange traded fund, mutual fund, or Undertakings for the Collective Investment in Transferable Securities (UCITS) purchased. Such fees are not charged by Skybound USA and are charged by the product, broker/dealer, trustee, or account custodian. Skybound USA does not share in any portion of such fees. Such advisory fees are not shared with Skybound USA and are compensation to the underlying fund manager. Termination Provisions You may terminate investment advisory services obtained from Skybound USA, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with Skybound USA. You will be responsible for any fees and charges incurred from third parties as a result of transferring and/or maintaining the account such as transaction fees for any securities transactions executed and account maintenance or custodial fees. Thereafter, you may terminate investment advisory services upon delivery to Skybound USA and your Advisory Representative of your written notice to terminate. a. If termination occurs prior to the initiation of the transfer of pension assets, clients will be responsible for time and third-party expenses incurred, such as the FCA report prepared by the UK qualified Advisor. b. If review, advice, and/or analysis of Client’s United Kingdom pension have been initiated, Client will not be entitled to a prorated refund of the initial fee. The initial fee covers Adviser’s time, analysis, and review of the pension assets and Client’s financial situation. Any ongoing fees due to Skybound USA are calculated and determined by the platform or custodian. The ongoing fee can be pro-rated by the platform or custodian based upon the number of days in the billing period up to Adviser’s receipt of Client’s written notice to terminate (the “termination date”). Item 6 - PERFORMANCE-BASED FEES AND SIDE BY SIDE MANAGEMENT Skybound USA does not charge performance-based fees. Item 7 - TYPES OF CLIENTS 14  We generally provide investment advice to the individuals who are seeking investment management and financial planning. Our service may also be suitable for: • Pension and profit-sharing plans • Trusts, estates Item 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Method of Analysis and Investment Strategies A critical component of Skybound USA’s investment philosophy is the perspective that wealth management and investing should be financial planning-led disciplines. Accordingly, the specific strategy we recommend and/or implement is based on each client’s specific situation. As part of our fiduciary duty to clients, we constantly endeavour to put our client's interests first. In selecting new underlying positions and/or third party managers for our portfolios and evaluating those currently used, we utilize an Investment Committee to review factors including but not limited to, internal costs, expense ratios, diversification, liquidity, benchmarks, and tracking error. Your Adviser Representative conducts an initial financial analysis which looks at your personal circumstances, risk tolerance, the suitability of various investments, and your financial goals. Each Advisory Representative conducts their own analysis to determine the most appropriate model portfolio and asset allocation they will use in a client’s portfolio. Skybound USA provides model portfolios that are constructed by the Investment Committee and has entered into agreements with third party managers acting as sub-advisors to Skybound USA. Additionally, the third-party managers provide model portfolios, tools to analyze a client’s situation, model investment strategies and asset allocations. Once your Adviser Representative decides as to which model portfolio or strategy might best meet your investment objective, a recommendation is made to purchase those assets or enroll in that strategy. Your Adviser Representative uses a variety of financial planning tools and software to evaluate the likelihood that your investment objectives will be met. These tools are also used to determine whether investment changes are warranted in light of changes in the parameters contained in your financial plan. Third Party Managers: Please refer to the third-party service provider’s Form ADV and/or associated disclosure documents for details on their investment strategies, methods of analysis and associated risks. The risks with utilizing third party managed programs include: • Market and economic risk. • The risk the third-party manager is not managing to the objective or managing based on the stated strategy. • The risk of the securities managed by the third-party manager will decline or fluctuate, impacting the overall performance of the portfolio. • The risk that the performance of the portfolio will be diminished by the fees of the third-party manager and expenses associated with the securities. • Additional layer of fees. Risk of Loss Clients should understand that past performance is not indicative of future results. Therefore, current and prospective clients (including you) should never assume that the future performance of any specific investment or investment strategy will be profitable. Investing in securities involves the risk of loss. Further, depending on 15  the different types of investments, there will be varying degrees of risk. Clients and prospective clients should be prepared to bear investment loss, including loss of original principal. Because of the inherent risk of loss associated with investing, the Firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated when investing in securities. Market Risk. Either the stock market as a whole or the value of an individual company as a result of moves in the overall market goes down, resulting in a decrease in the value of client investments. This is also referred to as systemic risk. Equity (stock) market risk. Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. Company Risk. When investing in stock positions, there is always a certain level of company or industry-specific risk inherent in each investment. This is also called unsystematic risk and can be reduced through appropriate diversification. The risk is that the company will perform poorly or decrease its value based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavourable media attention for its actions, the value of the company may be reduced. Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk of inflation eroding their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. ETF and Mutual Fund Risk. When we invest in an ETF or mutual fund for a client, the client will bear additional expenses based on its pro rata share of the ETF or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients will also incur brokerage costs when purchasing ETFs. Sometimes, the Firm utilizes mutual funds issued by Dimensional Fund Advisors (DFA). DFA funds are generally only available through registered investment advisors approved by DFA. Restrictions regarding additional purchases of, or reallocation among, other DFA funds will generally apply if you terminate our services and self-manage your account(s) or transition to another advisor who has not been approved by DFA to utilize DFA funds Tax Harvesting Risk. One trading strategy employed in client accounts is tax harvesting. This strategy intends to sell an ETF or mutual fund at a taxable loss and replace those positions with a holding whose historical performance and expected future performance are similar, thereby having little impact on the overall strategic allocation but capturing the tax loss. Because past performance is no indication of future performance, there is potential for the future performance of the replacement position to deviate from that of the initial holding. This strategy may also increase the frequency of trading and transaction costs. Management Risk. Actively managed client account performance can depend on the investment skills and abilities of the portfolio manager(s) to develop and implement strategies to achieve a mandated objective. The subjectivity of the analysis and implementation can result in the client account incurring losses or missing profitable opportunities that may have otherwise been capitalized. Values-based or Environmental, Social, and Governance Fund (“ESG”) Based Investing Risk. When directed by the client, thematic or ESG-based investments may be included in the client’s portfolio. It is important to note that fund managers consider ESG factors to varying degrees. Not every fund incorporates ESG factors in the same manner or degree, which can cause difficulty comparing different funds. As such, there is no standard matrix or benchmark upon which ESG factors affecting performance can be compared. ESG funds may include or exclude 16  securities based on ESG practices vs. other investment methodologies, impacting performance, fund expenses, and investment risk. We base our ESG recommendations on the information provided to us by the issuers. Digital Assets Risk. Digital assets represent an emerging asset class that has not been fully defined. There remains an overwhelming lack of clarity regarding the regulatory framework that will ultimately govern this investing sector. Additionally, a considerable list of risk factors carries their own range of probability and impact possibilities. Those risks include but are not limited to valuation risk; liquidity risk; volatility risks; technology risk; and legal, tax, and regulatory risk. Foreign Exchange Risk. Also known as FX risk or currency risk, refers to the losses that an international financial transaction may incur due to currency fluctuations. This creates a risk that the investment's value may decrease due to changes in the relative value of the currencies involved. Skybound USA may engage in these types of transactions for our clients, however, the client understands that they are assuming the risk, not Skybound USA. Cybersecurity Risk. Skybound USA and it’s service providers on whom it relies depend on complex information technology and communications systems to conduct business functions. These systems are subject to a number of different threats or risks that could adversely affect clients and their managed assets, despite the effort, Skybound USA and its service providers adopt in technologies, processes, and practices intended to mitigate these risks and protect the security of their computer systems, software, networks, and other technology assets, as well the confidentiality, integrity, and availability of information belonging to the clients and/or their investors. For example, unauthorized third parties may attempt to access, modify, disrupt the operations of, or prevent access to these systems of Skybound USA and/or its service providers on whom Skybound USA relies for data within these systems. Third parties may also attempt to fraudulently induce employees, customers, third-party service providers, or other users of systems to disclose sensitive information and gain access to Skybound USA’s data or that of its clients. A successful penetration of the security of Skybound USA’s systems or its service providers on whom Skybound USA relies on could result in the loss or theft of a client’s data or funds, the inability to access electronic systems, loss or theft of proprietary information or corporate data, physical damage to a computer or network system or costs associated with system repairs. Such incidence could cause Skybound USA or its service providers on whom it relies on to incur regulatory penalties, reputational damage additional compliance costs, or financial loss. Business Continuity Risk. Skybound USA has adopted a business continuation strategy to maintain critical functions in the event of a partial or total building outage affecting our offices or a technical problem affecting applications, data centers, or networks. The recovery strategies are designed to limit the impact on clients from any business interruption or disaster. Nevertheless, our ability to conduct business can be curtailed by a disruption in the infrastructure that supports our operations. Item 9 - DISCIPLINARY INFORMATION Skybound USA has an obligation to disclose to you any legal or disciplinary events involving Skybound USA or any of its supervised persons, including your Adviser Representative, which would be material to your evaluation of Skybound USA and the services it provides. There are no legal or disciplinary events to disclose. Additional disclosure about any disciplinary event involving your Adviser Representative is included in Part 2B of Form ADV. A copy of your Adviser Representative’s Part 2B will be furnished to you at no charge upon request. Item 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Skybound USA does not engage in any other business other than the delivery of investment advisory services, as described herein. Your Adviser Representative may be licensed as an insurance agent in connection with making offers and sales to you of life insurance and annuity products issued by life insurance companies as part of your financial plan. Except for these licenses, an Adviser Representative does not engage in any other financial industry 17  activity other than activities related to the distribution of wealth management services to you, nor is an Adviser Representative affiliated with any other financial service provider. Skybound USA is an affiliate of the following companies that are engaged in a financial services business and that are involved in Skybound USA’s delivery of investment advisory and /or financial planning services to clients: Skybound Wealth Management SA Skybound Wealth Management SA, a company organized in Skybounditzerland (“Skybound USA Skybounditzerland”), is a member of the Association Romande des Intermediaires Financiers (ARIF), a Skyboundiss self-regulatory for independent asset managers. Skybound Insurance Brokerage Ltd Skybound Insurance Brokers Ltd is a company registered in Cyprus under reference number HE 424935 and is authorised by the Insurance Company Controls Service under licence number 6940. Skybound Insurance Brokerage LLC Skybound Insurance Brokerage LLC is authorised by the Central Bank of UAE. Regulatory Details: Insurance Authority Registration Number 251. SWM Financial Planning SA SWM Financial Planning SA is registered by the Association Romande Des Intermediaires Financiers. Third Party Manager Relationship As stated under Item 4, Advisory Business above, Skybound USA recommends other investment advisers (i.e., discretionary managers, third-party managers, and third-party service providers). Skybound USA and your advisory representative do not share a portion of the advisory fees you pay to the third-party service providers for their services. Fees paid to third-party service providers are separate from the fees paid to Skybound USA. Skybound USA’s and your advisory representative’s fee is in addition to the third-party manager fee. The third- party managers will calculate and deduct Skybound USA’s and your advisory representative’s fee from your account and remit the fees to Skybound USA. Refer to Item 5 above for disclosure of fees. Advisory fees are paid to Skybound USA, to the management platform, and to any third-party manager or strategists used to manage your account. Item 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Skybound USA has a fiduciary duty to you to act in your best interest and to always place your interests ahead of its own. Skybound USA takes its compliance and legal obligations seriously and requires all persons for which it has supervisory responsibility in connection with its business as an investment adviser to comply with policies and procedures it has adopted under its Code of Ethics. The principal objective of the Code of Ethics is to ensure that neither Skybound USA nor any of its access persons misuse material non-public information that might have come into their possession or to which they might have become privy in the course of conducting investment 18  advisory activities on behalf of Skybound USA or the business of Skybound USA. In addition, the policies and procedures in the Code of Ethics are designed to ensure that Skybound USA advisory personnel and other access persons do not engage in personal securities transactions that would disadvantage and result in material harm to Skybound USA clients. To accomplish these objectives, the Code of Ethics contains provisions for standards of business conduct in order to comply with federal securities laws, personal securities reporting requirements, pre-approval procedures for certain transactions, code violations reporting requirements, and safeguarding of material non-public information about your transactions. Among other procedures, Skybound USA maintains a list of all securities holdings for its associated persons and has adopted procedures to supervise the trading activities of associated persons who have knowledge of your transactions and their related family accounts at least quarterly. Further, associated persons are prohibited from trading on non-public information or sharing such information. Item 12 - BROKERAGE PRACTICES Skybound USA does not maintain custody of your assets, although we are deemed to have custody of your assets if you give us authority to withdraw our advisory fee directly from your managed account. Additionally, Skybound USA will be deemed to have custody in certain situations involving standing letters of authorization and if you give us authority to transfers funds or securities between your accounts. (See Item 15-Custody, below.) Your assets must be maintained in an account at a “qualified custodian”. Generally, a qualified custodian is a broker/dealer or bank. We recommend one of the qualified custodians for our clients. We recommend Charles Schwab & Co., Inc. (Schwab), a registered brokerdealer, member SIPC, for all US based clients. For US connected persons living outside the United States, we recommend Interactive Brokers, LLC (IB) because of their ability to have multi- currencies and countries. However, Schwab accepts many clients living in various countries as well. We are independently owned and operated and are not affiliated with Schwab or IB. Schwab and IB will hold your assets in a brokerage account and buy and sell securities when we and/or you instruct them to. While we recommend that you use Schwab or IB as custodian/broker, you will decide whether to do so and will open your account with Schwab and/or IB by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. We do not open the account for you, although we will assist you in doing so. If you do not wish to place your assets with Schwab, IB, or another qualified custodian with which we have a relationship, then we cannot manage your account. Therefore, the services provided by Skybound USA could be limited to only advice and will not include implementation. The ability to select another broker/dealer and custodian will depend on the ability for Skybound USA to obtain trade information and supervise the activities of its Advisory Representatives. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor. Even though your account is maintained at Schwab or IB, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). Schwab and IB will act solely as a broker/dealer and custodian and not as an investment adviser to you. The firms will have no discretion over your account and will act solely on instructions it receives from Skybound USA or you. Schwab and IB have no responsibility for our services and undertakes no duty to you to monitor our management of your account or other services we provide to you. How We Select Brokers/Custodians. We seek to select a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their 19  services. We consider a wide range of factors, including, among others, these: • Ability to service you and us • Combination of transaction execution services along with asset custody services (generally without a separate fee for custody) • Capability to execute, clear and settle trades (buy and sell securities for your account) • Capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of investment products made available (stocks, bonds, mutual funds, exchange traded funds (ETFs), etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them • Industry reputation, staying power as a company, financial strength and viability • Technology and educational resources • Confidentiality and security of your information • Availability of other products and services that benefit us, as discussed below (see “Products and services available to us”) Your brokerage and trading costs For our clients’ accounts that Schwab and IB maintain, Schwab and IB generally do not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your account. Certain trades (for example, many mutual funds, and U.S. exchange-listed equities and ETFs) may not incur commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. In cases where we choose to execute a trade with different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab or IB account, the firm charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, to minimize your trading costs, we have the firm where your account is held execute most trades for your account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trade through Schwab or IB, we have determined that having the firm where your account is custodied execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/ custodians”). By using another broker or dealer you may pay lower transaction costs. Products and services available to us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through our firm. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available at no charge to us. Following is a more detailed description of Schwab’s support services: 20  Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, record keeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab, we would be required to pay for these services from our own resources. Our interest in Schwab’s services. The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/custodians”) and not Schwab’s services that benefit only us. There is an incentive for Skybound USA and the Advisory Representatives to recommend a broker/dealer over another based on the products and services that will be received rather than your best interest. Therefore, it is possible clients pay commissions higher than those charged by other broker/dealers in return for the products and services received by Skybound USA and/or its Advisory Representatives. The products and services Skybound 21  USA and its Advisory Representatives receive from the broker/dealer or account custodian will be used to benefit all clients including those clients who elect to maintain their accounts elsewhere. Aggregated Trading Procedure When appropriate, your Advisory Representative will aggregate (“bunch”) transactions in the same security on behalf of more than one client in an effort to strive for best execution and to possibly reduce the price per share and/or other costs to clients. However, aggregated or bunched orders will not reduce the transaction costs to participating clients. Skybound USA conducts aggregated transactions in a manner designed to ensure that no participating client is favored over another client. Participating clients will obtain the average price per share for the security executed that day. To the extent the aggregated order is not filled in its entirety and when possible, securities purchased or sold in an aggregated transaction will be allocated on a random basis. Under certain circumstances, the amount of securities is increased or decreased to avoid holding odd-lot or a small number of shares for particular clients. Item 13 - REVIEW OF ACCOUNTS If you are participating in the Asset Management program, or ongoing planning or consulting, you will be invited to participate in at least an annual review or as agreed by you and your Advisory Representative. You may request more frequent reviews and set thresholds for triggering events that would cause a review to take place. Your Advisory Representative will monitor for changes or shifts in the economy, changes to the management and structure of a mutual fund or company in which your assets are invested, and market shifts and corrections. If you are participating in Financial Planning only you will not receive regular reviews unless predetermined and agreed between you and your Advisory Representative. Skybound USA recommends you have at least an annual review and update to any plans. However, the time and frequency of the reviews is solely your decision. Additionally, you will be charged review fees based on the fee schedule disclosed under the program. Other than the initial plan or analysis, there will be no other reports issued. Your Advisory Representative will conduct your account review. Please refer to your Advisory Representative’s Form ADV Part 2B for important biographical information. You must notify your Advisory Representative promptly of any changes to your financial goals, objectives or financial situation as such changes may require him review the portfolio allocation and make recommendations for changes. For US based accounts, you will be provided statements at least quarterly direct from the account custodian. Additionally, you will receive confirmations of all transactions occurring direct from the account custodian. UK pension assets you will generally receive an annual valuation and can request more frequent valuations from your advisory representative or access your account online. Item 14 - CLIENT REFERRALS AND OTHER COMPENSATION We receive an economic benefit from Schwab and Interactive Brokers (IB) in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab and IB. Additionally, we receive similar support products and services from some of the third-party managers we utilize. We benefit from the products and services provided because the cost of these services would otherwise be borne directly by us, and this creates a conflict. You should consider these conflicts of interest when selecting a custodian. These products and services, how they benefit us, and the related conflicts 22  of interest are described above (see Item 12—Brokerage Practices). The Advisory Representatives have a direct incentive in the advisory fees being charged since a portion of the advisory fee collected by Skybound USA will be paid to the Advisory Representative for compensation for advisory services. In other words, Advisory Representatives share in the fees charged to you by Skybound USA. Item 15 - CUSTODY In the United States, Skybound USA uses unaffiliated banks and/or registered broker-dealers to hold client assets. Each custodian is a qualified custodian within the meaning of Rule 206(4)-2 under the Investment Advisers Act. Although Skybound USA does not maintain custody of funds and securities held in a client’s account, Skybound USA is deemed to have custody when it has the authority to deduct investment advisory fees directly from a client’s account and when it has the authority to transfer funds or securities between a client’s accounts pursuant to standing letters of authorization provided by this client. Clients receive quarterly account statements directly from the qualified custodian for the accounts. Each client is advised to carefully review these statements and compare them with statements received from Skybound USA to ensure that there are no material discrepancies in the information provided. Skybound USA believes that the safety of U.K. pension assets is one of the paramount considerations in selecting an adviser for your UK pension transfers and subsequent management. Skybound USA does not take custody of any client assets and utilizes the services of non-US financial institutions to safe-keep your assets and to provide administrative services for your account. Each financial institution serving as custodian is a qualified custodian within the meaning of Rule 206(4)-2 under the Investment Advisers Act. A financial institution acting as custodian or administrator charges separate fees to provide these services to you. Item 16 - INVESTMENT DISCRETION Based on your advisory agreement you may opt for your account to be managed on a discretionary basis. Discretionary authority authorizes Skybound USA and your Advisory Representative the authority to buy, sell, exchange and convert securities in your managed accounts and to engage, terminate, or replace Third-Party Service Providers. You will grant such authority by execution of the client advisory agreement. You may terminate discretionary authorization at any time upon receipt of written notice by Skybound USA. Discretionary authority will be limited to Skybound USA and your Advisory Representative having the authority to determine the securities to be bought or sold for a client’s account, the amount of securities to be bought or sold for a client’s account, and the Third-Party Service Providers on your account. Additionally, you are advised that: 1) You may set parameters with respect to when accounts should be rebalanced and set trading restrictions or limitations; 2) Your written consent is required to establish any brokerage account; 3) With the exception of deduction of Skybound USA’s advisory fees from the account, if you have authorized automatic deductions, Skybound USA will not have the ability to withdraw your funds or securities from the account. 4) Skybound USA will not have authority to remove or transfer funds or assets out of your account without your authorization with the exception of deduction of advisory fees from your account. 23  Item 17 - VOTING CLIENT SECURITIES Skybound USA does not have, and will not accept, authority to vote the securities held in your account. The custodian for your account sends proxies or other solicitations for the voting of securities held in your account directly to you. If a proxy or other solicitation is sent directly to Skybound USA, it is Skybound USA’s policy to promptly remit this proxy or other solicitation to you. Although you may contact your Adviser Representative about questions you may have about the voting of securities held in your account, the decision about how to vote any proxy rests solely with you. Item 18 - FINANCIAL INFORMATION Skybound USA does not require any client to prepay more than $1,200, six months or more in advance of receiving the investment advisory services to be provided to this client. Skybound USA does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Skybound USA has not been the subject of a bankruptcy petition in the past ten years or at any time in its operating history. 24