Spiegelman Wealth Management, Inc.

Item 1: Cover Sheet INFORMATIONAL BROCHURE FORM ADV PART 2A 1212 Broadway Plaza Suite 2100 #54. Walnut Creek, CA 94596 June 22, 2026 This brochure provides information about the qualifications and business practices of Spiegelman Wealth Management, Inc. (“SWM”). If you have any questions about the contents of this brochure, please contact us at 925-385-6200. 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. SWM is a registered investment adviser. Registration does not imply any certain level of skill or training. Additional information about SWM is also available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2: Statement of Material Changes SWM is required to include in this Item 2 any material changes to this Brochure. Since our last filing on March 30, 2026, we have added Charles Schwab as a custodian. . 2  Item 3: Table of Contents TABLE OF CONTENTS Item 1: Cover Sheet 1 Item 2: Statement of Material Changes 2 Item 3: Table of Contents 3 Item 4 Advisory Business 4 Item 5: Fees and Compensation 5 Item 6: Performance Based Fees 7 Item 7: Types of Clients 7 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 7 Item 9: Disciplinary Information 10 Item 10: Other Financial Industry Activities and Affiliations 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 11 Item 12: Brokerage Practices 11 Item 13: Review of Accounts 12 Item 14: Client Referrals and Other Compensation 12 Item 15: Custody 12 Item 16: Investment Discretion 13 Item 17: Voting Client Securities 13 Item 18: Financial Information 13 3  INFORMATIONAL BROCHURE SPIEGELMAN WEALTH MANAGEMENT, INC. Item 4 Advisory Business Spiegelman Wealth Management, Inc. (“SWM”) has been in business as a registered investment advisor since July, 2025. Adam Spiegelman is the firm’s owner. SWM provides personalized investment management and financial planning services. The firm provides services to individuals, trusts, foundations, retirement plans, and corporations. Financial Planning Financial planning is a process by which a client’s current circumstances are reviewed, goals stated, and a plan is made to guide the client to those goals. In the information-gathering stage, the client will supply to SWM information including income, investments, savings, insurance, age, and many other items that are helpful to the firm in assessing your financial goals. The information is typically provided during personal interviews and supplemented with written information. Once the information is received, we will discuss their financial needs and goals and compare their current financial situation with the goals they stated. Once these are compared, we will create a financial and/or investment plan to help them meet their goals. The plan is intended to be a suggested blueprint of how to meet our client’s goals. Not every plan will be the same for every client. Each one is specific to the client who requested it. Because the plan is based on information supplied by the client, it is very important that they accurately and completely communicate to us the information we need. We determine these objectives by interviewing the client for relevant financial information and any additional background information so we can understand a more complete picture of a client’s needs. It is very important that our clients continually provide us with any updates so that, if necessary, we are able to update their plan. Otherwise, their plan may no longer be accurate. Financial planning services are generally included with investment advisory services, but in some circumstances can be provided on a standalone basis. Investment Management Services Investment management services are designed to meet the desires, objectives and needs of a particular client or entity. This process includes determining risk tolerance and an in-depth understanding of the client’s investment objectives. The financial plan is also intended to be a suggested blueprint of how to meet client’s investment related goals. From this process an appropriate investment advisory strategy will be determined. Depending on the client’s desires, objectives and needs, we will determine which stocks, bonds, exchange- traded funds, and/or mutual funds to be utilized. When we perform investment management services, we will generally do so on a discretionary basis. This means that while we will continue an ongoing relationship with each client, being involved in various stages of their lives and decisions to be made, we will not seek specific approval of changes to the securities in client accounts. Clients can make deposits or withdrawals in their accounts at any time. Because we take discretion when managing accounts, clients engaging us will be asked to execute a Limited Power of Attorney (granting 4  us discretionary authority over the client accounts) through an Investment Management Agreement that outlines the responsibilities of both the client and SWM. This Limited Power of Attorney does not grant SWM the authority to make any withdrawals or transfers in or out of a client account beyond the deduction of fees. Such other transfers will only be made at the specific direction of the client. Advisory services are tailored to the specific needs of an individual client. Clients may place reasonable restrictions on the management of assets, including specific securities or types of securities. However, clients should understand that significant restrictions may decrease the ability of SWM to meet the client’s goals. In some circumstances, SWM may provide investment management services on a non-discretionary basis, which means we will manage the clients’ accounts as we do for our discretionary clients, except we will receive approval from the client prior to implementing any investment recommendation. Clients should be aware that some recommendations may be time-sensitive, and, as such, their performance may be affected if SWM is unable to reach them on a timely basis. SWM acts as portfolio manager for and sponsor of a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. Clients utilizing SWM’s wrap fee portfolio management should see SWM’s separate Wrap Fee Program Brochure. SWM manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than it would manage nonwrap fee accounts. SWM’s receives the advisory fee set forth in Item 5 below as a management fee under the wrap fee program. Please also see Item 5 and Item 12 of this brochure. Assets Under Management As of December 31, 2025, SWM provides discretionary investment management services to a total of $442,974,405 of regulatory assets under management. Item 5: Fees and Compensation A. Fees Charged All investment management clients will be required to execute an Investment Advisory Agreement that will describe the type of management services to be provided and the fees, among other items. Generally, fees range from 1.35% to 0.45% per annum of the market value of a client’s assets managed by SWM. Our tiered fee schedule is below: Account Fee Aggregate Account Size Above $10,000,000 Next $5,000,000 Next $3,000,000 Next $1,000,000 Next $500,000 0.45% 0.55% 0.70% 0.95% 1.10% 5  Next $250,000 First $250,000 1.25% 1.35% The fee range stated is a guide. Fees are negotiable, and may be higher or lower than this range, based on the nature of the account. Factors affecting fee percentages include the size of the account, complexity of asset structures, and other factors. Please note that same or similar services may be available for a lower cost from other investment advisers. Financial planning services are included in the investment management fee. B. Fee Payment Investment Advisory fees will generally be debited directly from each client’s account. As of the date of this brochure, the advisory fees may be paid monthly, in arrears, and the fees shall be calculated monthly using an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian chosen by the client. The client will also receive a statement from their account custodian showing all transactions in their account, including the fee. C. Other Fees There are a number of other fees that can be associated with holding and investing in securities. You will be responsible for fees including transaction fees for the purchase or sale of a mutual fund or Exchange Traded Fund, or commissions for the purchase or sale of a stock unless you are enrolled in the SWM Wrap Program. Expenses of a fund will not be included in management fees, as they are deducted from the value of the shares by the mutual fund manager. For complete discussion of expenses related to each mutual fund, you should read a copy of the prospectus issued by that fund. SWM can provide or direct you to a copy of the prospectus for any fund that we recommend to you. SWM may utilize external money managers, exchange traded funds, mutual funds and other investment options. These investment options have related expenses which are not included in the advisory fee. Clients utilizing SWM’s wrap fee portfolio management should see the separate Wrap Fee Program Brochure for additional details regarding third party fees. Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and custodial issues. D. Pro-rata Fees If you become a client during a billing cycle you will pay a management fee for the number of days left in that cycle. You may terminate the Investment Management Agreement by providing written notice to SWM Once your notice of termination is received, we will charge the fee through the date of transfer of your assets. SWM will cease to perform services, including processing trades and distributions, upon termination. Assets not transferred from terminated accounts within 30 (thirty) days of termination may be “de-linked”, meaning 6  they will no longer be visible to SWM and will become a retail account with the custodian. E. Compensation for the Sale of Securities This item is not applicable. SWM does not receive any commissions or fees from investment product providers or custodians. Its sole source of income is from fees paid by clients. Item 6: Performance Based Fees Fees will not be based upon a share of capital gains or capital appreciation of your accounts (otherwise known as “performance-based fees”). Item 7: Types of Clients Clients advised may include individuals, families, retirement accounts, trusts, foundations, and corporations. SWM does not currently require a minimum account size to receive our services. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss It is important for you to know and remember that all investments carry risks. Investing in securities involves risk of loss that clients should be prepared to bear. The specific securities we recommend for your account will depend on market conditions and our research at the time. Generally, we recommend a mix of mutual funds, exchange traded funds, stocks, and bonds. Specific funds are chosen based on where its investment objective fits into the asset allocation recommended by SWM, its risk parameters, past performance, peer rankings, fees, expenses, and any other aspects of the fund SWM deems relevant to that particular fund. We base our conclusions on predominantly publicly available research, such as regulatory filings, press releases, competitor analyses, and in some cases research we receive from our custodian or other market analyses. We will primarily use fundamental analysis which involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience, and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The risk of fundamental analysis is that the information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance Each client’s portfolio will be invested according to that client’s investment objectives. We determine these objectives by interviewing the client and/or asking the client to put these objectives in writing. Once we ascertain your objectives for each account, we will develop a set of asset allocation guidelines. Because we develop an investment strategy based on your personal situation and financial goals, your guidelines may be similar to or different from another client’s. We will periodically recommend securities transactions in your portfolio to meet the guidelines of the asset allocation strategy. It is important to remember that because market conditions can vary greatly, your guidelines are not necessarily strict rules. Rather, we review 7  accounts individually, and may deviate from the guidelines as we believe necessary. Depending on a client’s given circumstances, SWM may recommend that a client rollover retirement plan assets to an Individual Retirement Account (IRA). If a client chooses to hire SWM to manage the IRA, SWM may earn fees on those accounts. This presents a conflict of interest, as SWM has a financial incentive to recommend that a client roll over retirement assets into an IRA we will manage. This conflict is disclosed to clients verbally and in this brochure. Clients are also advised that they are under no obligation to implement the recommendation to roll over retirement plan assets or to hire SWM to manage those assets. SWM attempts to mitigate this conflict by requiring that all investment recommendations have a sound basis for the recommendation, and by requiring employees to acknowledge their fiduciary responsibility toward each client. 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. There are always risks to investing. Clients should be aware that all investments carry various types of risk including the potential loss of principal that clients should be prepared to bear. It is impossible to name all possible types of risks. Among the risks are the following: • Political Risks. Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world. • General Market Risks. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason, and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations. • Currency Risk. When investing in another country using another currency, the changes in the value of the currency can change the value of your security value in your portfolio. • Regulatory Risk. Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. • Tax Risks Related to Short Term Trading: Clients should note that SWM may engage in short-term 8  trading transactions. These transactions may result in short term gains or losses for federal and state tax purposes, which may be taxed at a higher rate than long term strategies. SWM endeavors to invest client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals regarding the transactions in client accounts. • Risks Related to Investment Term. Securities do not follow a straight line up in value. All securities will have periods of time when the current price of the security is not an accurate measure of its value. If you require us to liquidate your portfolio during one of these periods, you will not realize as much value as you would have had the investment had the opportunity to regain its value. • Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. • Business Risk. This can be thought of as certainty or uncertainty of income. Management comes under business risk. Cyclical companies (like automobile companies) have more business risk because of the less steady income stream. On the other hand, fast food chains tend to have steadier income streams and therefore, less business risk. • Financial Risk. The amount of debt or leverage determines the financial risk of a company. • Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk. • REITs: A REIT is an entity, typically a trust or corporation that accepts investments from a number of investors, pools the money, and then uses that money to invest in real estate through either actual property purchases or mortgage loans. While there are some benefits to owning REITs, which include potential tax benefits, income, and the relatively low barrier to invest in real estate as compared to directly investing in real estate, REITs also have some increased risks as compared to more traditional investments such as stocks, bonds, and mutual funds. First, real estate investing can be highly volatile. Second, the specific REIT chosen may have a focus such as commercial real estate or real estate in a given location. • MLPs: An MLP is a publicly traded entity that is designed to provide tax benefits for the investor. In order to preserve these benefits, the MLP must derive most, if not all, of its income from real estate, natural resources, and commodities. While MLPs may add diversification and tax favored treatment to a client’s portfolio, they also carry significant risks beyond more traditional investments such as stocks, bonds, and mutual funds. One such risk is management risk-the success of the MLP is dependent upon the manager’s experience and judgment in selecting investments for the MLP. Another risk is the governance structure, which means the rules under which the entity is run. International Investing: Investing outside of the United States, especially in emerging markets, can • have special or enhanced risks. The most obvious are political risk (changes in local politics can have a vast impact on the markets in that country as well as regulations affecting given issuers) and currency risk (changes in exchange rates between the dollar and the local denominations can materially affect the value of the security even if the underlying fundamentals and market price are stagnant). There are other risks, including enhanced liquidity risk, meaning that while domestic equities and mutual funds are generally easily liquidated (though there may be a risk of loss due to the timing of the sale), equities in other jurisdictions may be subject to the circumstances of lower overall market volume and fewer companies on an emerging exchange. In addition, there may be less information and less transparency in a foreign market or from a 9  foreign company. Foreign markets impose different rules than domestic markets, which may not be to an investor's advantage. Also, companies in foreign jurisdictions are generally able to avail themselves of local laws and venues, meaning that legal remedies for U.S. investors may not be as easily obtained as in the U.S. • Annuities: Annuities can have many complex features and clauses. In particular, annuity values and income may be impacted by the financial condition of the issuer. • Restriction Risk. Clients may at all times place reasonable restrictions on the management of their accounts. However, placing these restrictions limit our ability to implement recommendations, thus lowering the potential for returns. • Risks Related to Investment Term & Liquidity: Securities do not follow a straight line up in value. All securities will have periods of time in which the current price of the security is not an accurate measure of its value. If you require us to liquidate your portfolio during one of these periods, you may not realize as much value. Further, some investments are made with the intention of the investment appreciating over an extended period of time. Liquidating these investments prior to their intended time horizon may result in losses. Interest Rate Risks: The prices of, and the income generated by, most debt and equity securities may • be affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities generally will decline when interest rates rise and will increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call,” or refinance a security before its stated maturity date, which may result in having to reinvest the proceeds in lower-yielding securities. • Excess Cash Balance Risk: Client accounts may have cash balances in excess of $250,000, which is the insurance limit of the Federal Deposit Insurance Corporation. For cash balances in excess of that amount, there is an enhanced risk that operations related counterparty risk related to the account custodian could cause losses in the account. We mitigate this risk by carrying cash balances in amounts subject to protection or investing excess cash in money market products. • Market Disruption, Health Crises, Terrorism and Geopolitical Risk. Investments are subject to the risk that war, terrorism, global health crises or similar pandemics, and other related geopolitical events increase short-term market volatility and may have adverse long-term effects on world economics and markets generally. These risks have previously led and may lead in the future to adverse effects on the value of client’s investments. Item 9: Disciplinary Information There are no disciplinary items to report. Item 10: Other Financial Industry Activities and Affiliations A. Broker-dealer Neither the principal of SWM nor any related persons are registered, or have an application pending to register, as a broker dealer. B. Futures Commission Merchant/Commodity Trading Advisor 10  Neither the principal of SWM nor any related persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Relationship with Related Persons SWM only receives compensation directly from Clients. We do not receive compensation from any outside source or have any relationships with related persons.. D. Recommendations of Other Advisers We may recommend that you use a third party adviser or money manager based on your needs and suitability. We do not, however, receive compensation from the money manager for recommending that you use their services. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions of A. our fiduciary duty to clients, political contributions, gifts, entertainment, and trading guidelines. SWM does not recommend to clients that they invest in any security in which SWM, or any principal B. thereof has any financial interest. C/D. On occasion, an employee of SWM may purchase for his or her own account securities which are also recommended for clients including at or around the same time as such client transactions. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades must be reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. Item 12: Brokerage Practices A. Recommendation of Broker-Dealer SWM does not have any affiliation with any custodian we recommend. Specific custodian recommendations are made to the client based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. In recommending custodians, we have an obligation to seek the “best execution” of transactions in client accounts. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the custodian’s services. The factors we consider when evaluating a custodian for best execution include, without limitation, the custodian’s: ● Combination of transaction execution services and asset custody services (generally without a separate fee for custody); 11  ● Capability to execute, clear, and settle trades (buy and sell securities for your account); ● Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.); ● Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.); ● Availability of investment research and tools that assist us in making investment decisions ● Quality of services; ● Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; ● Reputation, financial strength, security and stability; ● Prior service to us and our clients. SWM utilizes Fidelity Brokerage Services, LLC and Charles Schwab as its primary custodians and generally recommends thesecustodians to clients. These custodians offer independent investment advisors services which include custody of securities, trade execution, clearance, and settlement of transactions. We receive some benefits through participation in these programs. Benefits provided to our firm may include, but are not limited to, market information and administrative services that help our firm manage your account(s). We believe that the recommended custodians and broker- dealers provide quality execution services for our clients at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the services provided by recommended custodians, including the value of the firm's reputation, execution capabilities, custodial fees, and responsiveness to our clients and our firm. In recognition of the value of the services recommended custodians provide, you may pay higher custodial fees than those that may be available elsewhere. In selecting or recommending a custodian and broker-dealer, we will consider the value of research and additional brokerage products and services a broker-dealer has provided or will provide to our clients and our firm. Receipt of these additional brokerage products and services are not considered to have been paid for with "soft dollars." Aggregating Trades Commission costs per client may be lower on a particular trade if all clients in whose accounts the trade is to be made are executed at the same time. This is called aggregating trades. Instead of placing a number of trades for the same security for each account, we will, when appropriate, executed one trade for all accounts and then allocate the trades to each account after execution. If an aggregate trade is not fully executed, the securities will be allocated to client accounts on a pro rata basis, except where doing so would create an unintended adverse consequence (For example, ¼ of a share, or a position in the account or less than 1%.) Directed Brokerage SWM does not allow clients to direct brokerage in most circumstances. SWM may be unable to achieve most favorable execution of client transactions if clients choose to direct brokerage. This may cost clients money because without the ability to direct brokerage, SWM may not be able to aggregate orders to reduce 12  transactions costs resulting in higher brokerage commissions and less favorable prices. Not all investment advisers allow their clients to direct brokerage. Item 13: Review of Accounts All accounts will be reviewed by a senior professional on at least an annual basis. However, it is expected that market conditions, changes in a particular client’s account, or changes to a client’s circumstances will trigger a review of accounts. All clients will receive statements and confirmations of trades directly from the account custodian, please refer to Item 15 regarding custody. Item 14: Client Referrals and Other Compensation A. Economic Benefit Provided by Third Parties for Advice Rendered to Client. Please refer to Item 12, where we discuss recommendation of Broker-Dealers. B. Compensation to Non-Advisory Personnel for Client Referrals. SWM does not receive compensation from third parties and does not compensate third parties for client referrals. We do not receive nor provide compensation for client referrals. Item 15: Custody There are two avenues through which SWM may have custody of client funds; by directly debiting its fees from client accounts pursuant to applicable agreements granting such right, and potentially by permitting clients to sign standing letters of authorization (“SLOAs”). SLOAs permit a client to sign one document that directs SWM to make distributions out of the client’s account(s). Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian chosen by the client. Each month or quarter, clients will receive a bill itemizing the fees to be debited, including the formula used to calculate the fee, the amount of assets the fee is based, and the time period covered by the fee. The invoice will also state that the fee was not independently calculated by the custodian. The client will also receive a statement from their account custodian showing all transactions in their account, including the fee We encourage clients to carefully review the statements and confirmations sent to them by their custodian, and to compare the information on your quarterly report prepared by SWM against the information in the statements provided directly from the custodian. Please alert us of any discrepancies. Item 16: Investment Discretion Asset management services will generally be provided on a “discretionary” basis. When SWM is engaged to 13  provide asset management services on a discretionary basis, we will monitor your accounts to ensure that they are meeting your asset allocation requirements. If any changes are needed to your investments, we will make the changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. You will receive written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive statements at least quarterly from your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and SWM. Item 17: Voting Client Securities From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities may be permitted to vote on various types of corporate actions. Examples of these actions include mergers, tender offers, or board elections. Clients are required to vote proxies related to their investments, or to choose not to vote their proxies. SWM will not accept authority to vote client securities. Clients will receive their proxies directly from the custodian for the client account. SWM will not give clients advice on how to vote proxies. Item 18: Financial Information A. SWM does not require the prepayment of fees more than six (6) months or more in advance and therefore has not provided a balance sheet with this brochure. B. There are no material financial circumstances or conditions that would reasonably be expected to impair our ability to meet our contractual obligations to our clients. C. SWM has not been the subject of a bankruptcy petition at any time during the past ten years. 14