SPWM ADVISORS LLC

SPWM Advisors LLC d/b/a Stonepath Wealth Management Form ADV Part 2A – Disclosure Brochure Effective: April 16, 2025 this Disclosure Brochure, please contact This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of SPWM Advisors LLC (“Stonepath Wealth Management” or the “Advisor”). If you have any questions about the the Advisor at (231) 668-6999 or by email at content of info@stonepathwm.com. Stonepath Wealth Management is a registered investment advisor with 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 Stonepath Wealth Management to assist you in determining whether to retain the Advisor. Additional information about Stonepath 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# 328977. SPWM Advisors LLC d/b/a Stonepath Wealth Management 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 | Fax: (231) 943-1247 http://stonepathwm.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 Stonepath Wealth Management. The Brochure Supplement is provided separately. Stonepath 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. Stonepath 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 The following material changes have been made to this Disclosure Brochure since the initial filing on November 13th, 2023: • The Advisor offers Retirement Plan Advisory Services. Please see Item 4 and Item 5 for additional information. • The Advisor has updated its maximum fee for Investment Management Services. Please see Item 5 for additional information. 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# 328977. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (231) 668-6999 or by email at info@stonepathwm.com. SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 2 Http://stonepathwm.com  Item 3 – Table of Contents Item 1 – Cover Page 1 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 .......................................................................................................................................... 6 D. Wrap Fee Programs ....................................................................................................................................................... 7 E. Assets Under Management ............................................................................................................................................ 7 Item 5 – Fees and Compensation ......................................................................................................................... 7 A. Fees for Advisory Services ............................................................................................................................................. 7 B. Fee Billing ....................................................................................................................................................................... 8 C. Other Fees and Expenses ............................................................................................................................................. 8 D. Advance Payment of Fees and Termination .................................................................................................................. 9 E. Compensation for Sales of Securities .......................................................................................................................... 10 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................ 10 Item 7 – Types of Clients ..................................................................................................................................... 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 10 A. Methods of Analysis ..................................................................................................................................................... 10 B. Risk of Loss .................................................................................................................................................................. 11 Item 9 – Disciplinary Information ....................................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 13 A. Code of Ethics .............................................................................................................................................................. 13 B. Personal Trading with Material Interest ........................................................................................................................ 13 C. Personal Trading in Same Securities as Clients .......................................................................................................... 13 D. Personal Trading at Same Time as Client ................................................................................................................... 13 Item 12 – Brokerage Practices ............................................................................................................................ 13 A. Recommendation of Custodian[s] ................................................................................................................................ 13 B. Aggregating and Allocating Trades .............................................................................................................................. 14 Item 13 – Review of Accounts ............................................................................................................................ 14 A. Frequency of Reviews .................................................................................................................................................. 14 B. Causes for Reviews ..................................................................................................................................................... 15 C. Review Reports ............................................................................................................................................................ 15 Item 14 – Client Referrals and Other Compensation ........................................................................................ 15 A. Compensation Received by Stonepath Wealth Management ...................................................................................... 15 B. Compensation for Client Referrals ............................................................................................................................... 15 Item 15 – Custody ................................................................................................................................................ 15 Item 16 – Investment Discretion ......................................................................................................................... 16 Item 17 – Voting Client Securities ...................................................................................................................... 16 Item 18 – Financial Information .......................................................................................................................... 16 Privacy Policy ...................................................................................................................................................... 17 SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 3 Http://stonepathwm.com  Item 4 – Advisory Services A. Firm Information SPWM Advisors LLC d/b/a Stonepath Wealth Management (“Stonepath 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 Delaware. Stonepath Wealth Management was founded in November 2023 and is owned by Prestige Worldwide Enterprises Inc, and LRG Financial, Inc. The Advisor is operated by Matthew Golba (Chief Executive Officer and Financial Advisor), and Lauren Golba (President, Chief Compliance Officer and Financial Advisor). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Stonepath Wealth Management. B. Advisory Services Offered Stonepath 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. Stonepath 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. Investment Management Services Stonepath Wealth Management provides customized investment management services for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Stonepath Wealth Management works closely with each Client to identify their investment goals, objectives, risk tolerance and financial situation in order to create an overall portfolio strategy. Stonepath Wealth Management will then construct an investment portfolio primarily consisting of low-cost, diversified mutual funds, exchange-traded funds (“ETFs”), individual stocks, bonds, option contracts, alternatives, or Independent Managers to meet the needs of its Clients. The Advisor may also recommend the Advisor’s Model Management Services as described below. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Stonepath 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. Stonepath 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. Stonepath Wealth Management evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Stonepath Wealth Management may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Stonepath 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. Stonepath 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 Stonepath Wealth Management accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 4 Http://stonepathwm.com  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. Model Management Services Stonepath Wealth Management provides customized investment strategies through model portfolios (“Model Portfolios”) that are recommended by Advisory Persons or third-party investment advisors. Advisory Persons may recommend that Clients utilize the Model Portfolios for all or a portion of the Client’s investment portfolio based on the Client’s investment objectives and risk tolerance. The Advisor’s Model Portfolios include several different strategies including Strategic Portfolios (Conservative, Moderate Conservative, Balanced, Moderate Growth, Growth, and All Equity), Core Portfolios, and Stock Models (Growth, Value, and Dividend). Use of Independent Managers Stonepath Wealth Management will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Financial Planning Services Stonepath Wealth Management will provide a variety of financial planning and consulting services to Clients as part of its investment management services. The Advisor will also provide standalone financial planning services pursuant to a written financial planning agreement. 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. Stonepath Wealth Management may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. 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 SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 5 Http://stonepathwm.com  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. Financial Institution Consulting Services The Advisor provides investment consulting services to brokerage customers (herein “Brokerage Customers”) of Mutual Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the Advisor’s consulting services pursuant to a written agreement with the Advisor. Consulting services are strictly on products Clients have purchased through Mutual Securities, Inc. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional details. Retirement Plan Advisory Services Stonepath Wealth Management provides 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 Due Diligence Investment Oversight Services (ERISA 3(21)) Investment Management Services (ERISA 3(38)) • Vendor Analysis • Plan Participant Enrollment and Education Tracking • • • • • Performance Reporting • Ongoing Investment Recommendation Assistance These services are provided by Stonepath Wealth Management 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 Stonepath Wealth Management’ 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 Prior to engaging Stonepath Wealth Management to provide investment advisory services, each Client is required to enter into one or more agreements 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 – Stonepath Wealth Management, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – Stonepath 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 – Stonepath 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 – Stonepath Wealth Management will provide investment management and ongoing oversight of the Client’s investment portfolio. SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 6 Http://stonepathwm.com  D. Wrap Fee Programs Stonepath Wealth Management does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Stonepath Wealth Management. E. Assets Under Management As of December 31, 2024, Stonepath Wealth Management manages $225,790,792 in Client assets on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. 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 one or more written agreement with the Advisor. A. Fees for Advisory Services Investment Management Services Investment management fees are paid monthly in advance pursuant to the terms of the investment advisory agreement. Investment management fees are based on the market value of assets under management at the end of the prior month. Investment management fees range up to 1.65% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. In certain circumstances, Clients will also engage the Advisor for model management services. In these instances, investment management fees range up to 1.90% annually. The investment 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. 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 Stonepath 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. Model Management Services The Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more of the Advisors model portfolios. The model management fees are 0.25% annually paid monthly in advance. Model management fees are based on the market value of assets under management at the end of the prior month. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. The Independent Manager will allocate a portion of the advisory fee collected to the Advisor pursuant to the terms of the executed agreement between the Advisor and the Independent Manager. Financial Planning Services Stonepath Wealth Management offers standalone financial planning services on an hourly basis, a fixed engagement fee, or annual ongoing fee. Hourly fees range up to $300. Fixed fees range up to $20,000. Annual ongoing fees range up to $20,000. Fees are negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 7 Http://stonepathwm.com  Financial Institution Consulting Services The Advisor receives a consulting fee based on the assets under MSI’s management from Brokerage Customers who have provided written consent to MSI to receive the investment consulting services from the Advisor. The consulting fee is calculated from the assets under MSI’s management at the end of the calendar quarter multiplied by the annualized rate ranging up to 1.00%. The initial fee is paid only after the completion of one full calendar quarter period following the date of the executed agreement with MSI. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00%, typically payable at the end of billing period, pursuant to the terms of the retirement plan advisory agreements. Retirement plan advisory fees may be negotiable depending on the size and complexity of the Plan. B. Fee Billing Investment Management Services Investment 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 to the total assets under management with Stonepath 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 investment advisory fee. Clients are urged to also review 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 Stonepath Wealth Management to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Model Management Services Model 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 to the total assets under management with Stonepath Wealth Management at the end of the prior month. Use of Independent Managers For Client accounts implemented through an Independent Manager, the Client’s overall fees will include the Advisor’s investment management fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager. The Independent Manager will assume the responsibility for calculating the Client’s fees and deducting all fees from the Client’s account[s]. Financial Planning Services The Advisor offers financial planning services for an hourly fee, fixed project fee or annual ongoing fee. Hourly fees range up to $300. Fixed project fees range up to $20,000 per engagement. Hourly and fixed project fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. Annual ongoing fees range up to $20,000 and are paid monthly in advance. Financial Institution Consulting Services MSI shall calculate and pay the Advisor for its consulting services on or before thirty (30) days past the end of each calendar quarter. 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 Stonepath Wealth Management, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 8 Http://stonepathwm.com  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 Stonepath Wealth Management are separate and distinct from these custody and execution fees. In addition, all fees paid to Stonepath Wealth Management for investment advisory 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 Stonepath Wealth Management, but would not receive the services provided by Stonepath 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 Stonepath 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 Investment Management Services Stonepath Wealth Management is compensated for its investment management services in advance of the month in which services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory 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 investment management fees from the effective date of termination to the end of the month. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Model Management Services Stonepath Wealth Management is compensated for its model management services in advance of the month in which services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory 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 model management fees from the effective date of termination to the end of the month. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest, the Advisor will have the discretion to terminate the relationship with the Independent Manager. The terms for termination are set forth in the respective agreements between the Advisor and the Independent Managers. Financial Planning Services Stonepath Wealth Management may require an advance deposit or compensation in advance of the month depending on the type of financial planning services rendered. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning 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. For purposes of calculating refunds, the Advisor will conduct the following calculations depending on the type of financial planning services rendered. For hourly engagements, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate. For a fixed fee engagement, the Client shall be billed for the percentage of the engagement scope completed by the Advisor. For an annual ongoing engagement, the Client shall be billed from the effective date of termination to the end of the month. The SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 9 Http://stonepathwm.com  Advisor will refund any unearned financial planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Institution Consulting Services Either party may terminate the consulting agreement by providing thirty (30) days advance written notice to the other party. The Advisor will be entitled to fees up to the date of termination. Retirement Plan Advisory Services Stonepath Wealth Management is typically compensated for its services at the end of the billing period, after retirement plan advisory services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the retirement plan advisory 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. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Stonepath 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 investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Stonepath Wealth Management does not charge performance-based fees for its investment advisory services. The fees charged by Stonepath 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. Stonepath 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 Stonepath Wealth Management offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans. Stonepath 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 Stonepath Wealth Management primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Stonepath 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. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 10 Http://stonepathwm.com  trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Stonepath Wealth Management will be able to accurately predict such a reoccurrence. As noted above, Stonepath Wealth Management generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Stonepath 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, Stonepath 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. Stonepath 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 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 SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 11 Http://stonepathwm.com  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. 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]. 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 Stonepath Wealth Management or its management persons. Stonepath 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# 328977. Item 10 – Other Financial Industry Activities and Affiliations SPWM Insurance Agency LLC As noted in Item 5, SPWM Insurance Agency LLC (“SPWM Insurance”) is an affiliated entity under common control and ownership as the Advisor. Certain Advisory Persons are a licensed insurance professional through SPWM Insurance. Implementations of insurance recommendations are separate and apart from one’s role with the Advisor. As an insurance professional, the Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset investment advisory fees. This presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by the Advisor or Advisory Persons. Financial Institution and Consulting Services The Advisor has an agreement with MSI to provide investment consulting services to Brokerage Customers, as noted in Item 4 – Advisory Services. MSI compensates the Advisor for providing consulting services to Clients who have SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 12 Http://stonepathwm.com  purchased products through MSI. This consulting arrangement does not include assuming discretionary authority over Brokerage Customers’ brokerage accounts or the monitoring of securities. These consulting services offered to Brokerage Customers includes a general review of Brokerage Customers’ investment holdings, which will result in Advisory Persons making specific securities recommendations or offering general investment advice. This relationship presents a conflict of interest. Potential conflicts are mitigated by Brokerage Customers consenting to receive consulting services from the Advisor. In addition, the Advisor will not accept or bill for additional compensation for asset under MSI’s management, beyond the consulting fees disclosed in Item 5 above. Advisory Persons of the Advisor will not engage or hold itself as a registered representative of MSI, as Advisory Persons are not registered to conduct commission-based activities under a broker-dealer. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Stonepath 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 Stonepath Wealth Management (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Stonepath Wealth Management and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Stonepath 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 (231) 668-6999 or via email at info@stonepathwm.com. B. Personal Trading with Material Interest Stonepath Wealth Management allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Stonepath Wealth Management does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Stonepath Wealth Management does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Stonepath 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 Stonepath Wealth Management requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. 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 Stonepath 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. At no time will Stonepath Wealth Management, or any Supervised Person of Stonepath Wealth Management, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Stonepath 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 SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 13 Http://stonepathwm.com  safeguard Client assets and authorize Stonepath Wealth Management to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Stonepath Wealth Management does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Stonepath 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 recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Stonepath Wealth Management. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Stonepath 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 Advisory will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc. (“Raymond James”). Raymond James is a FINRA-registered broker-dealer and New York Stock Exchange/SIPC member. Raymond James will serve as the Client’s “qualified custodian”. The Advisor maintains institutional relationships with Raymond James, whereby the Advisor receives economic benefits from the Custodian. Please see Item 14 below. 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. Stonepath 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 - Stonepath 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 Stonepath 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]). Stonepath 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, 4) confidentiality and 5) skill required of the Custodian. Stonepath Wealth Management will execute its transactions through the Custodian as authorized by the Client. Stonepath 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 Lauren Golba, Chief Compliance Officer of Stonepath Wealth Management. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 14 Http://stonepathwm.com  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 Stonepath 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 Stonepath Wealth Management Stonepath Wealth Management is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Stonepath Wealth Management does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Stonepath 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. Likewise, Stonepath Wealth Management may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform As noted in item 12, the Advisor has established an institutional relationship with Raymond James to assist the Advisor in managing Client account[s]. As part of the arrangement, Raymond James makes available to the Advisor, certain research and brokerage services, including research services obtained by Raymond James directly from independent research companies. The Advisor may also receive additional services and support from Raymond James. The Advisor has an incentive to continue to use or expand the use of Raymond James's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Raymond James and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support because the Advisor renders investment management services to Clients that maintain assets at Raymond James. The software and related systems support may benefit the Advisor, but not its Clients directly. 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 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. In addition, Raymond James has provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. B. Compensation for Client Referrals Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the Client. Item 15 – Custody Stonepath Wealth Management does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 15 Http://stonepathwm.com  Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Stonepath Wealth Management exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Stonepath Wealth Management to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Stonepath Wealth Management to ensure accuracy, as the Custodian does not perform this review. Item 16 – Investment Discretion Stonepath Wealth Management generally has discretion over the selection and amount of securities to be bought or 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 Stonepath 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 investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Stonepath Wealth Management will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Stonepath 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 Stonepath Wealth Management, nor its management, have any adverse financial situations that would reasonably impair the ability of Stonepath Wealth Management to meet all obligations to its Clients. Neither Stonepath Wealth Management, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Stonepath 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. SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 16 Http://stonepathwm.com  Privacy Policy Effective: April 16, 2025 Our Commitment to You SPWM Advisors LLC (“Stonepath 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. Stonepath 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. Stonepath 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 questionnaires and suitability Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment 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. SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 17 Http://stonepathwm.com  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. No Not Shared Marketing Purposes Stonepath 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 Stonepath 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 Stonepath 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 (231) 668-6999 or via email at info@stonepathwm.com. SPWM Advisors LLC 134 W State Street Suite 200, Traverse City, MI 49684 Phone: (231) 668-6999 Page 18 Http://stonepathwm.com