Smallwood Wealth Management

Smallwood Wealth Investment Management, LLC d/b/a Smallwood Wealth Management Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Smallwood Wealth Investment Management, LLC. If you have any questions about the contents of this brochure, please contact us at (732) 542-1565 or by email at: johnl@smallwoodwealth.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. Additional information about Smallwood Wealth Investment Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Smallwood Wealth Investment Management, LLC’s CRD number is: 288663. 199 Broad Street Red Bank, NJ 07701 (732) 542-1565 johnl@smallwoodwealth.com https://smallwoodassociates.com Registration does not imply a certain level of skill or training. Version Date: 03/13/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Smallwood Wealth Investment Management, LLC on 03/6/2025 are described below. Material changes relate to Smallwood Wealth Investment Management, LLC’s policies, practices or conflicts of interests. • Smallwood Wealth Investment Management has updated our AUM in Item 4 as of 12/31/2025 • Edward E. Bao, Jr. is no longer associated with Smallwood Wealth Management • Kaitlyn Galgano is no longer associated with Smallwood Wealth Management • Smallwood Wealth Investment Management LLC updated its Outside Business Activity • Smallwood Wealth Investment Management LLC updated the fees for the Wealth Curve™ Blueprint • Smallwood Wealth Investment Management LLC updated the range of fixed fees for Financial Planning • Smallwood Wealth Investment Management LLC created a “Service Only” category for smaller account balances. See Item 13 for details on review practices for these accounts. • Smallwood Wealth Investment Management LLC updated its disclosure to clarify that it may engage sub- advisers or third-party managers to implement specialized investment strategies when appropriate for clients. • Referral compensation may be received in connection with client referrals for life settlement transactions. ii  Item 3: Table of Contents Item 1: Cover Page……………………………………………………………………………………………………i Item 2: Material Changes ............................................................................................................................................ ii Item 3: Table of Contents .......................................................................................................................................... iii Item 4: Advisory Business........................................................................................................................................... 2 A. Description of the Advisory Firm ....................................................................................................................... 2 B. Types of Advisory Services ................................................................................................................................ 2 Pension Consulting Services ................................................................................................................................... 2 C. Client Tailored Services and Client Imposed Restrictions ................................................................................. 4 D. Wrap Fee Programs ............................................................................................................................................ 4 E. Assets Under Management ................................................................................................................................. 4 Item 5: Fees and Compensation .................................................................................................................................. 5 A. Fee Schedule ...................................................................................................................................................... 5 Pension Consulting Services Fees ........................................................................................................................... 5 B. Payment of Fees ................................................................................................................................................. 6 Payment of Pension Consulting Services Fees ........................................................................................................ 6 C. Client Responsibility For Third Party Fees ........................................................................................................ 6 D. Prepayment of Fees ............................................................................................................................................ 7 E. Outside Compensation For the Sale of Securities to Clients .............................................................................. 7 Item 6: Performance-Based Fees and Side-By-Side Management .............................................................................. 8 Item 7: Types of Clients .............................................................................................................................................. 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ......................................................................... 8 A. Methods of Analysis and Investment Strategies ................................................................................................ 8 B. Material Risks Involved..................................................................................................................................... 9 C. Risks of Specific Securities Utilized ................................................................................................................. 9 Item 9: Disciplinary Information ............................................................................................................................... 10 A. Criminal or Civil Actions ................................................................................................................................ 10 B. Administrative Proceedings ............................................................................................................................. 11 C. Self-regulatory Organization (SRO) Proceedings ........................................................................................... 11 iii  Item 10: Other Financial Industry Activities and Affiliations ................................................................................... 11 A. Registration as a Broker/Dealer or Broker/Dealer Representative .................................................................. 11 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor .............................................................................................................................................................................. 11 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ............... 12 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ....... 14 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............................. 15 A. Code of Ethics ................................................................................................................................................. 15 B. Recommendations Involving Material Financial Interests .............................................................................. 15 C. Investing Personal Money in the Same Securities as Clients .......................................................................... 15 D. Trading Securities At/Around the Same Time as Clients’ Securities .............................................................. 15 Item 12: Brokerage Practices .................................................................................................................................... 16 A. Factors Used to Select Custodians and/or Broker/Dealers .............................................................................. 16 1. Research and Other Soft-Dollar Benefits ......................................................................................................... 16 2. Brokerage for Client Referrals ......................................................................................................................... 16 3. Clients Directing Which Broker/Dealer/Custodian to Use ............................................................................... 16 B. Aggregating (Block) Trading for Multiple Client Accounts ............................................................................ 16 Item 13: Review of Accounts .................................................................................................................................... 17 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ................................................ 17 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ........................................................... 17 C. Content and Frequency of Regular Reports Provided to Clients ..................................................................... 17 Item 14: Client Referrals and Other Compensation .................................................................................................. 18 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ................................................................................................................................................................... 18 B. Compensation to Non – Advisory Personnel for Client Referrals ................................................................... 20 Item 15: Custody ....................................................................................................................................................... 20 Item 16: Investment Discretion ................................................................................................................................. 20 Item 17: Voting Client Securities (Proxy Voting) ...................................................................................................... 20 Item 18: Financial Information ................................................................................................................................. 21 A. Balance Sheet .................................................................................................................................................. 21 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ........ 21 iv  C. Bankruptcy Petitions in Previous Ten Years ........................................................................................................ 21 v  Item 4: Advisory Business A. Description of the Advisory Firm Smallwood Wealth Investment Management, LLC d/b/a Smallwood Wealth Management (hereinafter “SWIM”) is a Limited Liability Corporation organized in the State of New Jersey. The firm was formed in May 2017, and the principal owner is John L. Smallwood. B. Types of Advisory Services Portfolio Management Services SWIM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SWIM 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: Personal investment policy Asset selection • • • Investment strategy Asset allocation Risk tolerance • • • Regular portfolio monitoring SWIM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SWIM 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. SWIM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SWIM’s economic, investment or other financial interests. To meet its fiduciary obligations, SWIM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SWIM’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 SWIM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Pension Consulting Services SWIM offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) /403B plans). Pension consulting may include, but is not limited to: o identifying investment objectives and restrictions 2  o providing guidance on various assets classes and investment options o recommending money managers to manage plan assets in ways designed to achieve objectives o monitoring performance of money managers and investment options and making o recommendations for changes recommending other service providers, such as custodians, administrators and broker- dealers o creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. 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 SWIM generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities. SWIM may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. 3  C. Client Tailored Services and Client Imposed Restrictions SWIM 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 SWIM from properly servicing the client account, or if the restrictions would require SWIM to deviate from its standard suite of services, SWIM reserves the right to end the relationship. Clients with smaller account balances may be placed in a “Service Only” category. See Item 13 for details on review practices for these accounts. D. Wrap Fee Programs SWIM participates in wrap fee programs, which are investment programs where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. SWIM manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than non-wrap fee accounts. Fees paid under the wrap fee program will be given to SWIM as a management fee. E. Assets Under Management SWIM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $338,980,176 December 2025 $0 4  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fee $0 - $750,000 1.55% $750,001 - $2,000,000 1.35% $2,000,001 - $5,000,000 1.05% $5,000,001 - $10,000,000 0.85% $10,000,001 - $30,000,000 0.60% $30,000,001 - and up 0.50% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of SWIM's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Pension Consulting Services Fees The rate for pension consulting services is between 0.50% - 1.55% of the plan assets for which SWIM is providing such consulting services. These fees are negotiable. Financial Planning Fees Fixed Fees The negotiated initial fixed rate for creating client financial plans is between $1,050 and $14,000. Additionally, the fee for ongoing updates is between $450 and $6,500. Hourly Fees 5  The negotiated hourly fee for these services is between $200 and $525. Clients may terminate the agreement without penalty, for full refund of SWIM’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. Fees are paid in advance. SWIM calculates advisory fees using the value of the assets in the client’s account as of the last business day of the prior calendar quarter. Fees are billed quarterly in advance based on that valuation. In addition to the standard quarterly billing, the firm applies a cash flow true-up process at each billing cycle to account for significant account activity that occurred during the prior quarter. The firm reviews deposits and withdrawals made since the previous quarterly billing run. For any individual transaction that equals or exceeds five percent (5%) of the account’s value, a prorated adjustment is calculated for the remainder of that quarter. Deposits result in an additional prorated fee and withdrawals result in a prorated rebate. These adjustments are applied at the same time as the standard quarterly billing and are reflected in the net fee appearing on the client’s statement. For new clients whose accounts are established mid-quarter, the first billing cycle may include both the standard quarterly fee in advance and a prorated charge for the number of days the account was active during the prior quarter. Payment of Pension Consulting Services Fees Pension consulting fees are withdrawn directly from the client’s accounts with client’s written authorization on a quarterly basis. Fees are paid in advance. Payment of Financial Planning Fees Financial planning fees are paid via check. Fixed financial planning fees are paid in advance, but never more than six months in advance. Hourly financial planning fees are paid in advance, but never more than six months in advance C. Client Responsibility For Third Party Fees 6  SWIM will wrap third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). SWIM will charge clients one fee, and pay all transaction fees using the fee collected from the client. D. Prepayment of Fees SWIM collects fees in advance. Refunds for fees paid in advance will be returned within fourteen days to the client via check. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. 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 John L. Smallwood, Robert D. Marks, Christopher J. Smallwood, Jared R. Smallwood, and John L. Smallwood, Jr. are registered representatives of a broker-dealer. John L. Smallwood, Robert D. Marks, Christopher J. Smallwood, Jared R. Smallwood, and John L. Smallwood, Jr. are insurance agents. In these roles, they accept compensation for the sale of investment products to SWIM clients. 1. This is a Conflict of Interest Supervised persons may accept compensation for the sale of investment products, including asset based sales charges or service fees from the sale of mutual funds to SWIM's clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of investment products for which the supervised persons receives compensation, SWIM will document the conflict of interest in the client file and inform the client of the conflict of interest. 2. Clients Have the Option to Purchase Recommended Products From Other Brokers Clients always have the option to purchase SWIM recommended products through other brokers or agents that are not affiliated with SWIM. 7  3. Commissions are not SWIM's primary source of compensation for advisory services Commissions are not SWIM’s primary source of compensation for advisory services. 4. Advisory Fees in Addition to Commissions or Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management SWIM 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 SWIM generally provides advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ ❖ Pension and profit-sharing plans (other than plan participants) Charitable Organization There is no account minimum for any of SWIM’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis SWIM’s methods of analysis include Modern portfolio theory. 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. Investment Strategies 8  SWIM uses long term trading. 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 Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment 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. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized 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 9  and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. 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. 10  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. Allegations claimant allege it was an unaccredited investor and therefore, unsuitable for the 1031 program in question. Damage amount requested $1,411,403.78 settlement amount $90,000.00 broker comment this matter involved a complex strategy related to investments in tenant in common properties. The investment product and the investment strategy were entirely suitable, particularly in light of the subsequent unique and unforeseen circumstances beyond the registered representative's control, such as the customer's choice to change its corporate business structure and the death of the founder. The strategy resulted in significant tax savings and return on investment that would not have been realized had the strategy not been implemented. In fact the family retained more than $1 million that they otherwise would have parted with. Nonetheless, the matter was settled at mediation because it was less costly than proceeding to a full adjudication on the merits of the case. 9/13/2012 customer dispute settled allegations client alleges unsuitability of recommendations, breach of fiduciary duty and negligence damage amount requested $400,000.00 settlement amount $97,500.00 broker comment i did not contribute to the settlement. This suit was settled in lieu of the cost and nuisance of a continued defense. The matter was entirely meritless. In fact, prior to the client's second divorce, I worked extensively with her attorney to secure an additional $2,000,000 in divorce proceeds and created a financial plan that (had it been adhered to) would have provided sustainable monthly income. Despite this, the client chose to live well beyond her means, continually failing to head my advice to ratchet back her spending and lifestyle. Rather than accept the responsibility for her choices, she chose to augment her income by filing suits against the many professionals that laid the groundwork for what should have been her financial security. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative As a registered representative of Regulus Financial Group LLC, John L. Smallwood accepts compensation for the sale of securities. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither SWIM 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 John L. Smallwood Sr. is a registered representative of Regulus Financial Group LLC. From time to time, he will offer clients advice or products from this activity. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. Smallwood Wealth Investment Management, LLC always acts in the best interest of the client; including in the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services any representative of Smallwood Wealth Investment Management, LLC in such individual's outside capacity. John L. Smallwood Sr. is Co-owner of Smallwood Associates, LTD. a financial services firm engaged in providing financial advice, implementing life insurance, disability insurance, Long term Care Insurance. He is a licensed insurance agent. From time to time, he will offer clients advice or products from this activity. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. Smallwood Wealth Investment Management, LLC always acts in the best interest of the client; including in the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of Smallwood Wealth Investment Management, LLC in their capacity as a licensed insurance agent. John L. Smallwood Sr. is Sole Owner of My Wealth Curve, LLC and software development company engaged in designing educational material for wealth management. The software is only offered to clients of Smallwood Wealth Investment Management, LLC. John L. Smallwood Sr. is Sole Owner of Money I$n’t podcast, YouTube channel and URL offered to the public to educate what money cannot do. Robert D. Marks is a registered representative of Regulus Financial Group LLC and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. SWIM always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of SWIM in such individual’s capacity as a registered representative. Robert D. Marks is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of SWIM are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. SWIM addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. SWIM periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other 12  benefits. SWIM will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by SWIM’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. is a wealth advisor at Smallwood Wealth Investment Management, LLC. Christopher J. Smallwood is a registered representative of Regulus Financial Group LLC and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. SWIM always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of SWIM in such individual’s capacity as a registered representative. Christopher J. Smallwood is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of SWIM are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. SWIM addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. SWIM periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. SWIM will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by SWIM’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. John L. Smallwood, Jr. is a registered representative of Regulus Financial Group LLC and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. SWIM always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of SWIM in such individual’s capacity as a registered representative. John L. Smallwood Jr. is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and 13  sale of insurance products by supervised persons of SWIM are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. SWIM addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. SWIM periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. SWIM will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by SWIM’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. Jared R. Smallwood is a registered representative of Regulus Financial Group LLC and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. SWIM always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of SWIM in such individual’s capacity as a registered representative. Jared R. Smallwood is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of SWIM are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. SWIM addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. SWIM periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. SWIM will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by SWIM’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. is a wealth advisor at Smallwood Wealth Investment Management, LLC. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections 14  Smallwood Wealth Management may engage sub-advisers or third-party managers to implement specialized investment strategies when such arrangements are appropriate for a client’s specific investment objectives and circumstances. Prior to engaging any sub-adviser or third-party manager, the client will receive full disclosure regarding the arrangement. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics SWIM 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. SWIM's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests SWIM does not recommend that clients buy or sell any security in which a related person to SWIM or SWIM has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of SWIM may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of SWIM to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. SWIM will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of SWIM may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of SWIM 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, SWIM will never engage in trading that operates to the client’s disadvantage if representatives of SWIM buy or sell securities at or around the same time as clients. 15  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on SWIM’s duty to seek “best-execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and SWIM may also consider the market expertise and research access provided by the broker dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in SWIM's research efforts. SWIM will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. SWIM will require clients to create an account with Charles Schwab & Co., Inc. Advisor Services. 1. Research and Other Soft-Dollar Benefits While SWIM has no formal soft dollars program in which soft dollars are used to pay for third party services, SWIM may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). SWIM 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 for it, and SWIM does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. SWIM benefits by not having to produce or pay for the research, products or services, and SWIM will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that SWIM’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals SWIM 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 SWIM will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts 16  SWIM does not aggregate or bunch the securities to be purchased or sold for multiple clients. This may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for SWIM's advisory services provided on an ongoing basis are reviewed at least Quarterly by John L Smallwood, President, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at SWIM are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by John L Smallwood, President. Financial planning clients are provided a onetime 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, SWIM’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of SWIM's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. SWIM will also provide at least quarterly a separate written statement to the client. Each financial planning client will receive the financial plan upon completion. D. “Service Only” Accounts For clients with accounts below a designated asset threshold, SWIM has implemented a “Service Only” category. These accounts will no longer be subject to regularly scheduled Annual Reviews. Instead, clients in this category may initiate contact as needed, and we will respond to and process service-related requests, including but not limited to: • Money movement; 17  • Address or contact information; • Beneficiary changes; • General account inquiries. Clients in the “Service Only” category will continue to receive firm-wide communications such as marketing and podcasts notifications, office updates, and regulatory notices. However, proactive outreach such as portfolio reviews or financial planning updates will not be conducted unless initiated by the client. This policy is designed to allocate resources efficiently while maintaining responsive service for all clients. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Charles Schwab & Co., Inc. Advisor Services Charles Schwab & Co., Inc. Advisor Services provides SWIM with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For SWIM client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to SWIM other products and services that benefit SWIM but may not benefit its clients’ accounts. These benefits may include national, regional or SWIM specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of SWIM by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist SWIM in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing 18  information and other market data, facilitate payment of SWIM’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of SWIM’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to SWIM other services intended to help SWIM manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to SWIM by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to SWIM. SWIM is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. Compensation Received for Client Referrals – Life Settlements The Firm receives compensation from Ashar Group, LLC in connection with client referrals made under the Referral Agreement. For each client whose life insurance policy is successfully sold through a life settlement or viatical settlement transaction in which Ashar serves as the broker, the Firm is entitled to receive a referral fee equal to fifty percent (50%) of Ashar’s net compensation from that transaction (the “Referral Fee”). Net compensation is calculated as the total fees and commissions received by Ashar from the client, less Ashar’s actual out-of-pocket expenses related to that transaction (including, without limitation, costs of obtaining medical records and life expectancy reports for the insured). The Referral Fee is paid to the Firm no later than ten (10) days after Ashar has received full payment from the client for its services. Conflicts of Interest The existence of this referral arrangement creates a potential conflict of interest. Because the Firm receives compensation when a client is referred to Ashar and a life settlement transaction is completed, the Firm has a financial incentive to recommend that clients consider life settlement transactions and to refer them to Ashar rather than to other life settlement brokers or service providers. We address this conflict in the following ways: • Client Consent: We will only refer a client to Ashar after obtaining that client’s written consent to the referral and to the sharing of their personal and policy-related information with Ashar. • Suitability: We will only suggest that a client explore a life settlement when we have a reasonable basis to believe, in our professional judgment, that doing so is consistent with the client’s overall financial plan, estate planning objectives, and insurance needs. • Disclosure: Clients will be informed that the Firm receives a referral fee in connection with any completed transaction and that this compensation creates a financial incentive. Clients are free to seek life settlement services from any provider of their choice. 19  • No Negotiation Role: The Firm does not negotiate settlement terms on behalf of clients, does not deliver offers or counteroffers, and does not represent clients in settlement transactions. Ashar serves solely as the client’s life settlement broker. Clients should be aware that they are not required to work with Ashar and may independently seek life settlement brokerage services from other licensed providers. Clients who elect to work with Ashar directly, without referral from the Firm, would not be subject to any referral fee arrangement between Ashar and the Firm. No Investment Advisory Services in Connection with Life Settlements The referral of a client to Ashar for life settlement services does not constitute the provision of investment advisory services by the Firm. Life insurance policies and life settlement transactions are not securities. The Firm’s referral activity in connection with this arrangement is conducted outside of, and is separate from, the Firm’s investment advisory services. Clients are encouraged to seek independent legal, tax, and insurance advice before entering into any life settlement or viatical settlement transaction. B. Compensation to Non – Advisory Personnel for Client Referrals SWIM may enter into written arrangements with third parties to act as solicitors for SWIM's investment management services. Solicitor relationships will be fully disclosed to each Client to the extent required by applicable law. SWIM will ensure each solicitor is exempt, notice filed, or properly registered in all appropriate jurisdictions. All such referral activities will be conducted in accordance with Rule 206(4)-1 under the Advisers Act, where applicable. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, SWIM 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 SWIM 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, SWIM 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) 20  SWIM 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 SWIM 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 SWIM nor its management has any financial condition that is likely to reasonably impair SWIM’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years SWIM has not been the subject of a bankruptcy petition in the last ten years. 21 

Smallwood Wealth Investment Management, LLC d/b/a Smallwood Wealth Management Wrap Fee Program Brochure This brochure provides information about the qualifications and business practices of Smallwood Wealth Investment Management, LLC. If you have any questions about the contents of this brochure, please contact us at (732) 542-1565 or by email at: johnl@smallwoodwealth.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. Additional information about Smallwood Wealth Investment Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Smallwood Wealth Investment Management, LLC’s CRD number is: 288663. 199 Broad Street Red Bank, NJ 07701 (732) 542-1565 johnl@smallwoodwealth.com https://smallwoodassociates.com Registration does not imply a certain level of skill or training. Version Date: 3/13/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Smallwood Wealth Investment Management, LLC on 03/6/2025 are described below. Material changes relate to Smallwood Wealth Investment Management, LLC’s policies, practices or conflicts of interests. 3 • Edward E. Bao, Jr. is no longer associated with Smallwood Wealth Management • Kaitlyn Galgano is no longer associated with Smallwood Wealth Management • Smallwood Wealth Investment Management LLC updated its Outside Business Activity • Smallwood Wealth Investment Management LLC updated the fees for the Wealth Curve™ Blueprint ii  3: Table of Contents Item 1: Cover Page Item 2: Material Changes .......................................................................................................................................................................................... ii Item 3: Table of Contents .......................................................................................................................................................................................... ii Item 4: Services Fees and Compensation ................................................................................................................................................................. 5 A. Description of Services..................................................................................................................................................................................... 5 B. Contribution Cost Factors ................................................................................................................................................................................ 6 C. Additional Fees ................................................................................................................................................................................................. 6 D. Compensation of Client Participation............................................................................................................................................................ 6 Item 5: Account Requirements and Types of Clients ............................................................................................................................................. 7 Item 6: Portfolio Manager Selection and Evaluation .............................................................................................................................................. 7 A. Selecting/Reviewing Portfolio Managers ............................................................................................................................................. 7 Standards Used to Calculate Portfolio Manager Performance ................................................................................................................... 7 Review of Performance Information .............................................................................................................................................................. 7 B. Related Persons ................................................................................................................................................................................................. 7 C. Advisory Business ............................................................................................................................................................................................ 8 Wrap Fee Portfolio Management ................................................................................................................................................................... 8 Performance-Based Fees and Side-By-Side Management ........................................................................................................................... 8 Services Limited to Specific Types of Investments ...................................................................................................................................... 8 Client Tailored Services and Client Imposed Restrictions .......................................................................................................................... 9 Wrap Fee Programs .......................................................................................................................................................................................... 9 Amounts Under Management ........................................................................................................................................................................ 9 Methods of Analysis and Investment Strategies .......................................................................................................................................... 9 Material Risks Involved ................................................................................................................................................................................... 9 Risks of Specific Securities Utilized ............................................................................................................................................................. 10 Voting Client Proxies ..................................................................................................................................................................................... 11 Item 7: Client Information Provided to Portfolio Managers ............................................................................................................................... 11 Item 8: Client Contact with Portfolio Managers ................................................................................................................................................... 12 Item 9: Additional Information ............................................................................................................................................................................... 12 A. Disciplinary Action and Other Financial Industry Activities ........................................................................................................... 12 Criminal or Civil Actions .............................................................................................................................................................................. 12 Administrative Proceedings.......................................................................................................................................................................... 12 Self-regulatory Organization Proceedings .................................................................................................................................................. 12 Registration as a Broker/Dealer or Broker/Dealer Representative ......................................................................................................... 13 Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor ............................ 13 iii  Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests .................................................... 13 Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections .......................................... 16 B. Code of Ethics, Client Referrals, and Financial Information ............................................................................................................ 16 Code of Ethics ................................................................................................................................................................................................. 16 Recommendations Involving Material Financial Interests ........................................................................................................................ 16 Investing Personal Money in the Same Securities as Clients .................................................................................................................... 16 Trading Securities At/Around the Same Time as Clients’ Securities ...................................................................................................... 17 Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ....................................................................................... 17 Factors That Will Trigger a Non-Periodic Review of Client Accounts .................................................................................................... 17 Content and Frequency of Regular Reports Provided to Clients ............................................................................................................. 17 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ............... 17 Compensation to Non – Advisory Personnel for Client Referrals ........................................................................................................... 18 Balance Sheet ................................................................................................................................................................................................... 18 Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ........................................ 19 Bankruptcy Petitions in Previous Ten Years ............................................................................................................................................... 19 iv  Item 4: Services Fees and Compensation Smallwood Wealth Investment Management, LLC d/b/a Smallwood Wealth Management (hereinafter “SWIM”) offers the following services to advisory clients: A. Description of Services SWIM participates in and sponsors wrap fee programs. Under these programs, SWIM wraps certain third-party fees (i.e., custodian fees, brokerage fees, and transaction fees) for wrap fee portfolio management accounts. SWIM charges clients a single advisory fee and pays these transaction costs from the advisory fee paid by the client. Because SWIM bears the cost of brokerage and transaction fees in wrap accounts, the firm has a financial incentive to limit trading activity in those accounts. Certain other fees are not included in the wrap fee and are paid separately by the client. These include, but are not limited to, mutual fund and exchange-traded fund internal expenses, margin costs, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. The fee schedule is set forth below: Total Assets Under Management Annual Fees $0 - $750,000 1.55% $750,001 - $2,000,000 1.35% $2,000,001 - $5,000,000 1.05% $5,000,001 - $10,000,000 0.85% $10,000,001 - $30,000,000 0.60% $30,000,001 - and up 0.50% These fees are negotiable depending upon the needs of the client and complexity of the situation and the final fee schedule is attached as Exhibit II of the client contract. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid quarterly in advance. Smallwood Wealth Management calculates advisory fees using the value of the assets in the client’s account as of the last business day of the prior calendar quarter. Fees are billed quarterly in advance based on that valuation. 5  In addition to the standard quarterly billing, the firm applies a cash flow true-up process at each billing cycle to account for significant account activity that occurred during the prior quarter. The firm reviews deposits and withdrawals made since the previous quarterly billing run. For any individual transaction that equals or exceeds five percent (5%) of the account’s value, a prorated adjustment is calculated for the remainder of that quarter. Deposits result in an additional prorated fee and withdrawals result in a prorated rebate. These adjustments are applied at the same time as the standard quarterly billing and are reflected in the net fee appearing on the client’s statement. For new clients whose accounts are established mid-quarter, the first billing cycle may include both the standard quarterly fee in advance and a prorated charge for the number of days the account was active during the prior quarter. Refunds are given on a prorated basis, based on the number of days remaining in the billing period on the effective date of termination. The fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the billing period up to and including the effective date of termination. (*The daily rate is calculated by dividing the annual fee by 365). Clients may terminate the contract without penalty, for full refund, within five business days of signing the contract. Thereafter, clients may terminate the contract with thirty days’ written notice. B. Contribution Cost Factors The program may cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program, including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if provided separately (which in turn depends on the prices and specific services offered by different providers). Smallwood Wealth Management enrolls all advisory clients in its wrap fee program and does not offer an alternative or reduced advisory fee schedule for clients who elect not to participate in the wrap fee program. As a result, clients do not have the option to receive advisory services outside of the wrap fee structure offered by the firm. C. Additional Fees Clients who participate in the wrap fee program will not have to pay for transaction or trading fees. D. Compensation of Client Participation Neither SWIM, nor any of its supervised persons, receives compensation in connection with the wrap fee program other than the advisory fees paid by clients for participation in the program. However, the total fees paid by a client participating in the wrap fee 6  program may be higher or lower than the fees the client would pay if the services included in the wrap fee program were purchased separately. Because SWIM receives advisory fees for accounts enrolled in the wrap fee program, the firm may have a financial incentive to recommend participation in the wrap fee program rather than recommending that a client obtain investment advisory services and brokerage services separately. Item 5: Account Requirements and Types of Clients SWIM generally provides its wrap fee program services to the following types of clients: Individuals High-Net-Worth Individuals Pension and profit-sharing plans (other than plan participants) ❖ ❖ ❖ ❖ Charitable Organization There is no account minimum for any of SWIM’s services. Item 6: Portfolio Manager Selection and Evaluation A. Selecting/Reviewing Portfolio Managers SWIM will not select any outside portfolio managers for management of this wrap fee program. SWIM will be the sole portfolio manager for this wrap fee program. Standards Used to Calculate Portfolio Manager Performance SWIM will use industry standards to calculate portfolio manager performance. Review of Performance Information SWIM reviews the performance information to determine and verify its accuracy and compliance with presentation standards. The performance information is reviewed quarterly and is reviewed by SWIM. B. Related Persons SWIM and its personnel serve as the portfolio managers for all wrap fee program accounts. This is a conflict of interest in that no outside adviser assesses SWIM’s management of the wrap fee program. However, SWIM addresses this conflict by acting in its clients’ best interest consistent with its fiduciary duty as sponsor and portfolio manager of the wrap fee program. 7  C. Advisory Business SWIM offers portfolio management services to its wrap fee program participants as discussed in Section 4 above. Wrap Fee Portfolio Management SWIM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SWIM creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Portfolio management includes, but is not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring SWIM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Portfolio management accounts participating in the wrap fee program will not have to pay for transaction or trading fees. SWIM will charge clients one fee, and pay transaction fees using the advisory fee collected from the client. Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that SWIM has an incentive to limit trading activities for those accounts since the firm absorbs those transaction costs. To address this conflict, SWIM will always act in the best interest of its clients consistent with its fiduciary duty as an investment adviser. Performance-Based Fees and Side-By-Side Management SWIM 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. Services Limited to Specific Types of Investments SWIM generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. 8  securities. SWIM may use other securities as well to help diversify a portfolio when applicable. Client Tailored Services and Client Imposed Restrictions SWIM offers the same suite of services to all of its clients. However, specific client financial plans 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) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. 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 SWIM from properly servicing the client account, or if the restrictions would require SWIM to deviate from its standard suite of services, SWIM reserves the right to end the relationship. Wrap Fee Programs SWIM sponsors and acts as portfolio manager for this wrap fee program. SWIM manages the investments in the wrap fee program but does not manage those wrap fee accounts any differently than non-wrap fee accounts. The fees paid to the wrap account program will be given to SWIM as a management fee. Amounts Under Management SWIM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $0 $338,980,176 December 2025 Methods of Analysis and Investment Strategies SWIM’s methods of analysis include Modern portfolio theory. 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. SWIM uses long term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Material Risks Involved 9  Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. 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. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Risks of Specific Securities Utilized 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 10  rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. 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 a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Voting Client Proxies SWIM 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 7: Client Information Provided to Portfolio Managers All client information material to managing the portfolio (including basic information, risk tolerance, sophistication level, and income level) is provided to the portfolio manager. The portfolio manager will also have access to that information as it changes and is updated. 11  Item 8: Client Contact with Portfolio Managers SWIM places no restrictions on client ability to contact its portfolio managers. SWIM’s representative, First Middle Last can be contacted during regular business hours and contact information is on the cover page of First Middle Last’s Form ADV Part 2B brochure supplement. Item 9: Additional Information A. Disciplinary Action and Other Financial Industry Activities Criminal or Civil Actions There are no criminal or civil actions to report. Administrative Proceedings There are no administrative proceedings to report. Self-regulatory Organization Proceedings There are no self-regulatory organization proceedings to report. Allegations claimant allege it was an unaccredited investor and therefore, unsuitable for the 1031 program in question. Damage amount requested $1,411,403.78 settlement amount $90,000.00 broker comment this matter involved a complex strategy related to investments in tenant in common properties. The investment product and the investment strategy were entirely suitable, particularly in light of the subsequent unique and unforeseen circumstances beyond the registered representative's control, such as the customer's choice to change its corporate business structure and the death of the founder. The strategy resulted in significant tax savings and return on investment that would not have been realized had the strategy not been implemented. In fact the family retained more than $1 million that they otherwise would have parted with. Nonetheless, the matter was settled at mediation because it was less costly than proceeding to a full adjudication on the merits of the case. 9/13/2012 customer dispute settled allegations client alleges unsuitability of recommendations, breach of fiduciary duty and negligence damage amount requested $400,000.00 settlement amount $97,500.00 broker comment i did not contribute to the settlement. This suit was settled in lieu of the cost and nuisance of a continued defense. The matter was entirely meritless. In fact, prior to the client's second divorce, i worked extensively with her attorney to secure an additional $2,000,000 in divorce proceeds, and created a financial plan that (had it been adhered to) would have provided sustainable monthly income. Despite this, the client chose to live well beyond her means, continually failing to head my advice to ratchet back her spending and lifestyle. Rather than accept the responsibility for her choices, she chose to augment her income by filing suits against the many professionals that laid the groundwork for what should have been her financial security. 12  Registration as a Broker/Dealer or Broker/Dealer Representative As a registered representative of Regulus Financial Group LLC, John L. Smallwood accepts compensation for the sale of securities. Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Neither SWIM nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests John L. Smallwood Sr. is a registered representative of Regulus Financial Group LLC. From time to time, he will offer clients advice or products from this activity. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. Smallwood Wealth Investment Management, LLC always acts in the best interest of the client; including in the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services any representative of Smallwood Wealth Investment Management, LLC in such individual's outside capacity. John L. Smallwood Sr. is Co-owner of Smallwood Associates, LTD. a financial services firm engaged in providing financial advice, implementing life insurance, disability insurance, Long term Care Insurance. He is a licensed insurance agent. From time to time, he will offer clients advice or products from this activity. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. Smallwood Wealth Investment Management, LLC always acts in the best interest of the client; including in the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of Smallwood Wealth Investment Management, LLC in their capacity as a licensed insurance agent. John L. Smallwood Sr. is Sole Owner of My Wealth Curve, LLC and software development company engaged in designing educational material for wealth management. The software is only offered to clients of Smallwood Wealth Investment Management, LLC. John L. Smallwood Sr. is Sole Owner of Money I$n’t podcast, YouTube channel and URL offered to the public to educate what money cannot do. Robert D. Marks is a registered representative of Regulus Financial Group LLC and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered 13  investment adviser. SWIM always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of SWIM in such individual’s capacity as a registered representative. Robert Marks is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of SWIM are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. SWIM addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. SWIM periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. SWIM will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by SWIM’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. is a wealth advisor at Smallwood Wealth Investment Management, LLC. Christopher J. Smallwood is a registered representative of Regulus Financial Group LLC and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. SWIM always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of SWIM in such individual’s capacity as a registered representative. Christopher J. Smallwood is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of SWIM are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. SWIM addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. SWIM periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. SWIM will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving 14  any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by SWIM’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. John L. Smallwood, Jr. is a registered representative of Regulus Financial Group LLC and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. SWIM always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of SWIM in such individual’s capacity as a registered representative. John L. Smallwood Jr. is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of SWIM are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. SWIM addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. SWIM periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. SWIM will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by SWIM’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. Jared R. Smallwood is a registered representative of Regulus Financial Group LLC and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. SWIM always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of SWIM in such individual’s capacity as a registered representative. 15  Jared R. Smallwood is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of SWIM are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. SWIM addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. SWIM periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. SWIM will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by SWIM’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. is a wealth advisor at Smallwood Wealth Investment Management, LLC. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections SWIM does not utilize nor select other advisors or third party managers. All assets are managed by SWIM management. B. Code of Ethics, Client Referrals, and Financial Information Code of Ethics We have 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. Our Code of Ethics is available free upon request to any client or prospective client. Recommendations Involving Material Financial Interests SWIM does not recommend that clients buy or sell any security in which a related person to SWIM or SWIM has a material financial interest. Investing Personal Money in the Same Securities as Clients 16  From time to time, representatives of SWIM may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of SWIM to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. SWIM will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of SWIM may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of SWIM 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, SWIM will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for SWIM's advisory services provided on an ongoing basis are reviewed at least Quarterly by John L Smallwood, President, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at SWIM are assigned to this reviewer. 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). Content and Frequency of Regular Reports Provided to Clients Each client will receive at least quarterly from the custodian, a written report that details the client’s account including assets held and asset value which will come from the custodian. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Charles Schwab & Co., Inc. Advisor Services provides SWIM with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the 17  adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For SWIM client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. information Charles Schwab & Co., Inc. Advisor Services also makes available to SWIM other products and services that benefit SWIM but may not benefit its clients’ accounts. These benefits may include national, regional or SWIM specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of SWIM by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist SWIM in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of SWIM’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of SWIM’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to SWIM other services intended to help SWIM manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to SWIM by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to SWIM. SWIM is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. Compensation to Non – Advisory Personnel for Client Referrals SWIM does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Balance Sheet 18  SWIM does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither SWIM nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. Bankruptcy Petitions in Previous Ten Years SWIM has not been the subject of a bankruptcy petition in the last ten years. 19