STAVIS WEALTH TRANSFER SOLUTIONS

STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Item 1 – Cover Page STAVIS WEALTH TRANSFER SOLUTIONS, LLC 1330 POST OAK BLVD, SUITE 2050 HOUSTON, TX 77056 (713) 391-8200 ADV-PART 2 BROCHURE (2A & 2B) November 30, 2025 This Brochure provides information about the qualifications and business practices of Stavis Wealth Transfer Solutions, LLC. If you have any questions about the contents of this Brochure, please contact us at (713) 391-8200. 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. Stavis Wealth Transfer Solutions, LLC or Stavis Wealth is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about Stavis Wealth also is available on the SEC’s website at www.adviserinfo.sec.gov. ~ i ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Item 2 – Material Changes This Firm Brochure provides you with a summary of Stavis Wealth Transfer Solutions, LLC or Stavis Wealth’s advisory services and fees, professionals, certain business practices and policies, as well as actual or potential conflicts of interest, among other things. This Item is used to provide our clients with a summary of new and/or updated information; we will inform of the revision(s) based on the nature of the information as follows. st Quarter of 2025). This Item of the Firm Brochure will note only specific material updates or changes that are made to the Brochure and provide clients with a summary of such updates or changes. This Brochure is an update of the Firm’s Annual Updated ADV-Part 2 Brochure for March 2025 (1 MATERIAL UPDATE(S)/CHANGE(S)   Items 4 & 8: Firm Advisory Business & Advisory Services/Programs were updated. We have added disclosures in Item 4 – Advisory Business and Item 8 – Investment Strategies regarding certain third-party private equity and venture capital investment platforms and managers through which we may offer certain third party-managed private fund investment vehicles and that we may recommend to advisory clients.  Item 5: Advisory Fees-Compensation disclosures were updated generally and also to reflect an update in the Firm Principal’s affiliated broker-dealer as a registered representative. Item 10: Investment-Financial Industry Affiliation/Arrangement disclosures were updated to reflect strategic relationship arrangements with third-party private equity and venture capital managers.  Item 12: Brokerage Execution and Trading disclosures were updated.  Item 14: Client Referral and Other Compensation disclosures were updated to disclose strategic relationship arrangements and related compensation involving certain third- party private equity and venture capital managers. The Firm will provide you with a new updated Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Deborah Stavis, Firm Managing Principal/CEO, at dstavis@staviswealth.com. ~ ii ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Item 3 -Table of Contents Item 1 – Cover Page ............................................................................................................................................... i Item 2 – Material Changes.................................................................................................................................. ii Item 3 – Table of Contents.................................................................................................................................iii Item 4 – Advisory Business................................................................................................................................ 4 Item 5 – Fees and Compensation...................................................................................................................14 Item 6 – Performance-Based Fees and Side-By-Side Management.................................................. 19 Item 7 – Types of Clients.................................................................................................................................. 19 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 20 Item 9 – Disciplinary Information ................................................................................................................ 22 Item 10 – Other Financial Industry Activities and Affiliations........................................................... 22 Item 11 – Code of Ethics................................................................................................................................... 25 Item 12 – Brokerage Practices....................................................................................................................... 25 Item 13 – Review of Accounts........................................................................................................................ 30 Item 14 – Client Referrals and Other Compensation............................................................................. 31 Item 15 – Custody............................................................................................................................................... 31 Item 16 – Investment Discretion .................................................................................................................. 31 Item 17 – Voting Client Securities ................................................................................................................ 32 Item 18 – Financial Information ................................................................................................................... 32  Part 2B Brochure Supplement(s) – Pgs. 33-36 ~ iii ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Item 4 – Firm Advisory Business & Advisory Services/Programs Stavis Wealth Transfer Solutions, LLC (Stavis Wealth or Firm) is a wealth and estate advisory and asset management-advisory firm that provides financial and estate advisory and planning services as well as asset management and related wealth transfer solutions to clients, for a fee. The Firm offers and provides integrated wealth planning management and wealth transfer services to high-net-worth (HNW) individuals and their families. Included is the coordination with attorneys regarding estate planning trusts and related vehicles, charitable organizations, private and family foundations, family offices, and other corporate and business entities. These services are designed to assist our clients in identifying and realizing their personal and family financial and wealth planning objectives in coordination with their other professional advisors. Stavis Wealth was founded and is majority-owned and managed by its Managing Principal Deborah Stavis. Stavis Wealth, in offering financial/estate planning services and certain investment advisory supervisory services related to the client’s insurance policy, may also provide advice with respect to both discretionary and non-discretionary sub-accounts (fully dependent upon each individual carrier’s procedure). For such clients, we may provide other types of advisory services to the client from time to time, which can include investment policy advice and assistance, developing asset allocation strategies, manager selection and evaluation, and/or review of outside accounts to assist with adherence to investment policy guidelines. The types of service will be tailored to the needs of such clients and the availability of investment choices within each insurance policy. Services include an analysis based on client age, risk tolerance, and the availability and type of subaccounts (mutual-fund-like options) within each policy. When discussing investment options within a life insurance policy, both terms subaccount and Insurance Dedicated Funds (IDFs) may be used interchangeably. Stavis Wealth also renders investment management and asset advisory services for assets under management ("AUM") client accounts where the Firm provides such clients with on- going, continuous investment and asset management advisory services. We analyze existing portfolios, establish or assess financial and investment goals and objectives, and make recommendations. In accordance with the clients' risk profile and investment goals, we recommend securities, buy and sell them, and monitor their performance through the investing cycle. Each client has a unique portfolio guided by his or her individual investment objectives and goals and any related investment policy statement or other written investment parameters. We consider all client assets that are disclosed to us to provide a holistic investment approach for clients AUM and investment accounts. We offer non-discretionary and discretionary portfolio and asset management services. Our investment advice is tailored to meet our clients' needs and investment objectives while also observing any investment restrictions. Such advisory clients should also receive an independent statement of the portfolio directly from the independent qualified custodian. ~ 4 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 For the Firm’s financial-wealth and estate advisory services involving client planning objectives and the client's financial and investment position, Stavis Wealth will prepare a financial, wealth and estate plan designed to meet such client objectives. We offer financial and wealth planning to clients as an independent service or as part of additional advisory, planning and/or consulting services. Certain aspects of financial-wealth planning include furnishing of investment advice as defined by the Investment Advisers Act of 1940, as amended (“Advisers Act”), in which the Firm acts as a fiduciary under the Advisers Act. Financial planning services are provided to advisory clients through a variety of means, including through in-person meetings, video conferences, telephone calls, digital platforms, e-mail, reporting, or a combination thereof. We also have available to us and use a variety of proprietary and/or third-party tools to aid in delivering financial planning services to financial and wealth planning strategies and Implementation of our clients. recommendations is entirely at the client’s discretion. Also, Stavis Wealth is not required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains the client’s responsibility to promptly notify the Firm if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating, and/or revising the Firm’s previous recommendations and/or services. Managing Principal, Deborah Stavis, and Firm Staff are available for consultations at the Firm’s contact number and to discuss any changes or updates to a client's financial situation. For financial planning, a conflict may exist between the interests of the Firm and the interest of the client to the extent the Firm recommends itself to support and assist with the implementation of its financial and wealth planning recommendations. The client is under no obligation to act upon our recommendations, and, if the client elects to act on any of our recommendations, the client is under no obligation to effect any transactions through us. Also, neither we nor anyone associated with us are attorneys, and therefore no advice that we confer should be construed as legal advice. Financial-Wealth Planning, Consulting, and Analysis Services Stavis Wealth also offers stand-alone financial, estate, and/or insurance planning services that typically encompass preparation of dynamic, easily understood and actionable recommendations, based on a thorough evaluation of clients’ personal financial situation and objectives (“Financial Planning” or “Financial-Wealth Planning”). The customized action plan specifies strategic measures for the clients’ immediate implementation and execution into an existing financial, wealth transfer and estate plan.  The Firm works with HNW individuals and families on their planning needs, including:     Estate/Legacy Planning  Wealth Planning & Multi-Generational Planning (Stewardship of family wealth) Wealth Transfer Planning and Solutions ~ 5 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025           Trust Planning & Trust Policy Management Strategic Planning and Family Governance Asset Protection Insurance Analysis & Risk Management Philanthropic/Charitable Planning & Giving  The Firm also works with business owners to develop plans for:    Ownership transitions Key employee retention  Discovers Planning is a dynamic and continuous process. The following is brief summary of the process we follow in estate and financial planning.  to understand what the client is most committed to accomplish, fix or  Analysis avoid, and collects financial information  Quantifies of client’s current situation, with special emphasis on uncovering gaps,  inefficiencies and opportunities. “What if” scenarios are modeled to determine the short and long-term impact of planning options  the impact of recommended solutions, using flowcharts, graphs and  Collaborates state of the art planning software  with the client’s multi-disciplinary team in order to provide a   balanced viewpoint and help the client make informed decisions. Implements observations and recommendations.   Provides   Monitors the clients’ desired estate planning decisions. the clients’ progress. Repeat/Update the process as circumstances warrant. Financial-Estate & Wealth Planning Advisory Services Stavis Wealth offers Financial Planning to clients as an independent service or as part of another service offering. Certain aspects of Financial Planning and Financial-Wealth Planning also include delivery of investment advice as defined by the Investment Advisers Act of 1940, as amended (“Advisers Act”). Financial Planning varies among Wealth Advisors, clients, and the tools utilized by Wealth Advisors, as explained in more detail in Item 4 – Tools for Financial Planning; Tailoring Financial Planning below. Not all clients will receive Financial-Wealth Planning services. Financial Planning and Financial-Wealth Planning generally focuses on planning related to compensation and employment benefits, cash- flow, retirement, estate, insurance, investment, philanthropic, and tax, as may be appropriate. Depending on the level of service, Financial Planning is provided to the client either through meetings or digitally whereby the Wealth Advisor and the client will work together to develop a written or verbal financial plan and, with client cooperation, will endeavor to review risk profiles and objectives with clients no less than annually and update the financial plan to account for changes in the client’s situation. Stavis Wealth clients are not required to implement their financial plans through products and services offered by Stavis Wealth or its affiliates (each in their capacities as asset managers, broker-dealers, or insurance agencies, as applicable). ~ 6 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Clients deciding to implement any portion of their financial plans through Stavis Wealth, or its affiliates generally do so by entering into separate agreements with Stavis Wealth or an affiliate. Stavis Wealth does not have discretion over specified client assets as part of Financial Planning, but may have discretion from time to time as part of assets under management-supervision advisory services. Corporate partner groups or associations often have other relationships with Stavis Wealth as vendors, partners, or clients and they, their employees, or participants may receive benefits or preferential fees or rates as a result of such other relationships. See Item 5- Negotiated Fees. In addition to the above services, Financial Planning is also offered to supplement advisory services made available to certain current or prospective clients serviced by other RIAs, private wealth advisors, advisory personnel with other RIAs, and family offices. When Stavis Wealth provides Financial Planning only to current or prospective clients they undertake no responsibility for, and provide no investment or brokerage services related to, such clients’ investment accounts unless otherwise agreed to in writing. Stavis Wealth offers Financial-Wealth Planning through the various programs described below: Executive Wealth Executive Wealth programs and services offered by Wealth Advisors are made available to executives and high-net-worth clients directly or through an RIA or family office. Comprehensive estate and financial plans intended to maximize compensation and benefit programs, preserve and/or grow assets, manage income on a long-term basis, and integrate tax, retirement, and estate plans and goals. In order to deliver comprehensive financial planning services, Wealth Advisors analyze a number of factors, including, as applicable, the client’s financial status, sources of income, assets, personal obligations and debts, objectives, commitments, cash flow, family responsibilities and the effect of the existing income and estate tax structure on the client’s sources of income and accumulation of wealth. Family Office Family Office services are designed to help individuals and families with significant wealth manage their complex financial affairs. Family Office services can be provided to clients directly or through an RIA and often includes work with several generations within one client family and coordination with the individual’s or family’s other advisers (as directed). In many cases, Family Office services offer high-net-worth individuals and families an alternative to creating their own family office. Services include estate and trust planning and insurance policy trust management, review and evaluation of subaccounts within life insurance, portfolio monitoring, philanthropic and foundation planning, cash flow planning, tax planning and insurance audits. ~ 7 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Tools for Financial Planning As referenced above, Financial Planning and Financial-Wealth Planning services are provided to clients through a variety of means, including through in-person meetings, video conferences, telephone calls, digital platforms, e-mail, reporting, or a combination thereof. Stavis Wealth staff have available to them a variety of proprietary and third-party tools to aid in delivering such planning services to clients. Tailoring Financial Planning Financial Planning and Financial-Wealth Planning is typically designed to be personalized to the client, including such client’s unique circumstances and needs, personal financial goals, net worth, and/or complexity. Accordingly, the scope, duration, advisory personnel, deliverables, and channels through which such planning is provided will vary among clients and services based on a variety of factors. Financial Planning will also vary among clients as a result of agreements with Stavis Wealth. Stavis Wealth will develop programs with certain corporate partners and community-based organizations and associations. Financial and Estate Planning programs will vary among organizations and groups participating. Certain programs may be tailored to address certain corporate partner or community organization needs or client events. Financial and estate planning does not always address every aspect of a client’s financial life. Omission of one or more financial planning topics from discussions with Stavis Wealth advisors may be the result of differences and/or insufficient information provided by or on behalf of a client. Such omissions do not indicate that the Financial Planning topic is not relevant or applicable to the client’s financial situation, and clients are encouraged to consult with their other advisors regarding such topics (e.g., tax and legal counsel). In some situations, clients may also be eligible for reduced or waived fees due to certain arrangements, such as legacy relationships with Stavis Wealth principals. Reliance on Information in Financial Planning In providing Financial Planning, Stavis Wealth relies on the accuracy and completeness of information provided by or on behalf of clients and does not assume responsibility to independently verify the accuracy or completeness of such information. Stavis Wealth does not assume responsibility to review, respond to, or incorporate into its services any materials uploaded by or on behalf of the client to any electronic storage system made available to clients. Clients must consult with and inform their designated Firm Staff regarding any specific materials they would like to include in the services. Certain Insurance Services &Trust Related Services Individuals affiliated with the Firm provide insurance and design recommendations to ~ 8 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025  clients, as appropriate. We represent a wide range of life insurance, annuities, disability and long-term care products.     Periodic monitoring of sub- accounts within variable life insurance and annuity  policies. Annual trust policy management, including policies held within an irrevocable trust Establish Trust related accounts to facilitate premium payment. With the exception of ongoing asset monitoring and investment supervisory services, assuming prompt provision of all information from the client, our financial planning services are typically completed within 30-60 days of our engagement. Unless specifically requested by the client and agreed in writing, our performance of these services is typically accompanied by a formal written financial plan. On occasion, planning may be done on a project basis which may take the form of an informal written summary or checklist of action items and recommendations. Our final set of recommendations will be updated at least annually or upon a client’s specific request and upon re-engagement of our firm for such update(s) and the payment of a new advisory fee. Implementation of our recommendations will be at the exclusive discretion of the client and may be completed by our firm for an additional cost as agreed in writing. The client is under no obligation to use our firm to implement any recommendations provided. Tailored/Customized Advisory Services – Financial/Wealth & Estate Planning Stavis Wealth also offers personalized financial/wealth and estate planning advisory services, developed as a hybrid of any of the foregoing service offerings that are tailored to the unique needs of the client’s situation and financial reality. During the first information share meeting we will determine an appropriate mix of services based on the needs and circumstances of the client. The advice we provide is driven by each client’s individual, liquidity needs, generational financial objectives, goals, personal risk assessment, requirements, charitable desires, coordination of estate and trust planning documents with their attorney, and accountant for tax considerations. According to these needs, we develop and recommend an appropriate strategic plan. -Examples of the products we might recommend include: life insurance, both fixed and variable, (including private placement life insurance), annuities, variable annuities, long- term care, and disability. Ancillary Services Upon request, we may review a client’s existing estate plan and make recommendations in conjunction, with legal and accounting advisors, to provide guidance regarding the probate process, coordination, control, and distribution of assets to several various entities. These services offered in collaboration with legal counsel are provided to address certain issues with estate taxes, post-mortem control of assets, and other key details of a client’s post- mortem plan. ~ 9 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Trust Policy Management         Supervising/Oversight Advisor to Insurance Dedicated Funds within PPLI/PPVA Notices regarding the timing of the gift to the Trust checking account Notification to beneficiary regarding withdrawal rights (Crummey Powers); continuous updating to the number of beneficiaries for utilizing the annual gift tax exclusion(s) Notification to Trustee regarding timing of premium payment Handle administrative policy details such as resignation and appointment of Trustees, change of address, etc. (“PPLI”) and private placement variable annuities Stavis Wealth may recommend that certain clients invest in private placement life insurance (“PPVA”). When recommending PPLI, Stavis Wealth refers the client to appropriate insurance carriers in order to evaluate the individual Client’s specific needs and, when appropriate, may recommend a PPLI policy. After the PPLI policy is created, Stavis Wealth may be hired by the Client insured under the PPLI policy as a supervising or oversight advisor to help supervise the assets of the policy. The PPLI policy is a sponsored insurance dedicated fund ("IDF"). An IDF may also operate as one or more private investment funds each being organized as a designated series (each a "Fund") that is housed within an investment sub- account. Such IDFs are offered solely to segregated asset accounts of insurance companies established for the owners of private placement variable life insurance contracts or private placement variable annuity contracts. Each Fund typically has the ability to invest globally in speculative investments utilizing a variety of financial vehicles, including without limitation, funds, private investment vehicles, hedge funds, stocks, bonds, pools, warrants, options, preferred and convert debt and equity, real estate and any other investments which may be legally invested in by the Fund under applicable law. The investment strategy applicable to investments in all Funds varies from seeking capital preservation to capital appreciation. Investors in the Funds may not impose restrictions on the types of Private Placement Insurance Programs & Investment Sub-Accounts securities purchased. Through insurance sponsors or insurance broker/agents, accredited investors may choose to invest in PPLI or PPVA with the segregated investment account managed under the insurance sponsor’s PPLI or PPVA investment sub-account program. PPLI is a variable universal life insurance policy that provides a segregated investment account and a life insurance benefit. PPVA enables investors to defer income tax on investment gains without the traditional retail variable annuity features such as income guarantees or principal protection, thus reducing the internal fees. The life insurance portion of these products is Financial-Estate Planning and Ad v i so r y - Consulting Services provided through the insurance sponsor company. Stavis Wealth can provide financial planning and/or consulting services (including estate ~ 10 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 planning, insurance planning, divorce planning, etc.) to the extent specifically requested by a client. Financial and estate advisory planning or consulting fees are negotiable as described in Item-5 Fees and Compensation. Stavis Wealth provides certain clients with access to an online platform hosted by eMoney Advisor Advisors, LLC (“eMoney”). The eMoney platform allows a client to view their complete asset allocation, including those assets that Stavis Wealth does not manage. The Firm does not provide investment management, monitoring, or implementation services for any assets. should not The eMoney platform also provides access to other types of information and/or reports, including financial planning concepts. The generated information and/or reports are provided for educational purposes only and the client rely on it as the primary basis for insurance, investment, financial, and/or tax planning decisions. The generated report is not a recommendation of any investment strategy or transaction, rather it is a tool for Stavis Wealth and the client to collaboratively: (i) confirm the accuracy of the information on the client’s risk tolerance and other personal and financial information, and (ii) solicit the client’s input and feedback to refine the approach for the client’s financial future. Stavis Wealth shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without Stavis Wealth assistance or oversight. Multi-Generational Strategic Planning & Family Retreats Stavis Wealth offers Family Retreats, typically a full day with the entire family in a non- office setting (including multi-generational family members). Each family participant completes a behavioral assessment that explores “how” they behave in various financial situations and their “why”, which reflects their values. Stavis Wealth combines financial information with the family dynamics utilizing the profile of each family member. A meeting typically includes a review of family assets, estate and income tax forecasts, along with ways to minimize estate tax. Ways to reduce estate tax, ranging from design ideas such as Family Limited Partnerships, Trusts and charitable gifts, whether in a Donor Advised Fund or a Private Foundation, provide ways to reduce the estate tax, along with a discussion of the most economic ways to pay the estate tax and examine ways to overcome misalignment among family members. Critically, we examine and help develop ways to align family members regarding an optimum estate and philanthropic strategy. Investment Advisory & Investment Supervisory-Oversight/Allocation Services Stavis Wealth currently provides discretionary and non-discretionary investment management or asset management services on a fee basis. The Firm also provides certain non-discretionary investment advisory services regarding family/estate and high-net- investment supervisory-oversight and related worth wealth advisory clients and investment allocation oversight services, including such services associated with the ~ 11 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 investment sub-accounts that exist in variable insurance products.  Options for investing the cash value within life insurance contracts are expanding at a significant rate, which creates:        Analysis of clients’ risk tolerance At least a quarterly review of both asset allocation within the subaccounts and the need for more active investment within the cash value of the policy to properly assess client risk tolerance, offer significant optionality and Active management within sub-accounts may require additional monitoring at least quarterly Provide an annual update and performance report on each insurance policy The Firm provides discretionary and non-discretionary services to allocate and reallocate its advisor supervisory and insurance-related investment subaccounts as part of oversight services for such clients. In certain instances, advisory clients may grant us, respectively, discretion to: (a) select variable subaccounts for clients’ existing variable annuities and (b) allocate and reallocate any premiums among the variable subaccounts available from the specific annuity sponsor. In performing variable subaccount allocation services, the Firm will only consider the variable subaccount investment options available within the specific insurance or annuity purchased by the client. The Firm does not determine which variable subaccount options are made available by insurance companies or product sponsors, and variable subaccounts are not custodied at the Firm. If a client has not granted discretion regarding variable subaccounts as described above, the Firm will provide investment allocation and supervisory-oversight support services in coordination with the advisory client’s approval, along with providing certain clients with educational support regarding asset allocation principles or examples of model portfolios. Selection of Other Advisers From time to time, the Firm may recommend that you use the services of a third-party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, and client financial needs, investment goals, risk tolerance, and investment objectives. The TPMM(s) will actively manage your portfolio and will typically assume discretionary investment authority over your account. We will monitor the TPMMs' performance to ensure its management and investment style remains aligned with client investment goals and objectives. Investment Advisory Services & Types of Investments The Firm offers advice on equity securities, mutual funds, ETFs, and certain index options, as well as other various types of investments based on your stated goals and objectives. We ~ 12 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment. Private/Alternative Funds & Third-Party Investment Platforms rd rd Stavis Wealth also offers alternative investment strategies through third-party managers. These investments carry risk and are designed for investors that meet the qualified purchaser, qualified client, or accredited investor definitions. Stavis Wealth has a party unaffiliated private equity and venture capital relationship with GLASfunds, a 3 investment platform through which we may offer certain 3 party-managed private fund investment vehicles and that we may recommend to advisory clients. From time to time, Stavis Wealth recommends private equity funds offered through the GLASfunds (“GLAS”) platform. GLAS provides discretionary investment advisory services to GLASfunds, LP and GLASfunds, SPC (each, a “Fund”, and together, the “Funds”). Each investor in a Fund, with assistance from GLAS, will allocate its investment in each Fund to one or more investment strategies (each an “Investment Strategy”). Each Investment Strategy constitutes a separate series of interests or shares of the relevant Fund. Private funds are typically only available to high-net-worth individuals who qualify as accredited investors or qualified purchasers and who meet minimum investment thresholds. We recommend GLAS to investors who meet the relevant investment qualifications and for whom a private fund is appropriate based on investing goals and objectives. At the time of investment, you will receive fund-related offering documents, questionnaires, and disclosures outlining the risks, costs, and other pertinent information. Additionally, to the extent Stavis Wealth receives non-cash compensation from GLAS, this would create a conflict of interest (see also Item 14 – Client Referrals and Other Compensation for additional related disclosures). Regardless of how the client engages our firm, Stavis Wealth focuses on delivering investment advisory services are tailored to their unique circumstances, goals, and objectives. We manage the client’s account based on their financial situation and investment objectives and in accordance with any reasonable restrictions imposed by them in terms of the advisory management of the client’s account. (For additional related information, please also see GLAS/GLASfunds ADV-Part 2 Brochure.) from such vendors from time to time, which can Also in maintaining and engaging in business relationships or arrangements with certain third-party vendors, including GLAS-GLASfunds, Stavis Wealth or its staff may receive non- include cash compensation reimbursement or payment for travel, lodging, meals, entertainment, or participation in conferences and other events. To the extent this may occur, this creates a conflict of interest as these benefits create an incentive for Stavis Wealth or its personnel to promote the vendor providing the incentive or recommend investments on the GLASfunds platform over other platform options in order to continue receiving such non-cash compensation ~ 13 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 benefits. To mitigate this conflict, we make all investment recommendations based on our independent analysis consistent with each client’s best interests and related financial and investment objectives and risk tolerance parameters. In addition, Stavis Wealth has formed a strategic alliance or partnership arrangement with one or more third-party private equity and venture capital fund managers as described below. Curate Capital LLC and Stavis Wealth have entered into a strategic relationship whereby Stavis Wealth is a cornerstone fund investor and strategic partner. Stavis Wealth clients are able to access Curate Capital Private Funds on terms which are generally more favorable than those that are generally available to private alternative fund investors. Stavis Wealth also has received an economic-financial interest in the carried interest fees that may be earned by Curate with respect to the funds where Stavis Wealth is a strategic partner, which gives rise to conflicts of interest as Stavis Wealth has an incentive to recommend clients invest in such Curate Funds. Carnrite Ventures LLC and Stavis Wealth have also entered into a strategic relationship whereby Stavis Wealth clients will have access to Carnrite Ventures funds. Stavis Wealth also has received an economic-financial interest in the carried interest fees that may be earned by Carnrite Ventures with respect to the funds where Stavis Wealth is a strategic partner, which gives rise to conflicts of interest as Stavis Wealth has an incentive to Wrap-Fee Investment Programs recommend clients invest in such Carnrite Ventures Funds. Stavis Wealth is not a portfolio manager of, nor a sponsor of, wrap-fee investment programs. Certain of our clients may participate in wrap-fee programs through the use of certain third-party money managers. (See disclosure above regarding Selection of Other Advisers). Assets Under Management/Supervision As of March 31, 2025, the Firm has total advisory assets under management and supervision (AUM) of approximately $120.8 million, consisting of approximately $11.49 million of AUM on a discretionary basis and approximately $109.3 million of AUM on a non- discretionary basis. Item 5 – Fees and Compensation The specific manner in which fees are charged by Stavis Wealth is established in an advisory client’s written advisory services agreement with the Firm. Our advisory agreement does not include any assets under management or AUM fees on the subaccounts within a life insurance policy for which the Firm is providing supervisory services. These services are provided for clients who either have, or plan to purchase, life insurance policies through Stavis Wealth. ~ 14 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 We receive the following advisory and financial/wealth planning fees in connection with our services to clients. All client fee arrangements are set forth in written advisory agreement. Fees are generally calculated on an annual project basis, payable at the time of engagement, and are due upon receipt of invoice. Either party may terminate the financial/wealth planning and/or estate planning agreement within 30 days. Financial/Estate & Wealth Transfer Planning Advisory Fees Our Firm charges advisory fixed-fees for financial/wealth, estate, and philanthropic planning services, on a case by case basis. Total fees charged are generally based on the scope and complexity of the engagement and the time, research, and other resources that will be devoted to complete the services. FINANCIAL/ESTATE PLANNING & WEALTH ADVISORY FEE SCHEDULE NET WORTH ($ in Millions) BASIS POINT % APPLIED FEE STRUCTURE $0 - $25 (Not Applicable) Next $25 100 BPS (1.0%) per Million Next $50 100 BPS (1.0%) per Million Next $100 50 BPS (0.5%) per Million Over $200 25 BPS (0.25%) per Million $25,000 (Maximum) $50,000 (Maximum) $100,000 (Maximum) $150,000 (Maximum) $250,000 (Minimum) Fixed-Fees generally range from $5,000 to $100,000 depending on the mix of assets, scope and complexity of the engagement. The above fees exclude charges from other professionals during the course of the engagement such as Attorneys, CPAs, Business Valuation Experts, Estate-Financial Planning Project Services and Trustee fees. A flat or fixed project fee may be paid to our Firm for standalone financial planning/consulting services as agreed by the parties in writing based on the scope and complexity of such services, which is evaluated case by case and determined in the proposal meeting. The financial planning fee and scope of services is generally reviewed annually. ~ 15 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Assets Under Management Fee Schedule ASSETS UNDER MANAGEMENT FEE SCHEDULE Under 2MM 100 BPS 2MM-4MM 75 BPS 4MM-6MM 65 BPS 6MM-10MM 55 BPS 10MM and Over Negotiable flat fee from $1 invested Where mutually agreed, the Firm will offset planning-consulting fees with the asset under management fees in providing both types of advisory services. Where the Firm is not engaged for financial-estate planning services, the Firm will provide asset management Trust Policy Management Services advisory services only. The Firm will charge a $3,500-$5,500 annual fee, payable at time of engagement, in order to maintain the integrity of the estate plan and specific trusts, as they relate to the estate and estate tax protection plan. The processes and multi-step services are listed above, and such annual fee range is based on complexity and scope of work. In any year where a financial and estate planning fee is paid by the client, the cost of trust policy management servicing and the related trust policy management fee will be included in the annual financial planning retainer, rather than charged as a separate fee. Stavis Wealth reserves the right to extend Trust Policy Management Services to legacy clients per a different fee schedule, including up to a waiver of the fee. Life Insurance Policy Audits The Firm’s fee for a life insurance policy audit is $2500. This includes an assessment of the current valuation, planned premium payment, and in-force ledger examination to determine policy performance as it relates to client objectives. This fee may be waived for advisory clients who engage the Firm under a Financial-Estate Planning Contract Family Retreats Full-day family meetings generally have an associated $10,000 fee, excluding airfare and hotel expenses. Stavis Wealth retains the right to modify this fee based on complexity and content, agreed upon by client. ~ 16 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Brokerage Products & Related Commissions Firm’s Managing Principal earns additional compensation if a client purchases investment products through Benefit Funding Services (BFS) where the Managing Principal is also affiliated as a registered representative. This compensation is in the form of fee commissions. Because of receipt of this economic benefit, the Firm has a potential conflict of interest if it recommends to its advisory clients that they purchase investment products through BFS. This gives us an incentive to recommend investment products based on the compensation that the Managing Principal will receive. Nonetheless, we believe that we have addressed this conflict of interest because clients are under no obligation to purchase investment products through BFS or the Firm’s staff. Further, advisory clients have the option to purchase investment products that we recommend through other brokers or agents not affiliated with the Firm. Any commission/fee that individual Firm staff receives from the sale of investment products is in addition to the advisory fee the Firm charges, which advisory fee will not be reduced to offset the commission/fee that is received. Private Investment Funds/Vehicles Management Fee Compensation/Sharing Stavis Wealth may recommend affiliated or unaffiliated private funds, and the Firm may from time to time receive revenue fee sharing from or related to investments by non-Stavis Wealth clients in certain private investment vehicles that Stavis Wealth sponsors up to a one percent (1.0%) management fee. When investing in a private fund offered by Stavis Wealth, the client will not pay a fund level management fee. Clients should review the offering documents and applicable ADV’s of the fund and its fund investment manager prior to investing to understand all the fees and expenses associated with the investment. There is a conflict of interest when the Firm recommends an advisory client invest in certain private funds and/or in a strategic or alliance partner fund because Stavis Wealth earns additional fee and/or non-fee compensation. Regardless how the client engages our firm, Stavis Wealth focuses on providing investment advisory services that are tailored to their unique circumstances, goals, and objectives. We manage the client’s account based on the client’s financial situation, investment objectives, and risk parameters and in accordance with any reasonable restrictions imposed by the In addition, see the client in terms of the advisory management of the client’s account. disclosure above under “Private/Alternative Funds & Third-Party Investment Platforms” with respect to certain additional incentive fee allocations that Stavis Wealth may earn from its strategic partnerships. Insurance Products & Related Commissions Commissions are also received for insurance policies placed, which are dependent on product type, rating, premium, and any specific client objectives. The Firm’s Managing Principal also earns additional compensation from insurance companies in the form of fee compensation for all insurance in force and will receive compensation for the sale of insurance products from advisory and non-advisory clients. Please see further information in Item 10 below relating to the additional registrations and affiliations disclosed in this ~ 17 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Item 5, including information pertaining to conflicts of interest arising out of these other registrations and affiliations of certain Firm staff. Sharing of Financial and Estate Planning Fees In certain instances from time to time, Stavis Wealth may pay certain fees to private wealth managers that obtain financial data and client objectives in coordination with the governing estate plan. Such fees will be disclosed to the client in a separate form, and the amount will vary based upon the time and effort expended by the private wealth manager. Additional Information As indicated above, Stavis Wealth may price its advisory services based upon various objective and subjective factors. As a result, Stavis Wealth’s clients could pay diverse fees based upon the complexity of the engagement, and the level and scope of the overall financial advisory/estate planning services to be rendered. As a result of these factors, the services to be provided by Stavis Wealth to any particular client could be available from Related/Associated Person Employee Accounts other advisers at lower fees. : As an employee and/or other related persons or affiliates, such persons or entities may be allowed to invest in the Firm’s strategies as a client at no cost or a reduced cost. Firm managed employee or other related party accounts are managed in a manner consistent with Firm’s fiduciary duty to all Clients. Item 6 – Performance-Based Fees and Side-By-Side Management Stavis Wealth does not currently charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Any related performance-based fee compensation will be applied and assessed in accordance with the SEC Performance Fee Rule (Rule 205-3). However, Stavis Wealth will receive allocations of certain incentive fees earned by certain of its private fund strategic partners as more fully described under “Private/Alternative Funds & Third-Party Investment Platforms” above. Item 7 – Types of Clients Stavis Wealth provides financial, wealth and estate planning advisory services and related wealth transfer consulting services to individual and high-net-worth investors, family offices, trusts, charitable organizations and foundations, and small business companies and other corporate clients. ~ 18 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Item 8 – Methods of Analysis, Investment Strategies & Risk of Loss Investment Strategies & Methods of Analysis Stavis Wealth’s methods of analysis and investment strategies are focused on investment advisor supervisory services. Additionally, regarding the cash value within life insurance contracts (sub-accounts) and related sub-account investment or allocation options. Variable Insurance & Variable Annuities (“VA”): Variable insurance and VAs are types of insurance or annuity contracts that allow for the accumulation of capital on a tax-deferred basis. As opposed to a fixed annuity that offers a guaranteed interest rate and a minimum payment at annuitization, VAs offer investors the opportunity to generate higher rates of return by investing in equity and bond sub-accounts. If a VA is annuitized for income, the income payments can vary based on the performance of the subaccounts. Risks associated with VAs may include: • Taxes and federal penalties for early withdrawal; • Enduring surrender charges for early withdrawal; • Earnings taxed at ordinary income tax rates; • Mortality expense to compensate the insurance company for insurance risks; • Higher fees and expenses imposed for the subaccounts; • Other features with additional fees and charges; and • Investment losses. Private Placement Life Insurance (PPLI) & Private Placement Variable Annuities (PPVA): PPLI and PPVA products are long-term investments similar to variable life insurance products, except that purchasers are able to invest policy premiums into various alternative investments. In addition to the risks associated with VAs set forth above, PPLI and PPVA products also present the risk that, as unregistered securities products, they are not subject to the same regulatory requirements and oversight as their registered counterparts. PPLI and PPVA products are not suitable for all investors. An investment in PPLI or PPVA products is subject to fluctuating values of the underlying investment options and it entails risk, including the possible loss of principal. You should consider the investment objectives, risks, charges, and expenses of any PPLI or PPVA product carefully before investing. Additional risk disclosures and other important information about PPLI and PPVA products are contained in their offering memorandums, which clients are urged to carefully review with their tax and legal advisors before investing. The Firm may manage various variable insurance or annuity sub-accounts that are maintained directly with the insurance sponsor (“Sponsor”). Although such variable products and their respective sub-accounts may be represented on various reports or statements, the variable products are held directly with the Sponsor. Sub-account asset allocations may be limited by the Sponsor’s product fund options, and certain asset allocations may also be restricted by the Sponsor. In such cases when a reallocation is required, the Firm will direct and execute such reallocation transactions directly through the Sponsor. Clients must complete necessary documentation under the applicable variable ~ 19 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 insurance or annuity contract to grant the Firm access to information necessary to perform these services. Where client purchases a variable insurance or annuity contract, client will receive a prospectus or private placement memorandum (PPM) and should rely solely on the disclosure contained in such prospectus or PPM with respect to the terms and conditions of the variable insurance or annuity investment product. Client should also be aware that certain riders purchased with a variable insurance or annuity contract may limit the investment options and the ability to manage the sub-accounts. General Overview of Investments Stavis Wealth typically enters into discretionary agreements with clients granting Stavis Wealth the authority to engage and replace, if necessary, external investment managers and select individual securities. Firm Staff review clients’ existing portfolios and deliver recommendations based on a client’s individual risk tolerance, time horizon, and overall objectives. Stavis Wealth is responsible for determining a client’s overall target asset allocation, selecting investments, and implementing and maintaining the portfolio. Stavis Wealth may construct portfolios using a mix of cash and cash equivalents, exchange traded funds or notes, closed-end funds, mutual funds, individual equities, individual bonds, and private pooled investment vehicles or by allocating some or all of a given portfolio to a third-party separately managed account. In certain situations, Stavis Wealth can invest in strategies that involve the use of other, more esoteric assets such as financial derivatives or structured notes by engaging third-party managers or directly transacting in those assets. The Firm offers a platform of both equity, fixed income, and alternative investing strategies, through customized asset allocation, and uses a goals-based customized approach to portfolio management. Risk is considered at the security, strategy, manager, account, and/or portfolio level depending on a client’s objectives and recommended portfolio. Equity Investments/ Strategies The equity strategies vary by mandate, all with a focus on capital appreciation as a primary objective. Philosophies include dividend-based strategies, growth and GARP (growth at a reasonable price) strategies, value-based strategies, ESG/socially conscious strategies, and ETFs/ETNs/direct indexing strategies. In strategies other than direct indexing, we will select individual securities based upon fundamental analysis performed by our investment professionals. Firm Staff rely primarily on publicly available information in our analysis, supplemented by third-party research and analytical tools. Fixed Income Investments/ Strategies For our managed account fixed income strategies, our primary objective is capital preservation. Secondary objectives include providing steady income and the potential for capital appreciation. Our fixed income strategies are formed through a combined top-down and bottom-up perspective. From the top-down, we develop our economic outlook and interest rate strategy using macroeconomic and market data and trends. We will alter our duration, sector, and yield curve exposure targets based on this outlook. ~ 20 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Risk of Loss Stavis Wealth does not guarantee the future performance of sub-accounts managed or any specific level of performance, the success of any investment decision or strategy. The client understands that investment decisions made for the client’s sub account(s) are subject to various market, economic, political, and business risks. These investments are only recommended to sophisticated clients who meet required net worth and income qualifications. Clients are reminded that investing in any security entails risk of loss they should be willing to bear. Alternative Investments – Private Funds & Pooled Investment Vehicles Stavis Wealth does not guarantee the future performance of private funds and pooled investment vehicles. These investments carry risk and are designed for investors that meet qualified purchaser, qualified client, or accredited investor requirements as defined by SEC. Private investments are not liquid and cannot be readily sold or converted to cash or other securities. Clients should consider their liquidity needs before choosing to invest. Clients should review offering documents carefully before investing. From time to time, the Firm may recommend that qualified clients consider an investment in private investment funds, where appropriate. Private investment funds involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints, and lack of transparency. A complete discussion of risks is set forth in each fund’s offering documents which will be provided to each client for review and consideration. Certain private funds for qualified purchasers is available through the GLASfunds platform. There is a conflict of interest when a Wealth Advisor recommends a client invest in a private fund because the Firm earns additional compensation. These third party platforms and private fund managers offer varied investment strategies or series, with each having a distinct investment objective and terms. Examples of representative strategies or series include but are not limited to: private equity, private equity secondaries, venture capital, GP stakes, private equity co-investments, distressed credit, opportunistic credit, hedge funds, natural resources, real estate, infrastructure, royalties & minerals, corporate direct lending, private CLOs, asset-backed lending, emerging market debt, real estate lending, etc. In pursuit of each strategy or series of investment objectives, the fund investment manager may, without limitation, invest in private investment funds, separate accounts, co- investment vehicles, and other investment vehicles or accounts. The specific investment objectives of each strategy or series will be outlined in the fund or vehicle supplement and related offering documentation. Item 9 – Disciplinary Information Stavis Wealth has no disciplinary actions in its history and has no information applicable to this Item. ~ 21 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Item 10 – Other Financial Industry Activities and Affiliations Stavis Wealth is not and does not have a related company that is a (1) broker/dealer, municipal securities dealer, government securities dealer or broker, (2) investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund), (3) futures commission merchant, commodity pool operator, or commodity trading advisor, (4) banking or thrift institution, (5) accountant or accounting firm, (6) lawyer or law firm, (7) insurance company or agency, (8) pension consultant, (9) real estate broker or dealer, or (10) sponsor or syndicator of limited partnerships. Other Financial/Investment Industry Activities Any requested brokerage services or sales of investment brokerage products will be provided under a commission-based brokerage relationship with securities offered through Benefit Funding Services (BFS), a registered broker-dealer and Member FINRA/SIPC. Benefit Funding Services and Stavis Wealth are not affiliated companies. Under such an arrangement, you may choose to implement securities transactions through investment advisor Firm Managing Principal Deborah Stavis (or another Firm representative or “IAR”) in their respective capacity as a registered representative of BFS, a financial services company registered with the Financial Industry Regulatory Authority (“FINRA”) as a broker-dealer engaged in the offer and sale of securities and investment products. Brokerage commissions will be charged by BFS to process these securities transactions and thereafter, a portion of these commissions will be paid by BFS to our Firm’s BFS affiliated staff. Prior to effecting any securities transactions if you choose to use BFS at your option, you will be required to enter into a new account agreement with BFS. The brokerage commissions charged by BFS may be higher or lower than those charged by other brokerage firms or broker-dealers. The receipt of commissions creates an incentive to recommend those products for which a commission will be received. Consequently, the objectivity of the advice rendered to clients could be biased. This potential conflict of interest is controlled by generally informing clients of both the advantages and disadvantages of establishing commission- based accounts with BFS versus a fee-based advisory account through Stavis Wealth. Please be aware that you are under no obligation to purchase products or services recommended by us or members of our Firm in connection with providing you with any advisory service that we offer. Also, certain investment product sponsors may provide Stavis Wealth with other economic benefits as a result of the recommendation or sale of the product sponsors’ investments. The economic benefits received by Stavis Wealth from product sponsors can include but are not limited to, financial assistance or the sponsorship of conferences and educational sessions, marketing support, incentive awards, payment of travel expenses, and tools to assist Stavis Wealth in providing various services to clients. Although Stavis Wealth endeavors at all times to put the interest of their clients ahead of those of Stavis Wealth’s ~ 22 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 officers or representatives (“affiliated persons”), these arrangements present a conflict of interest which could affect judgment when recommending investment products. From time to time, Stavis Wealth strategic or alliance partners may refer prospective clients or private fund investors to us. In turn, Stavis Wealth may also refer clients to certain of our strategic or alliance partners. In such cases, Stavis Wealth will pay or receive direct or indirect compensation regarding the referral. Referrals of prospective clients present a conflict of interest to recommend strategic or alliance partners over others. Stavis Wealth seeks to mitigate this conflict by limiting recommendations to those Stavis Wealth believes to be in the best interest of our advisory clients and required disclosures are provided to referred prospects. Stavis Wealth considers a variety of factors when considering referral recommendations, including our advisory clients’ financial goals, objectives and portfolio, and the scope of our engagement. In all cases, it is our goal to provide our advisory clients with the services we believe best suit their needs. Other Industry Affiliations & Arrangements – Insurance Certain of Stavis Wealth’s advisory affiliates, including Firm Managing Principal Deborah Stavis, in their individual capacities, are also licensed insurance agents with various insurance companies, and in such capacity, may recommend, on a commission basis, the purchase of certain insurance products. Stavis Wealth does permit such affiliated persons, in their individual capacities as licensed insurance agents, to sell insurance products to its investment advisory clients and may receive compensation for the sale of such insurance products from advisory and non-advisory clients. A conflict of interest may exist to the extent that Stavis Wealth recommends the purchase of insurance products where Stavis insurance commissions or other additional Wealth’s affiliated persons receive compensation. Variable life insurance or variable annuity business is also placed through BFS, although the actual contracts are issued and serviced by insurance companies. Life insurance business is generally placed through insurance brokerage houses. A conflict of interest exists when Stavis Wealth recommends a commission-based product. The advisory client is informed of this inherent conflict and that the client can purchase the recommended insurance product from another agent. We also serve as a member of First Financial Resources (FFR Group), an invitational member association. The FFR Group is engaged to assist Stavis Wealth to select highly rated life insurance carriers that can provide clients with “Best in Class” support. Its insurance carriers generally include, but are not limited to, American General, Delaware Life, Genworth, John Hancock, Lincoln, MetLife, Nationwide, One America, Pacific Life, Penn Insurance company licensing Mutual, Principal, Prudential, Securian and State Life. appointments are generally set up both by carrier and the state in which business is conducted, and such insurance carriers typically identify both the writing agent and the servicing agent for each insurance product policy. Where insurance carriers are selected by the client, the Firm Managing Principal will ~ 23 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 receive compensation for the sale of insurance products to advisory and non-advisory clients. For clients who purchase products causing commissions to be generated from such purchases, these commissions are paid to the Firm Managing Principal in her separate capacity as an insurance agent. This activity represents a conflict of interest and may give her an incentive to recommend the purchase of insurance products for a client account based on that person’s ability to receive compensation from such a purchase. However, the Firm believes that it has addressed this conflict by (a) requiring that any such transaction will be on commercially reasonable terms that are generally consistent with industry standards, and (b) neither requiring nor expecting that a client will purchase any such insurance product from or through Firm Managing Principal. In addition, the Firm Managing Principal must maintain compliance with applicable rules and regulations that govern the sale of such products. Other Fee-Sharing Arrangements – Financial/Estate Planning Fees instances, Stavis Wealth may pay certain fees to private wealth In certain managers/advisors that work in collaboration with the Firm and its staff and that obtain financial data and client objectives in coordination with the governing estate plan and our related Firm services. Such fees will be disclosed to the client in a separate form, and the Insurance Commissions – Fee Sharing amount will vary based upon the time and effort expended by the private wealth manager. In certain cases, commissions may be shared with other licensed advisors. Any and all sharing arrangements are disclosed to the client in advance of any transaction. Item 11 – Code of Ethics Stavis Wealth’s Code of Ethics covers all supervised persons of the firm and describes its standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, and personal securities trading and reporting procedures, among other things. All supervised persons at Stavis Wealth must acknowledge the terms of the Code of Ethics annually and also follow the Firm’s Code of Ethics. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Stavis Wealth will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Employee trading is monitored on a quarterly basis under the Code of Ethics to reasonably prevent conflicts of interest between Stavis Wealth and its clients. To supervise compliance with its Code of Ethics, the Firm requires that anyone associated with this advisory practice with access to advisory recommendations provide annual securities holding reports and quarterly transaction reports to the firm's Compliance department. The Firm also requires such access persons to receive approval from the Compliance department prior to investing in any initial public offerings or private placements. Stavis Wealth’s clients or prospective ~ 24 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 clients may request a copy of the Firm's Code of Ethics by contacting Deborah Stavis, Firm Managing Principal/CEO, at dstavis@staviswealth.com. It is Stavis Wealth’s policy that the firm will not affect any principal or agency cross- securities transactions for client accounts. Stavis Wealth will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Item 12 – Brokerage/Trading Practices Stavis Wealth determines, in good faith, that Where the client grants discretion for or requests Stavis Wealth to recommend a broker- dealer/custodian for execution and/or custodial services (exclusive of those clients that may direct Stavis Wealth to use a specific broker-dealer/custodian), Stavis Wealth generally recommends that investment management or advisory accounts be maintained at an independent and unaffiliated broker-dealer/custodian. Factors that Stavis Wealth considers in recommending such broker-dealer/custodians include historical relationship with the Firm, financial strength, reputation, execution capabilities, pricing, research, and service. Although the commissions and/or transaction fees paid by Stavis Wealth's clients will comply with the firm's duty to obtain best execution, a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same the transaction where commission/transaction fee is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although Stavis Wealth will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client account transactions. The brokerage commissions or transaction fees charged by the designated unaffiliated broker- dealer/custodian are exclusive of, and in addition to, Stavis Wealth's investment management or advisory fees. Stavis Wealth’s best execution responsibility is qualified if securities that it purchases for client accounts are mutual funds that trade at net asset Custodian & Broker(s) Usage value as determined at the daily market close. Stavis Wealth does not maintain custody of client assets on which we advise and that we may manage from time to time. Your assets will be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We generally recommend that our clients use Fidelity (Broker), a registered broker-dealer, as the qualified custodian, and we are independently owned and operated and are not affiliated with Broker. Broker will hold ~ 25 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Broker as custodian/ broker, you will decide whether to do so and will open your account with Broker by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 as applicable (advisory client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. The Firm does not open the account for you, although we may assist you in doing so with Broker. Even though your account is maintained at Broker, and we anticipate that most trades will be executed through Broker, we can still use other brokers to execute trades for your account as described below (see “Brokerage and Custody Costs” and Selecting & Using Brokers/Custodians “Directed Brokerage”). We use Broker, a custodian/broker, to hold your assets and execute transactions. When considering whether the terms that Broker provides are, overall, most advantageous to you when compared with other available providers and their services, we take into account a range of factors, including: Brokerage and Custody Costs • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • 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 and price competitiveness of such services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate prices • Reputation, financial strength, security and stability • Prior and ongoing service to us and our clients • Availability of other products and services that benefit us, as discussed below (see “Products/Services Available from Broker”). For our clients’ accounts that Broker maintains, Broker generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Broker account. Certain trades (for example, mutual funds and ETFs) do not incur Broker commissions or transaction fees. Broker is also compensated by earning interest on the un-invested cash in your account in Broker’s Cash Features Program. Broker’s commission rates applicable to our clients’ accounts were negotiated based on the condition that our clients collectively maintain a certain total level of aggregate assets in accounts at Broker. This commitment benefits clients because the overall commission rates paid are lower than they would be otherwise. In addition to commissions, Broker charges you a flat dollar amount as a “prime-broker” or “trade-away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) ~ 26 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 into your Broker account. These fees are in addition to the commissions or other compensation you pay the separate executing broker-dealer. Because of this, in order to minimize your trading costs, we have Broker execute most trades for your account. We are not required to select the broker-dealer that charges the lowest transaction cost, even if that broker-dealer provides execution quality comparable to other broker-dealers. Although we are not required to execute all trades through Broker, we have determined that having Broker execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means seeking the most favorable terms for a transaction or trade based on all relevant factors under the surrounding circumstances, including those listed above (see “Selecting & Using Brokers/Custodians”). By using another broker-dealer, you may pay lower transaction costs in certain instances. Products/Services Available to the Firm from Broker Broker Fidelity operates a platform business serving independent investment advisory firms like us. They provide our clients and us with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Broker retail customers directly. However, certain retail investors may be able to get institutional brokerage services from Broker without going through us. Broker also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Broker’s support services are generally available on an unsolicited basis (we do not have to  request them) and at no charge to us. Services that Generally Benefit Clients A more detailed description of Broker’s support services follows. . Broker’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Broker include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Broker’s services described in this paragraph Services that Do Not Directly Benefit Clients generally benefit you and your account. . Broker also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Broker’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Broker. In addition to investment research, Broker also makes available software and other technology that: i) provide access to client account data (such as duplicate trade confirmations and account statements); ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; iii) provide pricing and other market data; iv) facilitate payment of our fees from our clients’ accounts; Services that Generally Benefit Only the Firm and v) assist with back-office functions, recordkeeping, and client reporting. . Broker also offers other services intended to help us manage and further develop our business enterprise. These services include: i) Educational conferences and events; ii) Consulting on technology and business needs; iii) ~ 27 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Consulting on legal and compliance related needs; iv) Publications and conferences on practice management and business succession; v) Access to employee benefits providers, human capital consultants, and insurance providers; and vi) Marketing consulting and support. Broker provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Broker also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. If you did not maintain your account with Broker, we would be required to pay for those services from our own resources. Our Interest in Broker’s Support Services The availability of these support services from Broker benefits us because we do not have to produce or purchase them and do not have to pay for Broker’s services. The fact that we receive these benefits from Broker is an incentive for us to recommend the use of Broker rather than making such a decision based exclusively on your interest in receiving the lowest price or cost in custody services and in the execution of your transactions. While this is a conflict of interest, we believe, however, that taken in the aggregate our selection of Broker as custodian and broker is in the best interests of our clients and is consistent with seeking best execution under the circumstances. Our selection is primarily supported by the scope, quality, and price of Broker’s services (see “Selecting & Using Research/Additional Benefits Brokers/Custodians” above) and not Broker’s services that benefit only us. Although not a material consideration when determining whether to recommend that a client utilize the services of a particular independent broker-dealer/custodian, Stavis Wealth from time to time receives from such broker-dealer/custodians without cost (and/or at a discount) support services and/or products, certain of which assist Stavis Wealth to better monitor and service client accounts maintained at such institutions. Included within the support services that may be obtained by Stavis Wealth may be investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by the Firm in furtherance of its investment advisory business operations. As indicated above, certain of the support services and/or products that may be received will assist Stavis Wealth in managing and administering client accounts. Others do not directly provide such assistance but rather assist Stavis Wealth in managing and further developing its business enterprise and operations. However, there is no corresponding commitment made by the Firm to such broker-dealer/custodians or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of the above broker-dealer/custodians arrangements. ~ 28 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Directed Brokerage Stavis Wealth may accept directed brokerage arrangements where a client requires that account transactions be effected through a specific broker-dealer. In such client directed arrangements, the client will typically negotiate terms and arrangements for their account with that broker-dealer separate from Stavis Wealth, and Stavis Wealth will not seek better execution services or prices from other broker-dealers or be able to aggregate or batch the client's transactions for execution through other broker-dealers with orders for other accounts managed by Stavis Wealth. As a result, in cases of a directed brokerage arrangement the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would Please Note otherwise be the case. to effect account transactions through alternative : In the event that the client directs Stavis Wealth to effect securities transactions for the client's accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined trade execution arrangements that may be available through Stavis Wealth. Batched-Bunched-Blocked/Aggregated Trading To the extent that Stavis Wealth provides investment management services to its clients, the transactions for each client account generally will be effected independently, unless Stavis Wealth decides to purchase or sell the same securities for several clients at approximately the same time. Stavis Wealth may (but is not obligated to) aggregate or “bunch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among Stavis Wealth’s clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account in any given trade. Stavis Wealth does not receive any additional compensation or remuneration as a result of such aggregation. Also, client commission arrangements and related “soft-dollar” benefits used or received by the Firm are being used within the parameters of Section 28(e) and its related safe harbor. Please also note that such “soft-dollar” benefits are not limited to those clients who may have generated a particular benefit although certain soft dollar allocations may be connected to particular clients or groups of clients. Sharing of Financial and Estate Planning Fees In certain cases as described above, Stavis Wealth may share and pay certain advisory fees to private wealth managers that obtain financial data and client objectives in coordination with the governing estate/financial plan. Such fees will be disclosed to the client in a separate form, and the amount will vary based upon the time and effort expended by the private wealth manager. ~ 29 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Sharing of Insurance Broker-Commission Fees In certain cases as described above, Stavis Wealth’s Firm Principal may share in as noted above, variable life insurance business that is conducted through BFS, whereby insurance commissions are received by the Firm’s Principal in such principal’s capacity as a Item 13 – Review of Accounts registered insurance broker-agent. Review of subaccounts within insurance policies, are reviewed quarterly. Such reviews entail a written report regarding overall asset allocation and the individual holdings within each policy subaccount, on an annual basis, in accordance with each client’s investment objectives, risk tolerance. Additional reviews are triggered by events, such as a client meeting; a request for withdrawal from a loan, or deposit into an account; a change in a client's risk tolerance, financial position or investment/estate planning objectives; a change in a company or fund's management; unusual market or economic circumstances; or other unforeseen event(s). The Firm encourages clients to meet with estate planning advisors of the Firm at least annually. Item 14 – Client Referrals and Other Compensation Where a client is introduced to Stavis Wealth by a third-party solicitor, Stavis Wealth can pay such solicitor a referral fee in accordance with the regulatory requirements. The Firm will only compensate such persons or entities for referrals of financial and estate planning clients, and all such referral or solicitor arrangements will be in accordance with applicable regulatory rules, which generally require a written agreement and certain related written documentation. The Firm may act as a third-party solicitor for compensation where and when it refers investment business to another advisor. In certain cases, and fully disclosed to the client, the Firm may serve as a third-party solicitor and accept a solicitor’s fee for referring a client to an investment manager. Third-Party Vendor Relationships Stavis Wealth maintains relationships with certain third-party vendors, including GLASfunds, a private equity investment platform. The Firm or its Staff may receive non- cash compensation from its vendors, which includes reimbursement or payment for travel, lodging, meals, entertainment, or participation in conferences and other events. To the extent this situation occurs, it creates a conflict of interest, as these benefits create an incentive for Stavis Wealth or its personnel to promote the vendor providing the incentive or recommend investments on the GLASfunds platform over other platform options in order to continue receiving such non-cash compensation benefits. To mitigate this conflict, we focus on providing investment recommendations that are based on independent analysis consistent with our fiduciary duty obligations and each client’s best interests. Additionally, we monitor and oversee vendor relationships through our advisory services team. ~ 30 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Item 15 – Custody Stavis Wealth does not accept, take or hold actual or physical custody of any clients’ assets rd Item 16 – Investment Discretion or investments. All custody is held by or with 3 party independent qualified custodians. Stavis Wealth may receive discretionary authority from the client at the outset of an advisory relationship to identify the appropriate allocation of subaccounts/IDFs within the policy. However, such discretion is to be exercised in a manner consistent with the stated insurance company policies and client investment objectives. When selecting securities and determining amounts, Stavis Wealth observes the investment policies, limitations and restrictions of the client for which it advises. Related investment guidelines and restrictions should be provided in writing to Stavis Wealth by the client. The Firm has the authority to determine, without obtaining consent of the client before transactions are effected, both the subaccounts/IDFs, which are to be reallocated within the account. Stavis Wealth may also generally receive discretionary authority from the client as part of an advisory relationship under a governing written advisory agreement to provide wealth advisory services, including selecting the identity and amount of securities to be bought or sold in client accounts. Generally, however, such discretion is to be exercised in a manner consistent with the written investment objectives or plan for that particular client account. When selecting securities and determining amounts in exercising such discretion, Stavis Wealth observes the investment policies, limitations and restrictions of the client for which it advises, as provided in writing to the Firm by the client from time to time inclusive of any In this scenario, the Firm has the authority to determine, without periodic updates. obtaining consent of the client before transactions are effected, both the securities which are to be bought or sold and the amount of such securities. Limitations or restrictions on this authority would result if the client specified that certain investments were to be precluded or prohibited such as "no tobacco stocks” or “no sin stocks" or the like. Item 17 – Voting Client Securities As a matter of firm policy, Stavis Wealth generally does not accept the authority to and Class Actions/Legal Proceedings does not generally vote proxies. Clients should note that Stavis Wealth will neither advise nor act on behalf of the investment advisor clients in legal proceedings involving companies whose securities are held or previously were held in the investment advisor’s clients’ account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. Unless directed otherwise in writing, Stavis Wealth will transmit, or forward copies of class action notices received to the client and/or a third-party advisor or representative as designated by the client. Stavis Wealth will also make commercially reasonable efforts to forward such notices in a timely manner. ~ 31 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about such advisory firm’s financial condition where such financial condition would likely impair the advisory firm’s ability to meet contractual and fiduciary commitments to its clients. Stavis Wealth has no such financial commitment or condition that impairs its ability to meet contractual and fiduciary commitments to its clients, and it has not been the subject of a bankruptcy proceeding. Also, the Firm does not require prepayment of more than $1200 in fees per client for six months or more in advance. ~ 32 ~  STAVIS WEALTH TRANSFER SOLUTIONS, LLC ADV-PART 2 BROCHURE DATE: 11/30/2025 ADV-PART 2B BROCHURE SUPPLEMENT (PART 2B) STAVIS WEALTH TRANSFER SOLUTIONS, LLC 1330 Post Oak Blvd, Suite 2050 Houston, TX 77056 This Brochure Supplement provides information about advisors at Stavis Wealth Transfer Solutions (Stavis Wealth) and is a supplement to the Stavis Wealth ADV-Part 2 Disclosure Brochure (Part 2A above). Additional information about our advisors is available on the SEC’s website at www.adviserinfo.sec.gov. LISTING OF ADVISORS COVERED IN THIS BROCHURE SUPPLEMENT DEBORAH M. STAVIS SAMIR SINHA ~ 33 ~  PART 2B – BROCHURE SUPPLEMENT DEBORAH M. STAVIS, CFP® - MANAGING PRINCIPAL/CHIEF EXECUTIVE OFFICER EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Year of Birth: 1955 Post-Secondary Education: Attended Wayne State University, 1974 – 1978, Communications  Business Background:  -History Back to 1980 is available upon request 2009-2023: Chief Executive Officer, Stavis & Cohen Private Wealth/CI Private Wealth 1996-2007: Chief Executive Officer, Stavis, Margolis Advisory Services, Inc. Professional Designations Held: Certified Financial Planner ™, CFP® - Since 1987  Licenses Held:     Series 7 General Securities Representative Series 24 General Securities Principal Series 63 Uniform Securities Agent State Law Series 65 Uniform Registered Investment Adviser Law Group 1 Life and Health Insurance -For an explanation of qualifications required for any designations, please see Appendix A. DISCIPLINARY INFORMATION Deborah M. Stavis has no legal or disciplinary events to report. OTHER BUSINESS ACTIVITIES Deborah M. Stavis is Managing Principal/CEO at Stavis Wealth but is also separately licensed as a Registered Representative with Benefit Funding Services (BFS), a registered securities broker/dealer, member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investors Protection Corporation (SIPC). Deborah Stavis is also a licensed insurance agent. Please refer to the Other Business Activities section of the Stavis Wealth ADV-Part 2 Brochure for more information on this topic. ADDITIONAL COMPENSATION Deborah M. Stavis’ primary source of income is derived from her activities conducted on behalf of the firm. Incidental sources derived from affiliates are minimal and disclosed on her Outside Business Activities form. SUPERVISION The Firm’s Managing Principal is also the Firm’s Chief Compliance Officer and is responsible for overseeing and enforcing the firm’s compliance program that monitors and supervises the activities and services provided by the firm and its advisory representatives. Deborah Stavis can be contacted by email as listed above or at 713-391-8200.  PART 2B – BROCHURE SUPPLEMENT SAMIR SINHA, CFA® - MANAGING DIRECTOR/CHIEF INVESTMENT OFFICER Year of Birth: 1965 EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE  Post-Secondary Education: Columbia University – B.S. Chemical Engineering  Business Background:    2018-2025: Sr. Investment Analyst, Franklin Templeton/Franklin Templeton Institute 2017-2018: Director of Research, Post Oak Private Wealth Advisors 2015-2017: Managing Director, Sinsonte Capital Management 2013-2015: Sr. Portfolio Manager, MBM Financial Advisors Professional Designations Held: Chartered Financial Analyst, CFA® - Since 2004 Licenses Held: Not Applicable -For an explanation of qualifications required for any designations, please see Appendix A. DISCIPLINARY INFORMATION Samir Sinha has no legal or disciplinary events to report. OTHER BUSINESS ACTIVITIES None currently. ADDITIONAL COMPENSATION None currently. SUPERVISION The Firm’s Managing Principal is also the Firm’s Chief Compliance Officer and is responsible for overseeing and enforcing the firm’s compliance program that monitors and supervises the activities and services provided by the firm and its advisory representatives. Deborah Stavis can be contacted by email as listed above or at 713-391-8200.  (Appendix A – Professional Designations/Certifications Summary) CHARTERED FINANCIAL ANALYST (CFA®) The Chartered Financial Analyst (CFA®) and Certification Mark (collectively, the "CFA marks") are professional certification marks granted in the United States and internationally by the CFA Institute. The Chartered Financial Analyst® (CFA®) charter is a globally respected, graduate-level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 150,000 CFA charterholders working in more than 140 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least four years of qualified professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffirm, their adherence to CERTIFIED FINANCIAL PLANNER (CFP®) the CFA Institute Code of Ethics and Standards of Professional Conduct. The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following Education requirements: – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and (since 2007) attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement Examination planning, and estate planning; – Complete at least three years of full-time financial planning-related experience (or Standards of Professional Conduct – Pass the comprehensive CFP® Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s Experience knowledge of financial planning to real world circumstances; Ethics the equivalent, measured as 2,000 hours per year); and – Agree to be bound by CFP Board’s , a set of documents Continuing outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics Education requirements in order to maintain the right to continue to use the CFP® marks: Code of Ethics Standards of Professional Conduct , – Complete 30 hours of continuing education hours every two years, including two hours on the and other parts of the Ethics Standards of Professional Conduct to maintain competence and keep up with developments in the financial planning field; and – Renew an agreement to be bound by the . The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients.