SPARTAN WEALTH ADVISORY SERVICES LLC

Spartan Wealth Advisory Services LLC Form ADV Part 2A – Disclosure Brochure Effective: July 23, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Spartan Wealth Advisory Services LLC (“Spartan Wealth Management” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (248) 297-6600 or by email at info@spartanwealth.com. Spartan Wealth Management is a registered investment advisor located in the U.S. Securities and Exchange Commission. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Spartan Wealth Management to assist you in determining whether to retain the Advisor. Additional information about Spartan Wealth Management and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 331719. Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Spartan Wealth Management. Spartan Wealth Management believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Spartan Wealth Management encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes Item 10 was updated for the addition of promoter agreements. Item 14 was updated to address the new transition bonus. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 331719. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (248) 297-6600 or by email at info@spartanwealth.com. Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 2  Item 3 – Table of Contents Item 2 – Material Changes ............................................................................................................................................. 2 Item 3 – Table of Contents ............................................................................................................................................ 3 Item 4 – Advisory Services ............................................................................................................................................ 4 A. Firm Information .................................................................................................................................................................... 4 B. Advisory Services Offered ..................................................................................................................................................... 4 C. Client Account Management ................................................................................................................................................. 5 D. Wrap Fee Programs .............................................................................................................................................................. 6 E. Assets Under Management ................................................................................................................................................... 6 Item 5 – Fees and Compensation ................................................................................................................................. 6 A. Fees for Advisory Services .................................................................................................................................................... 6 B. Fee Billing ............................................................................................................................................................................. 7 C. Other Fees and Expenses ..................................................................................................................................................... 7 D. Advance Payment of Fees and Termination .......................................................................................................................... 7 E. Compensation for Sales of Securities .................................................................................................................................... 8 Item 6 – Performance-Based Fees and Side-By-Side Management ........................................................................... 8 Item 7 – Types of Clients ............................................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................... 9 A. Methods of Analysis .............................................................................................................................................................. 9 B. Risk of Loss ........................................................................................................................................................................... 9 Item 9 – Disciplinary Information ................................................................................................................................ 11 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................... 12 A. Code of Ethics ..................................................................................................................................................................... 12 B. Personal Trading with Material Interest ............................................................................................................................... 12 C. Personal Trading in Same Securities as Clients .................................................................................................................. 12 D. Personal Trading at Same Time as Client ........................................................................................................................... 12 Item 12 – Brokerage Practices .................................................................................................................................... 13 A. Recommendation of Custodian[s] ........................................................................................................................................ 13 B. Aggregating and Allocating Trades ...................................................................................................................................... 13 Item 13 – Review of Accounts ..................................................................................................................................... 14 A. Frequency of Reviews ......................................................................................................................................................... 14 B. Causes for Reviews ............................................................................................................................................................ 14 C. Review Reports ................................................................................................................................................................... 14 Item 14 – Client Referrals and Other Compensation ................................................................................................. 14 A. Compensation Received by Spartan Wealth Management .................................................................................................. 14 B. Compensation for Client Referrals ....................................................................................................................................... 15 Item 15 – Custody ........................................................................................................................................................ 15 Item 16 – Investment Discretion ................................................................................................................................. 15 Item 17 – Voting Client Securities ............................................................................................................................... 16 Item 18 – Financial Information ................................................................................................................................... 16 Privacy Policy .............................................................................................................................................................. 17 Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 3  Item 4 – Advisory Services A. Firm Information Spartan Wealth Advisory Services LLC (“Spartan Wealth Management” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Michigan. The Advisor was founded in April 2024 and is owned by Spartan Wealth Management Inc. The Advisor is operated by E. Brian Mossallam (Chief Executive Officer), Anthony Mona (President), Steven Nofar (Treasurer), Joseph Mansoor (Vice President) Alexander Wagner (Vice President), and Derek Damian (Chief Investment Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Spartan Wealth Management. B. Advisory Services Offered Spartan Wealth Management offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Spartan Wealth Management's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Spartan Wealth Management provides customized wealth management services for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management services and a broad range of comprehensive financial planning. These services are listed below. Investment Management Services – Spartan Wealth Management provides discretionary investment management services. The Advisor works closely with each Client to identify their investment goals, objectives, risk tolerance and financial situation in order to create an overall portfolio strategy. The Advisor will then construct an investment portfolio primarily consisting of individual stocks, exchange-traded funds (“ETFs”), mutual funds, bonds, option contracts, alternative investments, or structured products to meet the needs of its Clients. The Advisor may retain Client’s legacy investments based on portfolio fit and/or tax considerations. Spartan Wealth Management’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Spartan Wealth Management will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Spartan Wealth Management evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Spartan Wealth Management may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Spartan Wealth Management may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Spartan Wealth Management may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Spartan Wealth Management accept or maintain custody of a Client’s funds or securities, except for Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 4  the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services - Spartan Wealth Management will typically provide a variety of financial planning and consulting services to Clients as part of its wealth management services. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Spartan Wealth Management may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services The Advisor provides 3(21) and 3(38) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring Investment Oversight (ERISA 3(21))  Vendor Analysis  Plan Participant Enrollment and Education Tracking   Discretionary Investment Management (ERISA 3(38))   Performance Reporting  Ongoing Investment Recommendation and Assistance  Benchmarking Services These services are provided by the Advisor serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 5  Prior to engaging Spartan Wealth Management to provide investment advisory services, each Client is required to enter into an agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: Establishing an Investment Strategy – Spartan Wealth Management, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.  Asset Allocation – Spartan Wealth Management will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.  Portfolio Construction – Spartan Wealth Management will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.  Investment Management and Supervision – Spartan Wealth Management will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Spartan Wealth Management does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Spartan Wealth Management. E. Assets Under Management As of 2/10/2025, Spartan Wealth Management had $406,619,436 in discretionary assets under management. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid monthly in advance pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior month. Wealth management fees are based on the following schedule. Assets under Management ($) Up to $500,000 $500,001 to $1,000,000 $1,000,001 to $2,000,000 $2,000,001 to $5,000,000 $5,000,001 to $10,000,000 $10,000,001 to $15,000,000 $15,000,001 to $25,000,000 $25,000,001 to $50,000,000 Annual Rate (%) 1.50% 1.35% 1.10% 1.00% 0.90% 0.80% 0.70% 0.60% The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month and billed in arrears off the value at the end of the month. Following the first month, the fees will be billed in advance as described above. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Spartan Wealth Management will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Fees for Financial Planning and Consulting Services Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 6  Clients that are receiving financial planning and consulting services only are charged a fixed fee ranging from $5,000 to $24,000, depending upon the complexity of the client’s plan and services provided. In the alternative, clients that are receiving financial planning and consulting services only may be charged and hourly fee rate up to $500.00. For clients receiving ongoing financial planning services the annual fee is charged monthly. For financial planning services that are completed upon the delivery of the financial plan to the client, the fixed fee can be charged in monthly installments, or otherwise in full upon delivery of the completed financial plan. Actual fees charged are clearly outlined in the financial planning agreement and clients receive invoices reflecting the amount of the fee due and payable. Retirement Plan Advisory Services Retirement plan advisory fees are charged an annual asset-based fee of up to 1.50%. Fees may be billed monthly or quarterly (“Billing Period”) in advance or arrears pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under management at the end of the Billing Period. Fees may be negotiable depending on the size and complexity of the Plan but shall not exceed the fee range stated above. B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective month. The amount due is calculated by applying the monthly rate (annual rate divided by 12) to the total assets under management with Spartan Wealth Management at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the wealth management fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Spartan Wealth Management to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Spartan Wealth Management, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Spartan Wealth Management are separate and distinct from these custody and execution fees. In addition, all fees paid to Spartan Wealth Management for wealth management services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Spartan Wealth Management, but would not receive the services provided by Spartan Wealth Management which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Spartan Wealth Management to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services Spartan Wealth Management may be compensated for its wealth management services in advance of the month in Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 7  which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the month. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services The Advisor may be compensated for its services at the beginning of the Billing Period before services are rendered pursuant to the terms of the retirement plan advisory agreement. Either party may request to terminate a retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for fees up to and including the effective date of termination. If the fees are billed in advance, the Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of the Billing Period. The Client’s retirement plan services agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Spartan Wealth Management does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the wealth management fees noted above. Broker-Dealer and Registered Investment Advisor Affiliation One or more Advisory Persons affiliated with Spartan Wealth Management are Registered Representatives and Investment Advisor Representatives of LPL Financial as broker-dealer representatives (“Dually Registered Persons”), LPL is registered as a broker-dealer, and as a registered investment advisor with the Securities and Exchange Commission (“SEC”). LPL is also a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Registered Representatives of LPL earn commissions and ongoing trails, as applicable, on securities transactions effected through LPL. While LPL is not responsible for the management, operations, or compliance programs of Spartan Wealth Management, LPL conducts certain recordkeeping and oversight of Spartan Wealth Management as required under FINRA Rules. Because of the affiliation with LPL, these persons may have different but concurrent roles:  As a Registered Representative with LPL who receives commissions for recommending securities; and  As an Investment Advisor Representative of Spartan Wealth Management who offers investment advisory services outside of LPL. Dually Registered Persons receive commission for sale of securities through LPL. This creates a conflict of interest because it gives and incentive to recommend products based on the commission they receive. This conflict is mitigated by disclosures, procedures and Spartan’s fiduciary obligation to place their client’s interests first. Clients have the option of purchasing many of the securities and investment products we make available to you through another broker- dealer or investment adviser at a lower cost. However, when purchasing these securities and investment products away from Spartan Wealth, you will not receive the benefit of the advice and other services we provide. Spartan Wealth Insurance Advisors LLC Certain Advisory Persons are also licensed as an independent insurance professional through Spartan Wealth Insurance Advisors LLC (“Spartan Wealth Insurance”), an affiliated entity under common control and ownership as Spartan Wealth Management. As an independent insurance professional, certain Advisory Persons may earn commission-based compensation for selling insurance products, including insurance products sold to Clients. Insurance commissions earned by Advisory Persons are separate and in addition to wealth management fees. This practice presents a conflict of interest as Advisory Persons have an incentive to recommend insurance products to the Client. Clients are under no obligation, contractually or otherwise, to purchase insurance products through Spartan Wealth Insurance or any Advisory Person. Please see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 8  Spartan Wealth Management does not charge performance-based fees for its investment advisory services. The fees charged by Spartan Wealth Management are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Spartan Wealth Management does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Spartan Wealth Management offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans. Spartan Wealth Management generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Spartan Wealth Management primarily employs fundamental analysis and Modern Portfolio Theory methods in developing investment strategies for its Clients. Research and analysis from Spartan Wealth Management are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Modern Portfolio Theory (“MPT”) is a Nobel Prize-winning approach that is utilized as a formal process for investment selection. By comparing historical return, historical volatility, and historical correlation, MPT finds the most efficient portfolio for a given level of risk. The sensitive process of gathering suitable inputs and constructing constraints to create marketable portfolios requires the infusion of opinion, experience, and importantly, a deep understanding of financial theory and markets. An inherent risk in applying MPT is the understanding that the historical characteristics of an investment or index do not necessarily indicate future outcomes. The Advisor employs various measures to mitigate this risk, including, but not limited to: continuously challenging all assumptions, applying practical constraints to the portfolio models, and considering alternative courses of history. As noted above, Spartan Wealth Management generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Spartan Wealth Management will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Spartan Wealth Management may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Spartan Wealth Management will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 9  lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 10  Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Non-Purpose Loans and Lines of Credit Non-purpose loans and lines of credit carry a number of risks, including but not limited to the risk of a market downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian, may result in a reduction in the draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit additional funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral account[s]. Structured Products Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Spartan Wealth Management or its management persons. Spartan Wealth Management values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 331719. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer and Registered Investment Advisor Affiliation As mentioned in Item 5.E above, certain Advisory Persons are also Registered Representatives of LPL. Registered Representatives of LPL earn commissions and ongoing trails, as applicable, on securities transactions affected through LPL. Clients are not obligated to implement any recommendation provided by Advisory Persons. Neither the Advisor nor Advisory Persons will earn ongoing wealth management fees through Spartan Wealth Management in connection with any services implemented in an Advisory Person’s separate capacity as a Registered Representative or Investment Advisor Representative of LPL. Spartan Wealth Insurance Advisors LLC As noted in Item 5.E, Spartan Wealth Insurance is affiliated and under common control as Spartan Wealth Management. Certain Advisory Persons are also licensed as an independent insurance professional of Spartan Wealth Insurance. As an independent insurance professional, Advisory Persons may earn commission-based compensation for selling insurance products, including insurance products sold to Clients. Insurance commissions Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 11  earned by Advisory Persons are separate and in addition to advisory fees. This practice presents a conflict of interest as Advisory Persons have an incentive to recommend insurance products to the Client. Clients are under no obligation, contractually or otherwise, to purchase insurance products through Spartan Wealth Insurance or Advisory Persons. Spartan Wealth Benefit Advisors LLC Spartan Wealth Benefit Advisors LLC (“Spartan Wealth Benefit”) is affiliated and under common control as Spartan Wealth Management. Spartan Wealth Benefit provides employee benefit and insurance resources for small businesses. Certain Advisory Persons may earn commission-based compensation for selling insurance products to small businesses. This presents a conflict of interest as Advisory Persons have an incentive to recommend the services of Spartan Wealth Benefit for purposes of generating commission based revenue. However, Clients are under no obligation, contractually or otherwise, to utilize the services of Spartan Wealth Benefit or Advisory Persons. Promoter Agreements Spartan Wealth Management has entered into and are currently party to promoter’s agreements whereby we receive payment for referring clients to another business, in accordance with the requirements of Rule 206(4)-1 of the Advisers Act and any corresponding state securities law requirements. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Spartan Wealth Management has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Spartan Wealth Management (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Spartan Wealth Management and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Spartan Wealth Management’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (248) 297-6600 or via email at info@spartanwealth.com. B. Personal Trading with Material Interest Spartan Wealth Management allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Spartan Wealth Management does not act as principal in any transactions. The Advisor does not act as the general partner of a fund, or advise an investment company. Spartan Wealth Management does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Spartan Wealth Management allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non- public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Spartan Wealth Management requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Spartan Wealth Management allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. Spartan Wealth Management has procedures in place to help prevent the Firm, or any Supervised Person of Spartan Wealth Management, from transacting in any security to the detriment of any Client. Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 12  Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Spartan Wealth Management does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Spartan Wealth Management to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, Spartan Wealth Management does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Spartan Wealth Management does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Spartan Wealth Management. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Spartan Wealth Management may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. The Advisor will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. The Advisor maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. As Registered Representatives of LPL, the Advisor may be limited in using other broker-dealers/custodians as LPL must approve the use of any outside broker-dealer/custodian. Additionally, as stated previously, individuals associated with Spartan Wealth are licensed as registered representatives of LPL Financial. As a result of this licensing relationship, LPL Financial is responsible for supervising certain activities of Spartan Wealth to the extent Spartan Wealth manages assets at a broker/dealer and custodian other than LPL Financial. LPL Financial charges a fee of up to 10 basis points to Spartan Wealth for this oversight. This presents a conflict of interest in that Spartan Wealth has a financial incentive to recommend that you maintain your account with LPL Financial rather than another custodian in order to avoid the oversight fee. However, to the extent Spartan Wealth recommends you use LPL Financial for such services, it is because Spartan Wealth believes that it is in your best interest to do so based on the quality and pricing of the execution, benefits of an integrated platform for brokerage and advisory accounts, and other services provided by LPL Financial. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Spartan Wealth Management does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Spartan Wealth Management does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Spartan Wealth Management will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Spartan Wealth Management will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 13  4) confidentiality and 5) skill required of the Custodian. Spartan Wealth Management will execute its transactions through the Custodian as authorized by the Client. Spartan Wealth Management may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons and periodically reviewed by the Chief Compliance Officer of Spartan Wealth Management. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Spartan Wealth Management if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Spartan Wealth Management Spartan Wealth Management does not receive commissions or other compensation from product sponsors, broker- dealers or any un-related third party. Spartan Wealth Management may refer Clients to various unaffiliated, non- advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Spartan Wealth Management has entered into and are currently party to promoter’s agreements whereby we receive payments for referring clients to another business, in accordance with the requirements of Rule 206(4)-1 of the Advisers Act and any corresponding state securities law requirements. Likewise, Spartan Wealth Management may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform - Schwab Spartan Wealth Management has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Spartan Wealth Management. As a registered investment advisor participating on the Schwab Advisor Services platform, Spartan Wealth Management receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 14  investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Spartan Wealth Management that may not benefit the Client, including: educational conferences and events, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Spartan Wealth Management believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Transition Bonus – LPL Financial As part of the transition from Cadaret Grant to LPL Financial, LPL Financial will pay Spartan Wealth Management a Transition Bonus to assist with technology, continuing education, among other things. This is not considered a loan and is not subject to repayment or minimum levels of business. This creates a conflict of interest where Spartan Wealth could feel obligated to send more business to LPL Financial, however, Spartan Wealth Management is under no obligations and is required to act in the best interest of their clients. B. Compensation for Client Referrals Spartan Wealth Management has entered into agreements with individuals and organizations for the referral of clients to us. All such agreements will be in writing and comply with the applicable state and federal regulations. If a client is introduced to Spartan Wealth Management by a solicitor, Spartan Wealth Management will pay that solicitor a fee in accordance with the applicable federal and state securities law requirements. While the specific terms of each agreement may differ, generally, the compensation will be based upon a varying percentage of the fees paid to Spartan Wealth Management. Any such fee shall be paid solely from Spartan Wealth Management’s fees and shall not result in additional charge to the client. Each prospective client who is referred under such arrangement will receive a copy of this Brochure and a separate disclosure document disclosing the nature of the relationship between the third-party solicitor and Spartan Wealth Management and the compensation that will be paid by us to the third party. The solicitor is required to obtain the client’s signature acknowledging receipt of this Brochure and the solicitor’s written disclosure document. Item 15 – Custody Spartan Wealth Management does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees and third-party Standing Letters of Authorization as directed by the client. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct Spartan Wealth Management to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Spartan Wealth Management to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Spartan Wealth Management generally has discretion over the selection and amount of securities to be bought or Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 15  sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Spartan Wealth Management. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by Spartan Wealth Management will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Spartan Wealth Management does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Spartan Wealth Management, nor its management, have any adverse financial situations that would reasonably impair the ability of Spartan Wealth Management to meet all obligations to its Clients. Neither Spartan Wealth Management, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Spartan Wealth Management is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 16  Privacy Policy Effective: July 23, 2025 Our Commitment to You Spartan Wealth Advisory Services LLC (“Spartan Wealth Management” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Spartan Wealth Management (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Spartan Wealth Management does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 17  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No to: processing Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. We share information with LPL. This sharing is due to the oversight LPL has over certain Supervised Persons of our firm. You may contact us at any time for a copy of LPL’s Privacy Policy. No Not Shared Marketing Purposes Spartan Wealth Management does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Spartan Wealth Management or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients Spartan Wealth Management does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (248) 297-6600 or via email at info@spartanwealth.com. Spartan Wealth Advisory Services LLC 32600 Telegraph Road, Suite 200, Bingham Farms, MI 48025 Phone: (248) 297-6600 www.spartanwealth.com Page 18