STRATEGIC WEALTH INVESTMENT GROUP, LLC

Strategic Wealth Investment Group, LLC Firm Brochure - Form ADV Part 2A Effective: September 30, 2025 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: pgayle@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 500 N. Hurstbourne Parkway, Suite 120 Louisville, KY, 40222 502.412.3354 Email: matt@SWDgroup.com Website: www.SWDgroup.com 9220 W Union Hills Drive Suite 101 Peoria, AZ 85382 623.544.3424 4600 South Syracuse Street Suite 100 Denver, CO 80237 303.952.4044 11030 Circle Point Road Suite 140 Westminster, CO 80020 303.952.4044  1 Alhambra Plaza PH 15 Coral Gables, FL 33134 877.934.7687 3030 N Rocky Point Dr Suite 100 Tampa, FL 33607 813.999.2486 1100 Abernathy Road N.E. Suite L-20 Atlanta, GA 30328 678.638.6363 2680 E. Main Street Plainfield , IN 46168 317.644.0876 9025 River Road Suite 120 Indianapolis, IN 46240 317.644.0876 13146 Ballantyne Corp Place Suite 100 Charlotte, NC 28277 704.817.4233 8041 Arco Corporate Drive Suite 130 Raleigh, NC 27617 919.426.2052 5181 Natorp Blvd Suite 100 Mason, OH 45040 513.492.2198 123 S Broad St. 15th Floor #1555 Philadelphia, PA 19109 877.934.7687 3711 South Mopac Expressway Bldg. 2, Suite 175 Austin, TX 78746 737.247.7683 12377 Merit Drive Suite 120 Dallas, TX 75251 972.327.6511  101 Summit Ave. Suite 100 Fort Worth, TX 76102 817.539.8702 2000 W. Sam Houston Pkwy S. Suite 150 Houston, TX 77042 346.385.0948 1921 Gallows Rd Suite 110 Vienna, VA 22182 703.718.6973 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 March 31, 2025 • Peter Gayle has replaced Chandra Halverson as Chief Compliance Officer. 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 ............................................................................................................................................................................ 1 A. Description of the Advisory Firm ...................................................................................................................................................... 1 B. Types of Advisory Services ................................................................................................................................................................. 1 Investment Supervisory Services ....................................................................................................................................................... 1 Financial Planning ................................................................................................................................................................................ 1 Services Limited to Specific Types of Investments .......................................................................................................................... 1 Written Acknowledgement of Fiduciary Status ............................................................................................................................... 2 C. Client Tailored Services and Client Imposed Restrictions .............................................................................................................. 2 D. Wrap Fee Programs ............................................................................................................................................................................. 2 E. Amounts Under Management ............................................................................................................................................................ 2 Item 5: Fees and Compensation ................................................................................................................................................................... 3 A. Fee Schedule ......................................................................................................................................................................................... 3 Investment Advisory Services Fees ................................................................................................................................................... 3 Financial Planning Fees ....................................................................................................................................................................... 3 B. Payment of Fees .................................................................................................................................................................................... 4 Payment of Investment Advisory Fees.............................................................................................................................................. 4 Payment of Financial Planning Fees .................................................................................................................................................. 4 C. Clients Are Responsible For Third Party Fees .................................................................................................................................. 4 D. Prepayment of Fees .............................................................................................................................................................................. 4 E. Outside Compensation For the Sale of Securities to Clients ........................................................................................................... 4 Item 6: Performance-Based Fees and Side-By-Side Management............................................................................................................ 4 Item 7: Types of Clients ................................................................................................................................................................................. 5 Minimum Account Size ....................................................................................................................................................................... 5 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss .............................................................................. 5 Methods of Analysis and Investment Strategies ...................................................................................................................... 5 A. Risk of Loss ................................................................................................................................................................................... 6 B. Item 9: Disciplinary Information ................................................................................................................................................................. 8 Item 10: Other Financial Industry Activities and Affiliations .................................................................................................................. 8 Registration as a Broker/Dealer or Broker/Dealer Representative ...................................................................................... 8 A. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor....... 8 B. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ................................. 8 C. iii  Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ........................ 9 D. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................ 9 Code of Ethics ............................................................................................................................................................................... 9 A. Recommendations Involving Material Financial Interests ................................................................................................... 10 B. Investing Personal Money in the Same Securities as Clients ................................................................................................ 10 C. Trading Securities At/Around the Same Time as Clients’ Securities ................................................................................. 10 D. Item 12: Brokerage Practices ....................................................................................................................................................................... 10 Factors Used to Select Custodians and/or Broker/Dealers ................................................................................................. 10 A. Research and Other Soft-Dollar Benefits ............................................................................................................................ 10 1. Brokerage for Client Referrals .............................................................................................................................................. 10 2. Clients Directing Which Broker/Dealer/Custodian to Use ............................................................................................. 11 3. Aggregating (Block) Trading for Multiple Client Accounts ................................................................................................. 11 B. Item 13: Reviews of Accounts .................................................................................................................................................................... 11 Frequency and Nature of Periodic Reviews and Who Makes Those Reviews................................................................... 11 A. Factors That Will Trigger a Non-Periodic Review of Client Accounts................................................................................ 11 B. Content and Frequency of Regular Reports Provided to Clients ......................................................................................... 11 C. Item 14: Client Referrals and Other Compensation ................................................................................................................................ 11 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other A. Prizes) 10 Compensation to Non – Advisory Personnel for Client Referrals ....................................................................................... 12 B. Item 15: Custody .......................................................................................................................................................................................... 12 Item 16: Investment Discretion .................................................................................................................................................................. 13 Item 17: Voting Client Securities (Proxy Voting) ..................................................................................................................................... 13 Item 18: Financial Information ................................................................................................................................................................... 13 Balance Sheet .............................................................................................................................................................................. 13 A. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ................... 13 B. Bankruptcy Petitions in Previous Ten Years .......................................................................................................................... 13 C. iv  Item 4: Advisory Business A. Description of the Advisory Firm Strategic Wealth Investment Group, LLC is a Limited Liability Company organized in the state of Delaware. 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. When offering our services, we may use the doing business 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: Investment strategy Asset allocation Risk tolerance • • • Personal investment policy Asset selection Regular portfolio monitoring • • • SWIG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SWIG will require 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. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning, life insurance; tax concerns; 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, ETFs, REITs, insurance products including annuities, and government securities. SWIG may use other securities as well to help diversify a portfolio when applicable. Form ADV 2A Version: 9.15.2025 1  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 creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • • • • Meet a professional standard of care when making investment recommendations (give prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and Give you basic information about conflicts of interest. • • 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 matches 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 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 end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. SWIG does not participate in any wrap fee programs. E. Amounts Under Management SWIG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $1,110,956,980 $0.00 December 2024 Form ADV 2A Version: 9.15.2025 2  Item 5: Fees and Compensation A. Fee Schedule Investment Advisory Services Fees The following table represents the base schedule of fees charged by a 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 1.50% 1,000,001- $2,499,999 1.00% $2,500,000 - $4,999,999 0.75% Above $5,000,000 0.50% These fees are negotiable depending upon the needs of the client and complexity of the situation, and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Fees are paid monthly in arrears to SWIG, and clients may terminate their contracts with fifteen days’ written notice. Because fees are charged in arrears, no refund policy is necessary. Clients may terminate their accounts without penalty within 5 business days of signing the advisory contract. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Financial Planning Fees Depending on the complexity of the situation and the needs of the client, the fee for financial planning services are negotiable and will be attached as Exhibit II of the Financial Planning Agreement. Fees are paid in advance, but never more than six months in advance. Clients may terminate their contracts without penalty within five business days of signing the Financial Planning Agreement. Fees that are charged in advance will be refunded based on the prorated amount of work completed at the point of termination. The fee refunded will be the balance of the fees collected in advance minus the remaining percentage of the plan left to be completed. In any educational seminar we may charge the client for printing and binding costs of the workbooks, other material costs or to recover a portion of venue rental cost. In these cases, the fee will be disclosed and collected before the event begins. Form ADV 2A Version: 9.15.2025 3  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 written authorization. Payment of Financial Planning Fees Payment of Financial Planning Fees may be paid via check, credit card or cash in advance, but never more than six months in advance. Fees charged in advance will be refunded based on the prorated amount of work completed at the point of termination. Material and event fees will not be refunded unless the event is not attended. C. Clients Are Responsible 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 SWIG. Please see Item 12 of this brochure regarding broker/custodian. D. Prepayment of Fees SWIG collects fees in advance and in arrears. Fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination and the total days during the billing period. Fees will be returned within fourteen days to the client via mailed check. E. Outside Compensation For the Sale of Securities to Clients Neither SWIG nor its supervised persons accept any compensation 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 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. 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. Form ADV 2A Version: 9.15.2025 4  Item 7: Types of Clients SWIG generally provides investment advice and/or management supervisory services to the following types of clients:  Individuals  High-Net-Worth Individuals  Corporations or Business Entities Minimum Account Size There is an account minimum, $25,000, 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 primarily employs 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, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. 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: o Long term purchases (investments held at least a year) o Short term purchases (investments sold within a year) Form ADV 2A Version: 9.15.2025 5  Model Portfolios SWD has developed and implemented a number of model portfolios (portfolios) that may be suitable for clients depending upon a client’s goals and individual risk tolerance, which is developed via risk questionnaire and/or via consultation with an advisor. These diversified portfolios may include some combination of publicly traded securities such as: exchange traded funds (ETFs), mutual funds, or individual securities. Portfolios are developed and monitored using a combination of internal and external resources, with portfolios typically rebalanced a minimum of twice, annually. Non Traded Securities/Private Placements Under certain circumstances, SWIG may recommend 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. 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.. Form ADV 2A Version: 9.15.2025 6  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. 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 Form ADV 2A Version: 9.15.2025 7  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. 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 Due to the firm’s financial planning philosophy, it is common for our financial professionals to recommend that clients utilize insurance products as part of the client’s overall financial plan in lieu of separately managed accounts (specifically, in lieu of cash and fixed income asset classes). There are potential conflicts of interest you should be aware that are present due to our planning philosophy and recommendations to utilize insurance products in this nature. Please refer to Item 5 – Fees and Compensation and Item 14 – Client Referrals and Other Compensation Form ADV 2A Version: 9.15.2025 8  for more details. You may therefore work with your SWIG financial professional in both their capacity as an investment adviser representative 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. There could be other conflicts present as well. SWD utilizes the services of Advisors Excel, a third-party insurance marketing organization ("IMO") to select the appropriate product for our clients. The purpose of the IMO is to assist us in finding the insurance product that best fits the client’s situation, although the IMO and insurance carrier may also offer special bonus or incentive compensation to our firm when when it meets certain overall sales goals by placing annuities and/or other insurance products through the IMO. This could create a conflict of interest for SWD to utilize the products recommended by the IMO. The principals of SWIG are also shareholders of the PRIVATE FUND Total Return Capital Management, LLC (the Fund). SWIG and our affiliates are not restricted from forming additional investment funds, entering into other investment advisory relationships or engaging in other business activities. 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. SWIG Clients who invest in the Fund are not charged any additional advisory fees other than the advisory fee allocated to the limited partners of the Fund. 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. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections SWIG 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 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 Form ADV 2A Version: 9.15.2025 9  upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests As noted above in Item 10, SWIG m a y recommend securities in which related persons to SWIG have a material financial interest. 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 client’s 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 The Qualified Custodian, Charles Schwab and Co. Inc., member FINRA/SIPC was chosen based on their relatively low transaction fees and access to mutual funds and ETFs. SWIG will never charge a premium or commission on transactions, beyond the actual cost imposed by Custodian. 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 Form ADV 2A Version: 9.15.2025 10  broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use SWIG will require clients to use a specific broker-dealer to execute transactions. B. Aggregating (Block) Trading for Multiple Client Accounts 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. Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts are reviewed on a periodic 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 q u a l i f i e d custodian, a s t a t e m e n t o r 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) Form ADV 2A Version: 9.15.2025 11  SWIG does not receive any economic benefit, directly or indirectly from any third party for advice rendered to SWIG clients. B. Compensation to Non – Advisory Personnel for Client Referrals SWIG may offer nominal non-cash compensation (typically a restaurant gift card) when it receives referrals of new clients. The total dollar amount offered to any client for referrals in a calendar year shall not conflict with the de minimis amount identified in the Firm’s Code of Ethics. Item 15: Custody SWIG does not take custody of client accounts at any time. Custody of client’s accounts held primarily at Charles Schwab and Co., Inc member FINRA/SIPC. Clients will receive account statements from the custodian and should carefully review those statements. SWIG will have written authorization from the client to deduct advisory fees from the account. Each time a fee is directly deducted from the client accounts, SWIG 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. All Clients must place their assets with a “qualified custodian.” Clients are required to engage the Custodian to retain their funds and securities and direct SWIG to utilize that Custodian for the Client’s security transactions. SWIG does not maintain physical possession of client cash or securities; however, pursuant to Rule 206(4)-2 of the Advisers Act under the Amended Custody Rule, SWIG is deemed to have limited custody of client funds because of (1) its authority from most clients to directly deduct fees from the clients’ custodial accounts, and/or (2) its ability to disburse client funds to a third party as authorized by a standing letter of authorization (SLOA) given by the client SWIG is also deemed to have custody when a client establishes certain types of letters of instruction or other asset transfer authorization arrangement with their qualified custodian, authorizing SWIG to disburse funds to one or more third parties specifically designated by the client. SWIG relies on SEC guidance for firms with this type of custody, and is not subject to a surprise annual audit as SWIG confirms it meets the requirements of the 7- step test as established by the SEC, to avoid being subject to a surprise annual audit. 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. Form ADV 2A Version: 9.15.2025 12  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. 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. Form ADV 2A Version: 9.15.2025 13