Overview

Headquarters
Louisville, KY
Average Client Assets
$1.6 million
Minimum Account Size
$25,000
SEC CRD Number
165474

Fee Structure

Primary Fee Schedule (FORM ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.50%
$1,000,001 $2,500,000 1.00%
$2,500,001 $5,000,000 0.75%
$5,000,001 and above 0.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $15,000 1.50%
$5 million $48,750 0.98%
$10 million $73,750 0.74%
$50 million $273,750 0.55%
$100 million $523,750 0.52%

Clients

HNW Share of Firm Assets
34.07%
Total Client Accounts
8,606
Discretionary Accounts
8,606

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Educational Seminars

Regulatory Filings

Additional Brochure: FORM ADV PART 2A (2026-03-23)

View Document Text
Form ADV Part 2A Strategic Wealth Investment Group, LLC Firm Brochure Effective: March 17, 2026 This brochure provides information about the qualifications and business practices of Strategic Wealth Investment Group, LLC. If you have any questions about the contents of this brochure, please contact us at (502) 412-3354 or by email at: compliance@swdgroup.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. Registration does not imply a certain level of skill or training. This brochure provides information about Strategic Wealth Investment Group to assist you in determining whether to retain the Advisor. Additional information about Strategic Wealth Investment Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Strategic Wealth Investment Group, LLC’s CRD number is: 165474 111 North Orange Avenue Suite 800, Office #853 Orlando, FL 32801 (877) 934-7687 Branch Office Locations: 500 North Hurstbourne Parkway Suite 120 Louisville, KY, 40222 (502) 412-3354 Website: www.swdgroup.com 3030 North Rocky Point Drive Suite 100 Tampa, FL 33607 (813) 999-2486 9220 West Union Hills Drive Suite 101 Peoria, AZ 85382 (623) 544-3424 1100 Abernathy Road N.E. Suite L-20 Atlanta, GA 30328 (678) 638-6363 4600 South Syracuse Street Suite 100 Denver, CO 80237 (303) 952-4044 2680 East Main Street Plainfield, IN 46168 (317) 644-0876 11030 Circle Point Road Suite 140 Westminster, CO 80020 (303) 952-4044 9025 River Road Suite 120 Indianapolis, IN 46240 (317) 644-0876 1 Alhambra Plaza PH 15 Coral Gables, FL 33134 (877) 934-7687 13146 Ballantyne Corp Place Suite 100 Charlotte, NC 28277 (704) 817-4233 1 Form ADV 2A Version: 3.17.2026 8041 Arco Corporate Drive Suite 130 Raleigh, NC 27617 (919) 426-2052 101 Summit Avenue Suite 100 Fort Worth, TX 76102 (817) 539-8702 5181 Natorp Boulevard Suite 100 Mason, OH 45040 (513) 492-2198 2000 West Sam Houston Parkway South Suite 150 Houston, TX 77042 (346) 385-0948 123 S Broad Street 15th Floor #1555 Philadelphia, PA 19109 (877) 934-7687 8000 IH-10 West Suite 970 San Antonio, TX 78230 (210) 764-4461 3711 South Mopac Expressway Bldg. 2, Suite 175 Austin, TX 78746 (737) 247-7683 1921 Gallows Road Suite 110 Vienna, VA 22182 (703) 718-6973 12377 Merit Drive Suite 120 Dallas, TX 75251 (972) 327-6511 3535 Factoria Blvd SE Suite 425 Bellevue, WA 98006 (425) 658-2197 Item 2: Material Changes The following changes have occurred since our last filing dated September 30, 2025: ƒ Signed an agreement to engage with wealth/tech firm Envestnet. 2 Form ADV 2A Version: 3.17.2026 Item 3: Table of Contents Item 2: Material Changes � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 2 Item 3: Table of Contents� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 3 Item 4: Advisory Business� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 4 Item 5: Fees and Compensation � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 6 Item 6: Performance-Based Fees and Side-By-Side Management � � � � � � � � � � � � � � � � � � � � � � � � � � � 8 Item 7: Types of Clients � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 8 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss � � � � � � � � � � � � 8 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 �15 Item 12: Brokerage Practices � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 16 Item 13: Reviews of Accounts � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 17 Item 14: Client Referrals and Other Compensation � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 17 Item 15: Custody � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 17 Item 16: Investment Discretion � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �18 Item 17: Voting Client Securities (Proxy Voting) � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �18 Item 18: Financial Information � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 19 3 Form ADV 2A Version: 3.17.2026 Item 4: Advisory Business A� DESCRIPTION OF THE ADVISORY FIRM Strategic Wealth Investment Group, LLC (“SWIG”) is a Delaware limited liability company. The firm was formed in July of 2002 and began conducting investment advisory business in 2012. The principal owners are Matthew J. Dicken and Jordan Schwartz. SWIG may conduct business under the trade name Strategic Wealth Designers. B� TYPES OF ADVISORY SERVICES Strategic Wealth Investment Group, LLC (hereinafter “SWIG”) offers the following services to advisory clients: Investment Supervisory Services SWIG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SWIG creates an Investment Advisory Contract 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. Investment Supervisory Services include, but are not limited to, the following: ƒ Investment strategy ƒ Personal investment policy ƒ Asset allocation ƒ Asset selection ƒ Risk tolerance ƒ Regular portfolio monitoring SWIG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SWIG requires 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 Advisory Contract, which is given to each client. In performing its asset management services for each client, SWIG may utilize a third-party platform operated by an unaffiliated investment advisor, Envestnet Asset Management (“Sub-Adviser”). The Sub- Adviser provides SWIG with certain sub-advisory asset management, administrative, technical and support services. When utilizing the asset management services of the Sub-Adviser, SWIG delegates discretionary authority to Sub-adviser which authorizes the Sub-Adviser to buy and sell investments in the account without asking you in advance. SWIG will provide you with the Sub-Adviser’s disclosure documents, including Form ADV 2A. Please refer to these disclosure documents for additional details regarding the Sub-Advisor. SWIG engages a third-party investment advisor (the “Advisor”) to provide SWIG with certain investment advisory consulting services. These services are provided to SWIG and not directly to SWIG’s advisory clients. The Advisor’s services may include, as requested by SWIG, consultation regarding investment strategies, asset allocation, and portfolio construction, and participation in periodic meetings with SWIG to discuss these and other advisory matters. SWIG may also request that the Advisor provide model portfolios based on parameters established by SWIG. In developing such model portfolios, the Advisor uses proprietary, internally developed analytical and screening tools. SWIG does not receive direct access to the Advisor’s proprietary tools. 4 Form ADV 2A Version: 3.17.2026 The Advisor does not provide investment advice to SWIG’s underlying clients, does not communicate directly with SWIG’s clients as part of this arrangement, and does not have discretionary authority or trading authority over any client account. SWIG retains full responsibility for determining whether any strategy, model portfolio, security, or investment approach is appropriate for any particular client, and for implementing any investment recommendation in client accounts. Any model portfolios, strategy input, or other consulting recommendations provided by the Advisor are general in nature and are considered by SWIG together with SWIG’s own analysis, the client’s investment objectives, risk tolerance, financial circumstances, and other relevant considerations. SWIG is not obligated to implement any recommendation or model provided by the Advisor. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning, life insurance; tax planning; retirement planning; college planning; and debt/credit planning. These services are based on hourly fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement. Services Limited to Specific Types of Investments SWIG generally limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, structured notes, ETFs, REITs, insurance products including annuities, government securities, and private equity (only available to accredited investors and qualified persons). SWIG may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money may create some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: ƒ Meet a professional standard of care when making investment recommendations (give prudent advice); ƒ Never put our financial interests ahead of yours when making recommendations (give loyal advice); ƒ Avoid misleading statements about conflicts of interest, fees, and investments; ƒ Follow policies and procedures designed to ensure that we give advice that is in your best interest; ƒ Charge no more than is reasonable for our services; and ƒ Give you basic information about potential conflicts of interest. C� CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS SWIG offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Advisory Contract which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that considers restrictions, and the client risk profile. Clients may request restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SWIG from properly servicing the client account, or if the restrictions would require SWIG to deviate from its standard suite of services, SWIG reserves the right to suggest alternatives. 5 Form ADV 2A Version: 3.17.2026 D� PRIVATE PLACEMENTS As part of our investment advisory services, we may recommend or assist clients in evaluating and investing in private placements and other alternative investments. Private placements generally include investments offered outside of a public exchange, such as interests in private investment funds (e.g., private equity, venture capital, hedge funds, private credit), private real estate funds, limited partnerships, private notes, and other offerings made in reliance on exemptions from registration under federal and state securities laws (commonly Regulation D). Private placements are typically available only to investors who meet certain eligibility standards (such as “accredited investor,” “qualified client,” or “qualified persons” status, as applicable). We will generally rely on the issuer, placement agent, sponsor, and/or the client’s representations regarding eligibility unless we separately agree otherwise in writing. SWIG’s principals are minority owners of TRCM, an affiliated private fund sponsor which SWD may recommend to clients. While clients are not charged a second layer of advisory fees by SWIG, the affiliated fund may pay management or performance-based compensation to its owners, including SWIG principals. This creates a conflict of interest because SWIG and its principals may benefit financially when clients invest in the TRCM fund, potentially influencing our recommendations. E� WRAP FEE PROGRAMS A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and any other administrative fees. SWIG does not participate in any wrap fee programs. F� ASSETS UNDER MANAGEMENT SWIG has the following assets under management: Discretionary Amounts: $1,384,291,490 Non-discretionary Amounts: $0.00 Date Calculated: December 31, 2025 Item 5: Fees and Compensation A� FEE SCHEDULE Investment Advisory Fees The following table represents the base schedule of fees charged by Strategic Wealth Investment Group LLC for services provided fees are based on assets under management and you will not pay separate commission ticket charge or custodial fee for the execution of transactions in your account this does not exclude the potential of additional fees being charged by our custodian for certain kinds of products as dictated by their client account agreement terms Total Assets Under Management Annual Fee First $1,000,000 1,000,001- $2,499,999 $2,500,000 - $4,999,999 Above $5,000,000 1.50% 1.00% 0.75% 0.50% 6 Form ADV 2A Version: 3.17.2026 Fees are negotiable based on the services requested and the complexity of the engagement. Your specific fee schedule is set forth in the Investment Advisory Contract (and any exhibits). Unless otherwise agreed in writing, portfolio management fees are calculated monthly and billed in arrears, and are typically deducted from your custodial account with your written authorization. You may terminate the Investment Advisory Contract upon fifteen (15) days written notice. Upon termination, we will calculate any advisory fee due through the effective termination date; because fees are generally billed in arrears, there is typically no unearned fee to refund. If any advisory fee is collected in advance for any reason, any unearned portion will be refunded on a prorated basis. You may terminate without penalty within five (5) business days of signing the contract, and any fees paid in advance (if any) will be refunded in full. SWIG pays the Advisor an annual consulting fee, billed quarterly in advance, for the services described above in Item 4. This fee is paid by SWIG from its own revenues and is not charged separately to clients as a distinct fee. To the extent this expense is a cost of operating SWIG’s advisory business, clients should understand that SWIG’s advisory fee is intended to cover, among other things, SWIG’s general business expenses, including amounts paid to third-party service providers such as the Advisor. Financial Planning Fees Financial planning fees are negotiable based on the scope and complexity of the planning engagement and are set forth in the Financial Planning Agreement (and any exhibits). Planning fees are generally due in advance; however, we do not require payment more than six (6) months in advance. You may terminate the Financial Planning Agreement within five (5) business days of signing without penalty. If you terminate after that period, any unearned portion of fees paid in advance will be refunded on a prorated basis based on the work completed as of the termination date. B� PAYMENT OF FEES Payment of Investment Advisory Fees Advisory fees are paid monthly in arrears to SWIG and are typically withdrawn from the client’s account with one-time up-front written authorization. Payment of Financial Planning Fees Financial planning fees may be paid by check or credit card. To the extent fees are paid in advance, we will not require payment more than six (6) months in advance, and any unearned portion will be refunded on a prorated basis upon termination. C� CLIENTS ARE RESPONSIBLE FOR THIRD PARTY FEES We want clients to understand that, in addition to SWIG’s advisory fee, their account may include certain routine third-party costs related to custody, brokerage, and investments. These charges are separate from SWIG’s fee, are paid to the applicable third-party provider, and may include custodian fees, brokerage commissions, transaction fees, and mutual fund or ETF expenses. These types of costs are common for investment accounts and will vary based on the services used, the investments selected, and account activity. Not all clients will incur all such charges. Please see Item 12 of this brochure for additional information regarding brokerage and custodian arrangements. D� PREPAYMENT OF FEES Advisory fees are quoted on an annualized basis, and, unless agreed to otherwise in writing, will be calculated and payable monthly in arrears, based on the market value of the client’s account (as determined by the Custodian) as of the last business day of the billing period. Multiple related accounts within a household shall be aggregated for purposes of determining the applicable annual fee rate to be charged. 7 Form ADV 2A Version: 3.17.2026 E� OUTSIDE COMPENSATION FOR THE SALE OF SECURITIES TO CLIENTS Neither SWIG nor its supervised persons accept any compensation from outside sources for the sale of securities or other investment products, including asset-based sales charges or services fees from the sale of mutual funds. F� ADDITIONAL COST OF STRUCTURED NOTES In addition to our advisory fee, clients may incur product-level and transactional costs when purchasing structured notes. These may include (depending on the offering) commissions or selling concessions, structuring fees, and hedging costs that can be embedded in the note’s price and may cause the issue price to be higher than the issuer’s estimated value at issuance. Clients may also experience bid/ask spreads and price concessions on early sale or secondary-market transactions. G� ADDITIONAL COMPENSATION Our representatives may also be licensed insurance agents and recommend insurance products to any client. They can earn commissions when selling these products. This is a potential conflict because they may recommend the purchase of an insurance product resulting in a commission being paid. In addition, our firm receives non-cash incentives and potential bonus compensation from Advisors Excel, a third-party insurance marketing organization, if aggregate insurance sales by SWIG representatives exceed certain thresholds. These incentives may include marketing support, reimbursement for conferences, or other firm benefits. This creates a conflict of interest because SWIG may have an incentive to promote insurance products in order to qualify for additional firm-level compensation. Item 6: Performance-Based Fees and Side-By-Side Management SWIG 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. Item 7: Types of Clients SWIG generally provides investment advice and/or management supervisory services to the following types of clients: ƒ Individuals ƒ High Net Worth Individuals ƒ Corporations or Business Entities Minimum Account Size There is an account minimum, $7,500, which may be waived by the investment advisor, based on the needs of the client and the complexity of the situation. Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A� METHODS OF ANALYSIS AND INVESTMENT STRATEGIES Methods of Analysis SWIG may employ fundamental, charting, cyclical and technical analysis methods in developing investment strategies for its clients. Research and analysis from SWIG are derived from numerous sources, including financial media companies, third-party research materials, professional data subscriptions, 8 Form ADV 2A Version: 3.17.2026 Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. The definitions of the different types of analysis are as follows: Charting analysis involves the use of patterns in performance charts. SWIG 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. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Investment Strategies Advisors generally use one or more of the following investment strategies when implementing investment advice to clients: ƒ Long-term investments (investments held at least one year) ƒ Short-term investments (investments sold within one year) Model Portfolios SWIG use internally developed model portfolios as a starting point (i.e., a baseline framework) for managing client accounts. These model portfolios are designed to promote consistent and disciplined investment practices; however, they may not be applied on a “one-size-fits-all” basis. Prior to implementation and on an ongoing basis, we review each client’s investment objectives, risk tolerance, time horizon, liquidity needs, tax considerations (as applicable), and any client-imposed restrictions. We periodically reassess both the underlying model portfolio and each client’s tailored implementation for continued appropriateness, and we make adjustments when a client’s circumstances or market conditions warrant. Clients may request additional customization at any time, and we will determine whether such customization is feasible and consistent with the client’s stated objectives and applicable guidelines. SWIG may offer both internally managed model portfolios and third-party strategies provided through Envestnet. In some cases, we may receive financial or operational benefits tied to client use of Envestnet. Although we strive to recommend the most suitable model based on your risk profile and investment goals, these affiliations create a potential conflict of interest when deciding which model to assign to a client. Selection of Third-Party Managers In addition to utilizing our firm’s own model portfolios, SWIG has contracted with a Sub-Advisor Envestnet, registered with the United States Securities and Exchange Commission. This contract provides SWIG clients with access to model portfolios, and third- party money managers. Our selection process cannot ensure that third-party money managers will perform as desired and SWIG has no control over the day-to- day operations of any of its selected third-party money managers. SWIG conducts initial and ongoing due diligence of third- party money manager and sub-advisors as part of its fiduciary duty to its clients. Non-Traded Securities/Private Placements Under certain circumstances, SWIG may recommend to accredited investors or qualified persons an allocation to select private placements or other non-traded investment vehicles (vehicles), where the investments inside the vehicle are managed by a third-party. Furthermore, the private placement or non- traded investment vehicle may have little to no liquidity such that an investor may be required to maintain their investment until such time that the manager of the investment liquidates the fund/vehicle and returns capital to investors. These types of investments may not be suitable for all clients. 9 Form ADV 2A Version: 3.17.2026 Structured Notes From time to time, our models and portfolios may include structured notes. Structured notes are securities issued by financial institutions with returns that are linked to a reference asset or index (e.g., an equity index, a basket of securities, interest rates, commodities, or currencies), typically with a fixed maturity and an embedded derivative component. B� RISK OF LOSS Investing in securities involves a risk of loss that you should be prepared to bear, including the loss of your original principal. You should also be aware that past performance of any security is not necessarily indicative of future results. Therefore, do not assume that future performance of any specific investment or investment strategy will be profitable. We do not provide any representation or guarantee that client goals will be achieved. Investing in securities involves risk of loss. Further, depending on the different types of investments, there may be varying degrees of risk: Risk of Loss: Securities investments are not guaranteed, and clients may lose money on investments. As with any investment , our investment recommendations are subject to market risk—the possibility that security prices will decline over short or extended periods of time. As a result, the value of client accounts will fluctuate with the market, and clients could lose money over short or long periods of time. Clients should recognize whenever they determine to invest in the securities markets, the entire investment is at risk. Clients should not invest money if they are unable to bear the risk of total loss of their investments. Economic Risk: The prevailing economic environment is important to the health of all businesses and security markets. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an security issuer is located in a country that experiences wide economic swings, or in situations where certain elements of an investment instrument interact with such countries, the investment instrument will generally be subject to a higher level of economic risk. Financial Risk: Financial risk represents internal disruptions within an investment or the issuer that can lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like Enron or many of the “dot com” companies that had weak balance sheets despite initial strong market performance. Market Risk: The value of a client’s portfolio may decrease if the value of an individual company or multiple companies in the portfolio decreases. Further, regardless of how well individual companies perform, the value of a client’s portfolio could also decrease if there are deteriorating economic or market conditions. It is important to understand that the value of clients’ investments may fall, potentially sharply, in response to changes in the market, and clients could lose money. Investment risks include price risk as may be observed by a drop in a security’s price due to company specific events (e.g., earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g., such as a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates could cause security prices to fall. Political & Regulatory Risks: Investments may be subject to risks resulting from a particular political party or regulatory agency. For example, Exploration and Production companies may face additional government and or regulatory oversight that either restricts their ability to develop resources or makes the future development of resources uneconomical. 10 Form ADV 2A Version: 3.17.2026 Equity (Stock) Market Risk: Common stocks are susceptible to fluctuations and to volatile increases/ decreases in value as their issuers’ confidence in or perceptions of the market change. Investors holding common stock (or common stock equivalents) of any issuer are generally exposed to greater risk than if they hold preferred stock or debt obligations of the issuer. Company Risk: There is always a certain level of company or industry specific risk when investing in stock positions. This is referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that a company may perform poorly or that its value may be reduced based on factors specific to it or its industry (e.g., employee strike, unfavorable media attention). Fixed Income Risk: Investing in bonds involves the risk that the issuer will default on the bond and be unable to make payments. In addition, individuals depending on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. ETF and Mutual Fund Risk: ETF and mutual fund investments bear additional expenses based on a pro- rata share of operating expenses, including potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities held by the ETF or mutual fund. Clients also incur brokerage costs when purchasing ETFs. Management Risk: Client investments also vary with the success and failure of Advisor’s investment strategies, research, analysis, and determination of portfolio securities. If Advisor’s strategies do not produce the expected returns, the value of a client’s investments will decrease. Cybersecurity Risk: SWIG’s information and technology systems could become vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltrations by unauthorized persons and security breaches, spyware, usage errors by its professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes, and earthquakes. Although SWIG has implemented various measures to manage these risks, including, but not limited to, creating redundant systems at all times, if these systems are compromised, become inoperable for extended periods of time, or cease to function properly, SWIG could potentially have to make a significant investment to fix or replace them. The failure of these systems and/or disaster recovery plans for any reason could cause significant interruptions in our operations and result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including personal information relating to clients. Such a failure could harm SWIG’s reputation or subject us to legal claims and otherwise affect our business and financial performance. SWIG has taken steps to mitigate these risks by retaining the services of cybersecurity specialists who are experts at monitoring, managing, and mitigating the risks of cyberattacks. This monitoring is implemented seven days a week, 24 hours a day and 365 days a year. Liquidity Risk: Privately held real estate, private equity investments, individual fixed income securities, thinly- traded equity securities, non-traded securities, and other alternative investment products often entail accepting liquidity risk. Liquidity risk is the inability to liquidate/exit an investment and/or liquidation in a timely manner without potentially incurring a significant monetary penalty in order to access their funds. Structured Note Risk: In addition to general market risk, structured notes have certain material risks and characteristics, which may be significant: ƒ Issuer credit/counterparty risk: Structured notes are generally unsecured debt obligations of the issuer. Any “principal protection” or repayment feature is subject to the issuer’s ability to pay; if the issuer defaults, a client could lose some or all principal and any expected payments. 11 Form ADV 2A Version: 3.17.2026 ƒ Complexity and payoff-structure risk: Notes may include features such as participation rates, caps, buffers/barriers/knock-ins, leverage or inverse exposure, and contingent coupons. These features can cause outcomes where a client has limited upside, amplified losses, or losses even when the reference asset increases (depending on the formula). ƒ Liquidity and early-sale risk: A secondary market is often limited; clients may need to hold a note to maturity and could be forced to sell at a significant discount (or may be unable to sell). ƒ Valuation and pricing risk (including “estimated value”): The issuance price paid by investors may exceed the issuer’s estimated value on the issue date due to selling, structuring, and hedging costs embedded in the note’s price. After issuance, notes may be difficult to value due to complexity and limited trading. ƒ Call/early redemption risk: Some notes permit the issuer to redeem prior to maturity, potentially limiting returns and creating reinvestment risk. ƒ Tax risk: Tax treatment can be complicated and, in some cases, uncertain; clients should review offering documents and consult their tax advisers. ƒ Concentration and correlation risk: Notes can embed concentrated exposure to a single security, issuer, sector, or proprietary index methodology; performance may differ materially from simpler exposures to the same reference asset. Client-specific use: Where structured notes are used, we generally evaluate (as applicable): product terms (caps/buffers/barriers), issuer credit profile, maturity/expected holding period, expected liquidity, estimated value vs. offering price, and role in overall portfolio construction. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9: Disciplinary Information There are no legal, regulatory, or disciplinary events involving SWIG or its management persons. SWIG values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www. adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 165474. Item 10: Other Financial Industry Activities and Affiliations A� REGISTRATION AS A BROKER/DEALER OR BROKER/DEALER REPRESENTATIVE Neither SWIG nor its representatives are registered as or have pending applications to become a broker/ dealer or as representatives of a broker/dealer. B� REGISTRATION AS A FUTURES COMMISSION MERCHANT, COMMODITY POOL OPERATOR, OR A COMMODITY TRADING ADVISOR Neither SWIG nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. C� REGISTRATION RELATIONSHIPS MATERIAL TO THIS ADVISORY BUSINESS AND POSSIBLE CONFLICTS OF INTERESTS Consistent with the firm’s financial planning philosophy, our financial professionals may recommend insurance products (for example, fixed index annuities (“FIAs”)) as part of a client’s overall financial plan, including in lieu of allocating certain assets to advisory accounts (e.g., cash and fixed income allocations). 12 Form ADV 2A Version: 3.17.2026 You should understand that recommendations involving insurance products present conflicts of interest because insurance transactions typically involve commission-based compensation and may involve incentive programs. These conflicts are described below, and clients are under no obligation to implement any recommendation through SWD or any affiliated insurance agency. As an estimate, our financial professionals that are registered as investment advisor representatives spend approximately half of their time on insurance sales and services and half of their time on investment advisory services. Please refer to Item 5 – Fees and Compensation and Item 14 – Client Referrals and Other Compensation for more details. You may therefore work with your SWIG financial professional in both their capacity as an investment adviser representative (IAR) of SWIG, as well as in their capacity as an insurance agent through our affiliated company Strategic Wealth Designers, LLC (“SWD”). As such, your SWIG financial professional, in their dual capacity as an IAR and insurance agent, may advise you to purchase insurance products (general disability insurance, life insurance, annuities, and other insurance products), and then assist you in implementing the recommendations by selling you those same products. If you purchase an insurance product through one of our financial professionals acting as an insurance agent, the agent will typically receive a commission from the insurance company or other third party. The receipt of commissions presents a conflict of interest because it creates a financial incentive to recommend insurance products (or particular products) that pay higher or more immediate compensation, which could influence the products we recommend. SWIG seeks to mitigate this conflict by requiring that recommendations be made in the client’s best interest, by disclosing the conflict, and through supervision and periodic reviews of insurance recommendations. Furthermore, because commissions vary by product, associated persons may have an incentive to recommend certain products based on the compensation received. This presents a conflict of interest, as the compensation received on one product may be greater than on another. Insurance products may have different commission schedules and payment timing depending on the product. In some cases, commissions may be paid substantially at the time of purchase, while advisory fees are generally paid over time. This difference in timing can create an incentive to recommend a product that pays compensation sooner rather than an advisory solution that pays over a longer period. For illustration only, a one-time commission on an insurance purchase may be paid upfront, while an advisory fee on a similarly sized account would typically be paid periodically over time. Additional conflicts may arise because our affiliate company, Strategic Wealth Designers (“SWD”), utilizes a third-party insurance marketing organization, Advisors Excel in connection with sourcing and placing certain insurance products. Advisors Excel may offer incentive compensation (which may include cash or non-cash awards) based on meeting specified sales goals or placing products through Advisors Excel. These incentives are typically determined based on aggregate sales and may be paid to the firm and/ or individuals. Such incentives create a conflict of interest because they could influence the selection of products or providers. Clients are not required to purchase any insurance product through Advisors Excel, or SWD. Advisors Excel provides SWD, with marketing assistance and business development tools; technology intended to improve the client experience and firm efficiency; and back office and operations support to assist in the processing of our insurance through Advisors Excel. SWIG seeks to address this conflict through disclosure, supervision, and by requiring that all recommendations be made in the client’s best interest. As a fiduciary, SWIG requires its investment adviser representatives to recommend insurance and annuities only when they believe the recommendation is in the client’s best interest, taking into account 13 Form ADV 2A Version: 3.17.2026 the client’s objectives, time horizon, risk tolerance, liquidity needs, and total costs. Commission-based insurance activity is supervised by the firm’s Managing Members and/or designated supervisors. SWIG conducts periodic reviews of insurance recommendations (including a review of suitability and documentation) and addresses exceptions as appropriate. If you have questions or concerns about an insurance or annuity recommendation, please contact your financial professional or SWIG’s Chief Compliance Officer. Finally, you should be aware that there are other insurance products that are offered by other insurance agents other than those recommended by our financial professionals. You are under no obligation to implement any insurance or annuity transaction through SWD. Ownership Interest in Private Placement We Recommend The principals of SWIG are also minority shareholders of the private fund Total Return Capital Management, LLC (the Fund). Investments in the Fund may be recommended to advisory clients for whom a partnership investment may be more suitable than would a separate advisory account managed by our firm. While SWIG Clients are not charged a second layer of advisory fees by SWIG, the affiliated fund may pay management or performance-based compensation to its owners, including SWIG principals. This creates a conflict of interest because SWIG and its principals may benefit financially when clients invest in the TRCM fund, potentially influencing our recommendations. We seek to mitigate this conflict through policies and procedures designed to ensure that our recommendations remain in clients’ best interests, including: ƒ Full disclosure of the conflict in this Brochure and, where appropriate, in other client communications ƒ Investment due diligence and an investment selection process that considers the Private Placement alongside comparable alternatives ƒ Ongoing monitoring of the Private Placement and the applicable strategy, including periodic reviews to determine whether the Private Placement continues to be appropriate relative to alternatives The Fund is not required to register as an investment company under the Investment Company Act of 1940 in reliance upon an exemption available to funds whose securities are not publicly offered. The Fund is managed on a discretionary basis in accordance with the terms and conditions of its offering and organizational documents. Ownership Interest in an ETF We Recommend The principal(s) of SWIG are also minority shareholders in Coastal Compass 100 ETF ROPE (the “ETF”), an exchange-traded fund that we may recommend to clients and/or include in our model portfolios. In addition, through a minority ownership interest in TRCM, one of our owners also holds an indirect minority ownership interest in Bancreek Capital, the sponsor of Bancreek International Large Cap ETF (BCIL) and Bancreek US Large Cap ETF (BCUS) (together, the “Bancreek ETFs”), which may be in our models in which we recommend to clients. Because a principal has a financial interest in the ETF and because one of our principal(s) has an indirect financial interest in Bancreek Capital and the Bancreek ETFs, these relationships create a conflict of interest: SWIG has an incentive to recommend or cause clients to invest in the ETF and/or the Bancreek ETFs in order to benefit from increases in the value of that ownership interest and/or from any economic benefits associated with such ownership. We seek to mitigate this conflict through policies and procedures designed to ensure that our recommendations remain in clients’ best interests, including: ƒ Full disclosure of the conflict in this Brochure and, where appropriate, in other client communications; 14 Form ADV 2A Version: 3.17.2026 ƒ Investment due diligence and an investment selection process that considers the ETF alongside comparable alternatives (including cost, liquidity, tracking error, tax considerations, and risk/return characteristics); ƒ Ongoing monitoring of the ETF and the applicable strategy, including periodic reviews to determine whether the ETF continues to be appropriate relative to alternatives; ƒ Supervisory oversight of the inclusion of the ETF in models and client accounts; and SWIG and our affiliates are not restricted from forming additional investment funds, entering into other investment advisory relationships or engaging in other business activities. D� SELECTION OF OTHER ADVISERS OR MANAGERS AND HOW THIS ADVISER IS COMPENSATED FOR THOSE SELECTIONS As described in Item 4, SWIG may engage an unaffiliated sub-adviser/platform provider (the “Sub- Adviser”) to provide certain investment management and platform-related services. Through this relationship, SWIG may receive access to technology and support services (for example, model and manager selection tools, trading, reporting, billing, and client service support). In addition, the availability and/or level of certain services, pricing concessions, service credits, or other non-cash benefits may depend on the aggregate client assets that SWIG places with or through the Sub-Adviser. These arrangements present a conflict of interest because they provide an incentive for SWIG to recommend or continue using a particular platform, sub-adviser, or manager. SWIG seeks to mitigate this conflict by evaluating Sub-Advisers and investment options based on client needs and by periodically reviewing the relationship for reasonableness. SWIG has a business relationship with the Advisor, which provides the Firm with consulting services and model portfolio support as described in this Brochure. In some circumstances, the Advisor or its affiliates may sponsor, manage, or be otherwise associated with investment funds or models that the Firm may consider for client accounts. This creates a conflict of interest because the Firm’s consideration or recommendation of an Advisor- affiliated fund in one of our investment models could be viewed as being influenced by the Firm’s relationship with the Advisor. The Firm is under no obligation to recommend any such fund or product and will do so only if the Firm determines that the investment is appropriate for the client in light of the client’s investment objectives, financial situation, and risk tolerance. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A� CODE OF ETHICS We have 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. Our Code of Ethics is available free upon request to any client or prospective client. B� RECOMMENDATIONS INVOLVING MATERIAL FINANCIAL INTERESTS As noted above in Item 10, SWIG may recommend securities in which related persons to  SWIG have a material financial interest. 15 Form ADV 2A Version: 3.17.2026 The Code requires personnel to disclose any and all material financial interests as part of the ongoing compliance process. Clients may receive recommendations to buy securities where a material financial interest exists. C� INVESTING PERSONAL MONEY IN THE SAME SECURITIES AS CLIENTS From time to time, representatives of SWIG may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of SWIG 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. SWIG will always document any transactions that could be construed as conflicts of interest and will always transact client business before their own 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 SWIG may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of SWIG 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. SWIG will always transact clients’ transactions before its own when similar securities are being bought or sold. Item 12: Brokerage Practices A� FACTORS USED TO SELECT CUSTODIANS AND/OR BROKER/DEALERS 1� Research and Other Soft-Dollar Benefits SWIG receives no research, product, or services other than execution from a broker-dealer or third-party in connection with client securities transactions (“soft dollar benefits”). 2� Brokerage for Client Referrals SWIG 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 Clients do not have the ability to direct SWIG which Broker/Dealer/Custodian to use SWIG will require clients to use Schwab’s broker-dealer to execute transactions, except when Schwab uses an outside executing facility for liquidity or best execution. 4� Delegation of Processing Trades to Sub-Adviser When a client’s account has been assigned to the sub-adviser, Envestnet, the processing of trades in client accounts is delegated by SWIG, to the Sub-Advisor. The Sub-Advisor is responsible for submitting transactions for clients on behalf of SWIG, on an individual or aggregated basis, according to the Sub- Adviser’s policies. For a complete description of the Sub-Adviser’s policies regarding aggregate trading, please refer to the Sub-Adviser’s Form ADV2A. B� AGGREGATING (BLOCK) TRADING FOR MULTIPLE CLIENT ACCOUNTS Through Schwab, SWIG maintains the ability to block trade purchases across accounts. Block trading may benefit a large group of clients by providing SWIG the ability to purchase larger blocks resulting in smaller transaction costs to the client. Declining to block trade can cause more expensive trades for clients. 16 Form ADV 2A Version: 3.17.2026 C� STRUCTURED NOTES When structured notes are purchased, they are often sourced through broker-dealers and may be offered on a new-issue basis or via limited secondary markets. As a result, price discovery and liquidity may differ from exchange-traded securities. Clients should understand that structured notes are often not exchange- listed and the issuer, an affiliate, or a distributor may be the only practical source of secondary liquidity (if any). In evaluating broker-dealers and execution for these transactions, we consider (as applicable) availability of the desired exposure/structure, total expected cost (including embedded economic costs), transparency of terms and estimated value disclosures, and the likelihood and terms of secondary liquidity Item 13: Reviews of Accounts A� FREQUENCY AND NATURE OF PERIODIC REVIEWS AND WHO MAKES THOSE REVIEWS Client accounts are reviewed on a periodic sample basis by a compliance representative of the firm with regards to their investment policies and risk tolerance levels. All financial planning accounts are reviewed upon plan delivery by a compliance representative of the firm. 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 will receive at least quarterly from the qualified custodian, a statement or written report that details the client’s account including assets held, asset value and management fees assessed. 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) SWIG does not receive cash compensation from unaffiliated third parties in exchange for providing investment advice to clients. However, as described elsewhere in this brochure, SWIG may receive certain non-cash benefits or services from unaffiliated service providers (including platform or sub-adviser providers) that are made available, in whole or in part, based on the overall client assets serviced through those providers. These benefits create a conflict of interest because they may influence SWIG’s selection of service providers. SWIG addresses this conflict through due diligence, periodic review, and by acting in clients’ best interests. B� COMPENSATION TO NON – ADVISORY PERSONNEL FOR CLIENT REFERRALS From time to time, SWIG may provide nominal, non-cash tokens of appreciation (for example, a restaurant gift card) to individuals who refer prospective clients to the firm. These tokens are not conditioned on the referred person becoming a client, are not based on the size of any account opened, and are not intended to compensate the referrer for solicitation activities. Nonetheless, this practice presents a conflict of interest because it could create an incentive to make referrals. Any such non-cash items are limited in value and frequency under the firm’s Code of Ethics. Item 15: Custody SWIG does not maintain physical possession of client assets. All assets are held by qualified custodians. When advisory fees are deducted directly from client accounts at client’s custodian, SWIG is deemed to 17 Form ADV 2A Version: 3.17.2026 have limited custody of client’s assets and SWIG will have up-front written authorization from the client to deduct advisory fees from the account. Clients will receive account statements from the custodian and should carefully review those statements. Each time a fee is directly deducted from the client accounts, SWIG or its partner Envestnet will send the qualified custodian notice of the amount of fee to be deducted. At least quarterly, the qualified custodian will send to the client an account statement identifying the amount of funds and each security in the accounts at the end of the period and setting forth all transactions in the account during that period. We maintain client assets with a “qualified custodian.” You must engage the custodian to hold your funds and securities, and you will receive account statements directly from the custodian (at least quarterly). SWIG does not maintain physical possession of client cash or securities. Under Rule 206(4)-2 under the Advisers Act (the “Custody Rule”), SWIG is deemed to have limited custody of client funds because: (1) with your written authorization, we may deduct advisory fees from your custodial account; and/or (2) you may authorize the custodian, through a standing letter of authorization (“SLOA”) or similar instruction, to permit SWIG to direct certain disbursements to third parties you designate. Clients may revoke such authorization at any time by notifying the custodian (and, as applicable, SWIG). SWIG may be deemed to have custody when a client establishes certain types of letters of instruction or other asset transfer authorization arrangements with a qualified custodian that permit SWIG to direct disbursements to one or more third parties specifically designated by the client. SWIG intends to structure and administer any such SLOA arrangements in a manner consistent with applicable SEC staff guidance, including maintaining written client authorization and implementing appropriate safeguards designed to limit SWIG’s authority to the specific third parties and amounts authorized by the client. To the extent SWIG satisfies the conditions in applicable SEC staff guidance for SLOA arrangements, SWIG believes it is not required to obtain a surprise examination solely as a result of that limited custody. If those conditions are not met, or if regulatory requirements change, SWIG will take steps to comply with the Custody Rule, which may include obtaining a surprise examination. The custodians recommended by SWIG send a statement to the client, generally on a monthly basis, indicating all amounts disbursed from the account including the amount of management fees paid directly to SWIG. Clients should review statements provided by the Custodian and compare them to any reports provided by SWIG to ensure accuracy, as the Custodian does not perform this review. If you ever have a question about an entry on your SWIG report(s), please call us immediately. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Item 16: Investment Discretion For those client accounts where SWIG provides ongoing supervision, the client has given SWIG written discretionary authority over the client’s accounts with respect to securities to be bought or sold and the amount of securities to be bought or sold. Details of this relationship are fully disclosed to the client before any advisory relationship has commenced. The client provides SWIG discretionary authority via a limited power of attorney in the Investment Advisory Contract and in the contract between the client and the custodian. Item 17: Voting Client Securities (Proxy Voting) SWIG will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the qualified custodian. Clients should direct all proxy questions to the issuer of the security. 18 Form ADV 2A Version: 3.17.2026 Item 18: Financial Information A� BALANCE SHEET SWIG does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. B� FINANCIAL CONDITIONS REASONABLY LIKELY TO IMPAIR ABILITY TO MEET CONTRACTUAL COMMITMENTS TO CLIENTS Neither SWIG nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. C� BANKRUPTCY PETITIONS IN PREVIOUS TEN YEARS SWIG has not been the subject of a bankruptcy petition in the last ten years. 19 Form ADV 2A Version: 3.17.2026

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