STILLWATER WEALTH MANAGEMENT GROUP LLC

Stillwater Wealth Management Group LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Stillwater Wealth Management Group LLC. If you have any questions about the contents of this brochure, please contact us at (561) 214-4125 or by email at: tyler.wright@stillwaterwealthmgt.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Stillwater Wealth Management Group LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Stillwater Wealth Management Group LLC’s CRD number is: 309796. 790 Juno Ocean Walk, Suite 202C Juno Beach, FL 33408 (561) 214-4125 tyler.wright@stillwaterwealthmgt.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 02/11/2026 I  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Stillwater Wealth Management Group LLC on 02/10/2025 are described below. Material changes relate to Stillwater Wealth Management Group LLC’s policies, practices or conflicts of interests. Ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ........................................................................................................................................................ ii Item 3: Table of Contents ....................................................................................................................................................... iii Item 4: Advisory Business .......................................................................................................................................................2 Item 5: Fees and Compensation ..............................................................................................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management......................................................................................6 Item 7: Types of Clients...............................................................................................................................................................7 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .................................................................................7 Item 9: Disciplinary Information ..........................................................................................................................................12 Item 10: Other Financial Industry Activities and Affiliations...........................................................................................12 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.................................13 Item 12: Brokerage Practices..................................................................................................................................................14 Item 13: Review of Accounts .................................................................................................................................................16 Item 14: Client Referrals and Other Compensation ...........................................................................................................16 Item 15: Custody .....................................................................................................................................................................17 Item 16: Investment Discretion .............................................................................................................................................18 Item 17: Voting Client Securities (Proxy Voting)................................................................................................................18 Item 18: Financial Information................................................................................................................................................19 Iii  Item 4: Advisory Business A. Description of the Advisory Firm Stillwater Wealth Management Group LLC (hereinafter “SWMG LLC”) is a Limited Liability Company organized in the State of Florida. The firm was formed in June 2020, and the principal owners are Tyler Steven Wright and Richard Robert Blumenfeld. B. Types of Advisory Services Portfolio Management Services SWMG LLC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SWMG LLC creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring SWMG LLC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SWMG LLC will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. is to seek fair and equitable allocation of SWMG LLC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SWMG LLC’s economic, investment or other financial interests. To meet its fiduciary obligations, SWMG LLC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SWMG LLC’s policy investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is SWMG LLC’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. 2  Pension Consulting Services SWMG LLC offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • identifying investment objectives and restrictions • providing guidance on various assets classes and investment options • recommending money managers to manage plan assets in ways designed to achieve objectives • monitoring performance of money managers and investment options and making recommendations for changes • recommending other service providers, such as custodians, administrators and broker-dealers • creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Services Limited to Specific Types of Investments SWMG LLC generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements, although SWMG LLC primarily recommends total return/ investment objective in quality dividend-paying large cap equities and growth investment grade fixed income. SWMG LLC may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions SWMG LLC will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by SWMG LLC on behalf of the client. SWMG LLC may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SWMG LLC from properly servicing the client account, or if the restrictions would require SWMG LLC to deviate from its standard suite of services, SWMG LLC reserves the right to end the relationship. 3  D. Wrap Fee Programs includes management A wrap fee program is an investment program where the investor pays one stated fee that fees, transaction costs, fund expenses, and other administrative fees. SWMG LLC does not participate in any wrap fee programs. E. Assets Under Management SWMG LLC has the following assets under management: Total: As of: Non-discretionary Amounts: Discretionary Amounts: $204,919,516 $ 1,663,319 $206,582,835 Feb 09, 2026 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $999,999 1.10% $1,000,000 - $2,499,999 1.00% $2,500,000 - $4,999,999 0.90% $5,000,000 - $10,000,000 0.80% $10,000,000 - $15,000,000 0.70% $15,000,000 - $20,000,000 0.60% $20,000,000 + 0.50% 4 The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of SWMG LLC's fees within  five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 3 days' written notice. Pension Consulting Services Fees Asset-Based Fees for Pension Consulting Total Assets Under Management Annual Fee All Assets 0.75% The advisory fee is calculated using the value of the assets on the last business day of the prior billing period. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of SWMG LLC's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the pension consulting agreement generally with 30 days' written notice. SWMG LLC bills based on the balance on the first day of the billing period. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization or may be invoiced and billed directly to the client on a monthly basis. Fees are paid in advance and may be paid by check. Payment of Pension Consulting Fees Asset-based pension consulting fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis. Fees are paid in advance. 5 C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by SWMG LLC. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees SWMG LLC collects fees in advance. Refunds for fees paid in advance but not yet earned  will be refunded on a prorated basis and returned within fourteen days to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) E. Outside Compensation For the Sale of Securities to Clients Neither SWMG LLC nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management SWMG LLC does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 6  Item 7: Types of Clients SWMG LLC generally provides advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Pension and Profit Sharing Plans ❖ Corporations or Business Entities There is an account minimum of $1,000,000, which may be waived by SWMG LLC in its discretion. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis SWMG LLC’s methods of analysis include Charting analysis, Fundamental analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. SWMG LLC uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. SWMG LLC uses long term trading and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 7 B. Material Risks Involved Methods of Analysis  Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Investment Strategies SWMG LLC's use of options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 8 C. Risks of Specific Securities Utilized SWMG LLC's use of options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency.  Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. 9  ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. 10  Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 11  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither SWMG LLC nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither SWMG LLC nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. 12  C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Mr. Joseph Runnels, Investment Adviser Representative, is a 0.20% owner in Enhanced Investment Technologies, LLC, a West Palm Beach advisory firm. Mr. Runnels holds no title or responsibilities with Enhanced Investment Technologies but it is possible that Mr. Runnels would receive profit-sharing compensation from Enhanced Investment Technologies at the discretion of the management of Enhanced Investment Technologies. Mr. Runnels and Stillwater Wealth Management do not have any kind of professional affiliation or referral arrangements. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections SWMG LLC does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics SWMG LLC has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. SWMG LLC's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests SWMG LLC does not recommend that clients buy or sell any security in which SWMG LLC or a related person has a material financial interest. 13  C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of SWMG LLC may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of SWMG LLC to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. SWMG LLC will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of SWMG LLC may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of SWMG LLC to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, SWMG LLC will never engage in trading that operates to the client’s disadvantage if representatives of SWMG LLC buy or sell securities at or around the same time as clients. Oftentimes, block trading is used to mitigate conflicts of interest. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on SWMG LLC’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and SWMG LLC may also consider the market expertise and research access provided by the broker dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in SWMG LLC's research efforts. SWMG LLC will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. SWMG LLC will require clients to use Schwab Institutional, a division of Charles Schwab & Co., Inc. 14  1. Research and Other Soft-Dollar Benefits While SWMG LLC has no formal soft dollars program in which soft dollars are used to pay for third party services, SWMG LLC may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). SWMG LLC may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and SWMG LLC does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. SWMG LLC benefits by not having to produce or pay for the research, products or services, and SWMG LLC will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that SWMG LLC’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals SWMG LLC receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use SWMG LLC will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If SWMG LLC buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, SWMG LLC would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. SWMG LLC would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). 15  Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for SWMG LLC's advisory services provided on an ongoing basis are reviewed at least Quarterly by Richard Blumenfeld, Principal, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at SWMG LLC are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of SWMG LLC's advisory services provided on an ongoing basis will receive a report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian quarterly at minimum. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) SWMG LLC does not receive any economic benefit, directly or indirectly from any third party for advice rendered to SWMG LLC's clients. With respect to Schwab, SWMG LLC receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ 16  assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For SWMG LLC client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to SWMG LLC other products and services that benefit SWMG LLC but may not benefit its clients’ accounts. These benefits may include national, regional or SWMG LLC specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of SWMG LLC by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist SWMG LLC in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of SWMG LLC’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of SWMG LLC’s accounts. Schwab Advisor Services also makes available to SWMG LLC other services intended to help SWMG LLC manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to SWMG LLC by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to SWMG LLC. SWMG LLC is independently owned and operated and not affiliated with Schwab. Depending on the value of assets held at Schwab Advisor Services, Schwab will offer payment to third parties for services in the following categories on behalf of SWMG LLC: Legal, Compliance, Technology, and Marketing. B. Compensation to Non – Advisory Personnel for Client Referrals SWMG LLC does not directly or indirectly compensate any person who is not advisory personnel for client referrals. 17  Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, SWMG LLC will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion SWMG LLC provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, SWMG LLC generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, SWMG LLC’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to SWMG LLC. SWMG LLC will also have discretionary authority to determine the broker or dealer to be used for a purchase or sale of securities for a client's account.) Item 17: Voting Client Securities (Proxy Voting) SWMG LLC acknowledges its fiduciary obligation to vote proxies on behalf of those clients that have delegated to it, or for which it is deemed to have, proxy voting authority. SWMG LLC will vote proxies on behalf of a client solely in the best interest of the relevant client. SWMG LLC has established general guidelines for voting proxies. SWMG LLC may also abstain from voting if, based on factors such as expense or difficulty of exercise, it determines that a client’s interests are better served by abstaining. Further, because proxy proposals and individual company facts and circumstances may vary, SWMG LLC may vote in a manner that is contrary to the general guidelines if it believes that it would be in a client’s best interest to do so. If a proxy proposal presents a conflict of interest between SWMG LLC and a client, then SWMG LLC will disclose the conflict of interest to the client prior to the proxy vote and, if participating in the vote, will vote in accordance with the client’s wishes. Clients may obtain a complete copy of the proxy voting policies and procedures by contacting SWMG LLC in writing and requesting such information. Each client may also request, by contacting SWMG LLC in writing, information concerning the manner in which proxy votes have been cast with respect to portfolio securities held by the relevant client during the prior annual period. Clients can send written requests to the Chief Compliance Officer at Tyler.wright@stillwaterwealthmgt.com. 18  Item 18: Financial Information A. Balance Sheet SWMG LLC neither requires nor solicits prepayment of more than $1200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither SWMG LLC nor its management has any financial condition that is likely to reasonably impair SWMG LLC’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years SWMG LLC has not been the subject of a bankruptcy petition in the last ten years. 19