STUDIO INVESTMENT MANAGEMENT, LLC

FORM ADV PART 2A Firm Brochure March 13, 2025 STUDIO Investment Management, LLC 1901 N. Clybourn Ave., Suite 404 Chicago, IL 60614 312.399.0828 CRD #: 158489 This brochure provides informa3on about the qualifica3ons and business prac3ces of STUDIO Investment Management, LLC (referred to herein as “STUDIO” or the “Firm”). STUDIO does business as Studio Investment Management. If you have any ques3ons about the contents of this brochure, please contact STUDIO at 312.399.0828 or mwolcoP@studioinvestment.com. The informa3on in this brochure has not been approved or verified by the United States Securi3es and Exchange Commission (“SEC”) or any state regulatory authority. STUDIO is a registered investment adviser. Registra3on of an investment adviser does not imply any level of skill or training. Addi3onal informa3on about STUDIO is also available on the SEC’s website at hPp://www.adviserinfo.sec.gov/.  Item 2 – Material Changes Since STUDIO Investment Management, LLC’s last annual updated ADV filed on 03/22/2024, the Firm has had no material changes. If you have any ques3ons about the contents of this brochure, please contact STUDIO at 312.399.0828 or mwolcoP@studioinvestment.com. ADV 2A V250313 | 03/13/2025 | Page 2 of 16  Table of Contents ITEM 2 – MATERIAL CHANGES 2 TABLE OF CONTENTS 3 ITEM 4 – ADVISORY BUSINESS 4 ITEM 5 – FEES AND COMPENSATION 5 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT 7 ITEM 7 – TYPES OF CLIENTS 8 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS 8 ITEM 9 – DISCIPLINARY INFORMATION 10 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 11 ITEM 11 – CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL TRADING 11 ITEM 12 – BROKERAGE PRACTICES 12 ITEM 13 – REVIEW OF ACCOUNTS 15 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION 15 ITEM 15 – CUSTODY 16 ITEM 16 – INVESTMENT DISCRETION 16 ITEM 17 – VOTING CLIENT SECURITIES 16 ITEM 18 – FINANCIAL INFORMATION 16 ADV 2A V250313 | 03/13/2025 | Page 3 of 16  Item 4 – Advisory Business Firm DescripNon STUDIO Investment Management, LLC (referred to herein as “STUDIO” or the “Firm”) is an investment adviser registered with the U.S. Securi3es and Exchange Commission and provides discre3onary investment advisory services, financial planning, and investment consul3ng to its clients. STUDIO does business as STUDIO Investment Management. The majority owners of the Firm are Mike WolcoP and Neha Prabhu through STUDIO Associates, LLC. STUDIO also has a passive, minority investor through STUDIO Holdings, LLC. STUDIO was founded on four key beliefs: 1) A small, well-aligned client base allows for a bou3que experience with a personal touch. 2) An investment philosophy should be built on research intensity and price sensi3vity. 3) An investment philosophy should be executed with a calm temperament and a long-term mindset. 4) A sensi3vity to all client costs – including STUDIO fees, custodial fees, fund expenses, trading commissions, market-impact costs, taxes, and infla3on – is essen3al. Services Offered 1) STUDIO’s discre3onary investment advisory services are represented by rela3onships in which STUDIO can manage and direct the investment decisions for designated accounts according to the client’s wriPen guidelines and restric3ons. As a result, this discre3onary authority includes both asset alloca3on (i.e., the mix of stocks, bonds, cash, and other) and security selec3on (i.e., the choice of par3cular stocks, bonds, cash, and other). Most discre3onary client assets will be invested in stocks, bonds, exchange-traded funds, exchange- traded notes, op3ons, mutual funds, money-market instruments, and cash. An independent custodian will hold client assets, which should employ controls to protect client assets from misappropria3on. STUDIO may also use a pladorm provided by Pontera Solu3ons to manage employer-sponsored re3rement accounts – primarily 401(k) accounts, 403(b) accounts, 529 accounts. In most such cases, STUDIO will provide discre3onary investment advisory services. 2) Clients of STUDIO’s discre3onary investment advisory services may request that STUDIO conduct re3rement- plan analyses, educa3on-funding analyses, or reviews of Outside Assets (“Outside Assets”; i.e., assets over which STUDIO does not have discre3on, such as 401k accounts or Execu3ve Savings Plans). Clients may request analyses and reviews of Outside Assets up to twice per year, and such analyses may be delivered either verbally or in wri3ng. 3) STUDIO may also occasionally discuss topics with its discre3onary investment advisory clients pertaining to taxes, insurance, or estate maPers, but in such topics STUDIO insists that clients seek primary advice from accountants/tax professionals, insurance professionals, estate aPorneys, or other relevant experts. STUDIO also insists that its related exchanges with clients should not be deemed sufficient and should not be deemed accoun3ng, insurance, or legal advice, whether discussed in isola3on or in rela3on to other investment advisory services. STUDIO may offer one-3me or ongoing investment consul3ng or financial-planning engagements. Planning components may include re3rement planning, tax planning, estate planning, insurance planning, real estate analysis, educa3on-funding analysis, and execu3ve-compensa3on analysis. Consul3ng components may include asset-alloca3on review and investment-security review. Neither STUDIO, nor any affiliate, nor any associated person will receive commissions from the sale of insurance or real estate, nor will it ADV 2A V250313 | 03/13/2025 | Page 4 of 16  receive fees or other compensa3on from the sale of securi3es or other products or services recommended in any financial plan. The client is under no obliga3on to act on the recommenda3ons of STUDIO, its affiliates, or its associated persons. 4) STUDIO may provide non-discre3onary investment advisory services for a fee on a limited basis on either a por3on of the assets held in an account or an en3re account, with the client retaining final investment decision-making authority. Tailoring Your Account to Your ObjecNves Client accounts will be managed based on the client’s guidelines and restric3ons, provided the client provides such guidelines and restric3ons in wri3ng to STUDIO (e.g., in Schedule B of the client’s investment advisory agreement with STUDIO). There are cases in which a client holds a par3cular security that the client does not want to be managed or monitored by STUDIO. In some of these situa3ons, STUDIO may recommend holding the security in an account over which STUDIO has no discre3on or investment authority. Without explicit wriPen guidelines and restric3ons, STUDIO encourages clients to develop conserva3ve expecta3ons and consider their overall financial situa3ons, future financial objec3ves, risk tolerances, 3me horizons, and investment objec3ves and constraints. Wrap Fee Programs STUDIO does not par3cipate in wrap-fee programs. (Wrap fee programs offer services for a single, all-inclusive fee.) Assets Under Management As of December 31, 2024, STUDIO had assets under management of $831,519,111 on a discre3onary basis. STUDIO does not currently manage any assets on a non-discre3onary basis. Item 5 – Fees and Compensa@on Investment Advisory Services – Fees STUDIO’s investment advisory service fee schedule is calculated based on the client’s assets under management as follows: Account Value Tier $0 to $1,000,000 $1,000,001 to $3,000,000 $3,000,001 to $10,000,000 $10,000,001+ Annual Fee Rate 1.25% 1.00% 0.75% 0.50% Account Values are based on the average daily balance during the month. Average daily balances are based on the values of all securi3es and cash. Monthly fee rates are Annual Fee Rate divided by 12. Certain legacy clients and their associated par3es have been or will be waived into a prior fee schedule and fee- billing methodology that differs from the fee schedule and fee-billing methodology described herein; such clients ADV 2A V250313 | 03/13/2025 | Page 5 of 16  should refer to their specific Investment Advisory Agreement for a complete descrip3on of the applicable fee schedule and fee-billing methodology. While STUDIO’s fees are not nego3able, STUDIO may decide at its own discre3on to charge any client a fee for investment advisory services that is different from the fees set forth in the fee schedule above. STUDIO typically requires a minimum asset level of $1,000,000 for its investment advisory services’ rela3onships. STUDIO, in its sole discre3on, may waive the required minimum asset level. See also “Item 7: Types of Clients” below. Lower fees for comparable services may be available from other sources. Investment Advisory Services – Fee AdministraNon Clients pay fees to STUDIO on a monthly or quarterly basis in arrears. Fees may be paid by automa3c deduc3on from client accounts, which requires wriPen pre-authoriza3on by the client to the custodian. Alterna3vely, fees may be paid by check. STUDIO will provide the client with a statement displaying the advisory fees regardless of the payment method. If STUDIO deducts fees directly from the client’s account, the custodian will indicate the amount of the fees, at least quarterly, in a client statement. However, the client’s custodian will not verify the accuracy of STUDIO’s fee calcula3on. Investment Advisory Services – Custody Fees The client may be required to pay, in addi3on to STUDIO’s fees, underlying fees and charges assessed by the custodian, including custodial fees, brokerage fees, transfer fees, margin interest, and other transac3on costs. Any custodian fee is nego3ated directly between the client and the custodian. The custodian may also receive an administra3ve fee from certain money-market mutual funds; if this is the case, it should be disclosed in the custodian’s agreement with the client. The client bears responsibility for verifying the accuracy of these custodian fees and charges. Please refer to “Item 12: Brokerage Prac3ces” below. Investment Advisory Services – Individual-Security Fees, Expense Fees/RaNos, Rollovers The fees charged by STUDIO do not include fees or expenses charged by any security or fund selected for the client. For example, exchange-traded funds and mutual funds generally charge a fee for their services as a manager. This management fee is part of the total compensa3on received by the fund company and is included in its expense ra3o. STUDIO is not paid any sales, service, or administra3ve fees for the sale of any securi3es or other products. These individual-security fees or expense ra3os should be disclosed in each security’s disclosure document or in each fund’s prospectus. These should be available from the custodian or the SEC’s website (www.sec.gov). STUDIO may recommend the client transfer assets from an employer-sponsored re3rement plan to an IRA account (i.e., a Rollover). Such a recommenda3on may represent a conflict of interest, since STUDIO earns investment advisory fees from IRA accounts that it manages. STUDIO’s Rollover recommenda3ons consider various factors related to the client’s financial circumstances and investment guidelines and restric3ons. Among other factors, STUDIO considers the following factors, to the extent possible, for both the employer’s plan and an IRA account to be managed by STUDIO: 1) the range of investment op3ons available; 2) the various fees the client will pay (to the ADV 2A V250313 | 03/13/2025 | Page 6 of 16  extent available and provided), including STUDIO’s investment advisory fees; 3) the levels of service available; 4) the client’s exper3se in self-direc3ng investments; and 5) the tax consequences, including poten3al penal3es that may be assessed if the client withdraws funds before permissible ages as set by the IRS, as well as the tax consequences of rolling over employer stock held in a plan. STUDIO also recommends that the client consult a tax advisor on transfers from employer-sponsored re3rement plans to an IRA account. As discussed in Item 4 above, STUDIO may use a pladorm provided by Pontera Solu3ons to provide services to certain types of client accounts – typically employer-sponsored re3rement accounts. Pontera does not have trading authority and does not bill STUDIO’s clients. Instead, STUDIO pays Pontera directly for access to the pladorm. Clients pay STUDIO for these services as explicitly agreed to in the Investment Advisory Agreement. Suitability documenta3on will be held with the custodian of the re3rement plan and cannot be changed by STUDIO. Investment Advisory Services – Client Use of Margin Borrowing A custodian may authorize a client’s account for the use of margin borrowing (or margin). However, STUDIO does not recommend the use of margin. The client maintains sole discre3on as to whether margin is used in the account. If the client uses margin, the market value of the account and the corresponding advisory fee payable by the client to STUDIO will be greater than without the use of margin. As a result, in addi3on to understanding and assuming the addi3onal principal risks associated with the use of margin (see Item 8 for more), clients authorizing the account for margin are advised of a poten3al conflict of interest, since the client’s decision to employ margin will correspondingly increase the advisory fee payable to STUDIO. In other words, STUDIO may have an economic disincen3ve to recommend that the client terminate the use of margin. Investment Advisory Services – CompensaNon for the Purchase or Sale of SecuriNes STUDIO is compensated solely through advisory, planning, and consul3ng fees paid by clients. STUDIO is not paid any sales, service, or administra3ve fees for the sale of any securi3es or other products. Investment ConsulNng and Financial Planning – Fees STUDIO offers its investment-consul3ng or financial-planning services for a fixed fee. Generally, an ini3al investment-consul3ng or financial-planning engagement requires at least one in-person mee3ng, research and analysis, and the prepara3on and presenta3on of recommenda3ons. The 3me needed to complete a par3cular requested service will vary depending on the client’s specific financial circumstances. Prior to commencing the engagement, STUDIO will provide a fixed fee to complete all the components the client has directed. Prepayment of Fees No fees are paid in advance to STUDIO. Item 6 – Performance-Based Fees and Side-by-Side Management STUDIO does not charge performance-based fees. ADV 2A V250313 | 03/13/2025 | Page 7 of 16  Item 7 – Types of Clients STUDIO offers its investment advisory services to various types of clients, including individuals, high-net-worth individuals, trusts, partnerships, re3rement plans, government en33es, and other legal en33es. STUDIO typically requires a minimum asset level of $1,000,000 to establish an investment advisory services rela3onship. STUDIO, in its sole discre3on, may waive the required minimum asset level. Aper establishing a rela3onship with STUDIO, clients are not required to maintain a par3cular balance in their accounts. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis and Investment Strategies STUDIO uses fundamental analysis in its investment strategies. STUDIO may u3lize passive or indexed strategies as well. Generally, the Firm’s investment philosophy focuses on price sensi3vity (i.e., value-minded inves3ng) with a long-term mindset. Fundamental analysis considers the compe33ve posi3on of the underlying en3ty, the financial health of the en3ty, the quality of its management or leadership, and the exis3ng price level of the security rela3ve to prospects for future cash flows. Client pordolios are managed u3lizing a mixture of several security types. Most of the assets will be represented by individual stocks, individual bonds, exchange-traded funds, exchange-traded notes, op3ons, mutual funds, money- market instruments, and cash. A variety of research sources are used, including, but not limited to, financial newspapers and magazines, business publica3ons, third-party research materials, SEC filings, other regulatory filings, annual reports, other company reports, and industry conferences. Addi3onally, through its third-party financial-planning sopware, STUDIO may use Monte Carlo simula3on or other simula3ons in prepara3on for client re3rement analyses or other analyses. Generally, simula3on is a mathema3cal process that aPempts to assess the probabili3es of future financial-market paths and client outcomes, by using historical market results, forecasted market results, or other reasoned methods to create hundreds (or more) of forward-looking simula3ons. Simula3ons are used to help STUDIO and its clients assess client preparedness for re3rement needs and other needs. Risk of Loss There will be many periods in which the stock, bond, and other markets generate losses (or nega3ve returns). Clients should only invest money to the extent that they can bear the risk of such losses. STUDIO uses fundamental analysis in its investment strategies. STUDIO may u3lize passive or indexed strategies as well. Risks to fundamental analysis include vola3lity risk, market risk, compe33ve risk, technological risk, liquidity risk, and valua3on risk. Risks to passive strategies include vola3lity risk, market risk, liquidity risk, valua3on risk, and tracking error, which is the failure of the fund to track the underlying index perfectly. ADV 2A V250313 | 03/13/2025 | Page 8 of 16  STUDIO’s investment decisions always consider both the prospects for return on investment and the risk of loss on investment. In considering the risk of loss, STUDIO generally contemplates both the probability of loss and the poten3al magnitude of such loss. Some of the risks of loss include vola3lity risk, market risk, compe33ve risk, technological risk, liquidity risk, infla3on risk, exchange-rate risk, interest-rate risk, reinvestment risk, poli3cal risk, tax-law risk, regulatory risk, monetary-policy risk, fiscal-policy risk, and valua3on risk. These and other risks should be considered as the client establishes the appropriate wriPen guidelines and restric3ons to include in Schedule A of STUDIO’s Investment Advisory Agreement with the client. A margin-borrowing (or margin) strategy (also discussed in Item 5), in which a client uses borrowed assets to purchase (or maintain investment in) financial securi3es, involves a high level of risk. The client generally obtains the borrowed assets by using other securi3es as collateral. In using margin, account gains or losses will be magnified. While the use of margin can improve investment results, it also increases the riskiness of the client’s account. In other words, the use of margin increases the magnitude of losses. Under certain circumstances, the custodian may demand an increase in the collateral that secures the client’s obliga3ons; if the client were unable to provide addi3onal collateral, the custodian could, without approval by the client or STUDIO, liquidate assets held in the account to sa3sfy the client’s obliga3ons. Liquida3on in such manner could have an adverse effect on the account. In addi3on, the amount of the client’s margin borrowing and the interest rates on those borrowings, which will likely fluctuate, will significantly affect the account’s results. STUDIO does not recommend the use of margin. The client maintains sole discre3on as to whether margin is used in the account. Risks of Investments Used Clients should be aware that there is a material risk of loss when inves3ng. The investments listed below, as well as any other investments STUDIO may use, are not guaranteed or insured by the FDIC or any other government en3ty. Equity securi3es generally refer to shares of publicly traded companies (i.e., stocks) that may produce dividends and capital gains or losses. Equity securi3es can lose substan3al value. The value of equity securi3es may fluctuate in response to company-specific condi3ons, country-specific condi3ons, industry-specific condi3ons, or general stock-market and economic environments. Fixed-income securi3es generally refer to debt instruments (i.e., bonds) that pay interest on a fixed schedule, though the amount of the payments and the 3me horizon of such payments can vary. Even the least risky fixed- income securi3es can lose value, and some can lose substan3al value. Fixed-income securi3es include corporate and government debt securi3es, leveraged loans, high-yield debt securi3es, investment-grade debt, and structured products, such as mortgage and other asset-backed securi3es. Fixed-income securi3es carry significant interest- rate risk and can experience significant vola3lity. (As interest rates rise, bond prices usually fall, and vice versa.) Fixed-income securi3es also carry infla3on risk, liquidity risk, call risk, currency risk (in the case of non-U.S. securi3es), and credit and default risks for both issuers and counterpar3es. Mutual funds and closed-end funds generally refer to investments that allow money to be pooled with the funds of other investors to purchase stocks, bonds, or other securi3es. Mutual funds and closed-end funds can lose substan3al value. Nearly all mutual funds and closed-end funds have expenses that reduce net-of-fee investment returns. Mutual funds carry the risk of rapid redemp3ons and forced selling. Closed-end funds carry liquidity risk. ADV 2A V250313 | 03/13/2025 | Page 9 of 16  Exchange-Traded Funds (ETFs) are traded on exchanges (like stocks). ETFs can lose substan3al value. An ETF holds assets such as stocks, bonds, or commodi3es and is designed to keep its share price close to its net asset value, although devia3ons can occur. Areas of concern include lack of transparency, conflicts of interest, poten3ally inadequate regulatory compliance, and complexity. Exchange Traded Notes (ETNs) are unsecured, unsubordinated debt securi3es issued by a bank. ETNs can lose substan3al value. Like other debt securi3es, ETNs have a maturity date and are backed only by the credit of the issuer. ETNs are designed to provide investors access to the returns of various market benchmarks. The value of an ETN may decrease even if the underlying index is unchanged, due to changes in the outlook for the issuer’s credit. Index funds aim to replicate the movements of a specific index of securi3es. Index funds can lose substan3al value. Index funds can be in the form of mutual funds, closed-end funds, ETFs, or ETNs. An imperfect correla3on between the securi3es in the index fund and those in the underlying index can result in tracking error – the failure of the fund to perfectly track the underlying index. This risk may be heightened during 3mes of increased market vola3lity or other unusual market condi3ons. Tracking error also occurs because a pordolio incurs fees and expenses while an underlying index does not. Deriva3ves are contracts that derive their value from an underlying en3ty. Deriva3ves can lose substan3al value, and it is not uncommon for them to lose all their value, and even more than all their value in some strategies. The risk of deriva3ves is some3mes increased using leverage (i.e., borrowing). Addi3onally, deriva3ves can generate large gains and large losses from even small movements in the underlying asset’s price. Op3ons are a type of deriva3ve that allow a buyer the right to purchase or sell an underlying security at a given price on or before a given date. Op3ons buying and selling can result in substan3al losses. Risk of Reliance on SimulaNons Simula3ons (discussed above) may not be representa3ve of future financial-market results. The aggregated data presented by STUDIO to clients regarding the probabili3es of success for financial-planning analyses, re3rement analyses, or other analyses should not be relied upon as absolute or accurate probabili3es, but instead should be viewed only as projec3ons. Future financial-market results can differ greatly from the summary data points or even the outlier data points presented to clients in re3rement analyses or other analyses. Historical market results, forecasted market results, or other reasoned projec3ons of future financial-market results may not accurately or even reasonably resemble the market’s future path or client outcome. Addi3onally, re3rement plans and other plans require many other es3mates that may differ from future results. As a result, since such future projec3ons and es3mates are uncertain, client re3rement goals or other goals may not be fulfilled by following STUDIO’s advice in re3rement analyses or other analyses. Past performance is not indicaNve of future results. InvesNng in securiNes involves a risk of loss that you, as a client, should be prepared to accept. Item 9 – Disciplinary Informa@on STUDIO is required to disclose all material facts regarding legal or disciplinary events that would be material to a client’s evalua3on of the Firm. Neither STUDIO nor management persons have been involved in any legal or disciplinary events related to past or present items. ADV 2A V250313 | 03/13/2025 | Page 10 of 16  Item 10 – Other Financial Industry Ac@vi@es and Affilia@ons AcNviNes and AffiliaNons Neither STUDIO nor any of its management persons are registered or have an applica3on pending to register as a broker-dealer, registered representa3ve of a broker-dealer, futures commission merchant, commodity pool operator, or a commodity trading advisor. STUDIO nor its management persons have affilia3ons with other businesses or en33es and receive no compensa3on from any other en3ty. STUDIO does not select other investment advisers for its clients. STUDIO may purchase fixed-income securi3es through the sales division of Bernardi Securi3es, Inc. (“Bernardi”). A son of Michael Vezzeq, an investment adviser with STUDIO, is employed by Bernardi in its public finance division. In his work with Bernardi, Michael Vezzeq does not interact with his son or discuss securi3es that STUDIO may purchase or has purchased through Bernardi. Item 11 – Code of Ethics, Par@cipa@on in Client Transac@ons and Personal Trading Code of Ethics STUDIO has adopted a Code of Ethics (the “Code”) describing our standards of business conduct and our fiduciary duty to clients. The Code provides provisions rela3ng to the prohibi3on on insider trading, restric3ons on the acceptance of significant gips, the repor3ng of certain gips and business entertainment items, and personal securi3es trading procedures, among other things. The Code also references STUDIO’s Privacy Policy, which provides provisions for the confiden3ality of client informa3on. STUDIO is commiPed to an annual review of its compliance program. All supervised persons of STUDIO must acknowledge the terms of the Code ini3ally, annually, and as amended. Clients and prospec3ve clients may request a copy of STUDIO’s Code at any 3me by contac3ng Mike WolcoP at 312.399.0828 or mwolcoP@studioinvestment.com. ParNcipaNon/Interest in Client TransacNons STUDIO has policies and procedures in place to ensure that the interests of its clients are given preference over those of the Firm, its affiliates, and its supervised persons. All supervised persons are subject to STUDIO’s policies and procedures, which include various repor3ng and disclosure requirements. Both the Firm’s Code and its policies and procedures are designed to best assure that the personal securi3es transac3ons, ac3vi3es, and interests of the Firm’s employees do not interfere with decision-making that is in the best interest of clients. All employees of STUDIO must acknowledge through the Code the terms of the Firm’s policies and procedures annually or as amended. Personal Trading STUDIO, its owners and employees, and their families, trusts, estates, charitable organiza3ons, and re3rement plans established by STUDIO or its owners or supervised persons (“Internal Accounts”) may purchase the same securi3es as client accounts. This has the poten3al to create a conflict of interest because it allows STUDIO or its related persons to profit from the investment recommenda3ons made to clients. STUDIO’s policies and procedures and Code address this conflict of interest by prohibi3ng such trading by STUDIO or its related persons if it would be to the detriment of any client and by monitoring for compliance through the repor3ng and reviewing personal securi3es transac3ons. In all instances, STUDIO will act in the best interests of its clients. ADV 2A V250313 | 03/13/2025 | Page 11 of 16  Internal Accounts are eligible for securi3es transac3ons that differ from those recommended or effected for the Firm’s clients. STUDIO does not recommend to clients or buy or sell for clients’ accounts any securi3es in which it or a related person has a material financial interest. Mike WolcoP, STUDIO’s Managing Principal and CCO, is responsible for reviewing and, if necessary, approving personal securi3es transac3ons according to the Firm’s Code. Item 12 – Brokerage Prac@ces Custodian and Brokerage Client assets must be maintained by a “qualified custodian”. STUDIO recommends that clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer and member of the Securi3es Investor Protec3on Corpora3on (SIPC), as the qualified custodian to hold client assets and execute trades upon receipt of instruc3ons from the Firm. STUDIO does not have the power of aPorney to select a custodian on the client’s behalf and, therefore, does not have the discre3on to select the custodian for the client. As a result, clients should make their own reviews of Schwab’s services and make inquiries with Schwab as appropriate. In effect, a client must choose to custody assets at Schwab to work with STUDIO. RecommendaNon of Custodians STUDIO may consider a wide range of factors in recommending custodians for client accounts, which include the following: • financial strength and reputa3on • capability to execute trades • capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payments, etc.) • breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.) • availability of investment research and tools • quality of services, including customer service • compe33veness of commission rates, margin interest rates, and other fees • availability of other products and services that benefit STUDIO, as discussed below (see “Products and Services Available from Schwab”) Brokerage and Custody Costs In client accounts that Schwab maintains, Schwab generally does not charge separately for custody services, but it is compensated by charging the client commissions or other fees on some executed or sePled trades. If the client owns Schwab-managed funds, Schwab will be compensated by fund expenses. Products and Services Available from Schwab ADV 2A V250313 | 03/13/2025 | Page 12 of 16  Schwab Advisor Services (“SAS”) is Schwab’s business serving independent investment advisory firms like STUDIO. SAS provides STUDIO and its clients with access to its ins3tu3onal brokerage services — trading, custody, repor3ng, and related — many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help STUDIO manage or administer client accounts, while others help STUDIO manage its business. Schwab’s support services generally are available on an unsolicited basis (i.e., STUDIO does not have to request them) and at no charge to STUDIO. Following is a more detailed descrip3on of Schwab’s support services: Services That Benefit Clients. Schwab’s ins3tu3onal brokerage services include access to a broad range of investment products, execu3on of securi3es transac3ons, and custody of client assets. The investment products available through Schwab include some to which STUDIO might not otherwise have access or that would require a significantly higher minimum ini3al investment by the Firm’s clients. Schwab’s services described in this paragraph generally benefit the client and the client’s accounts. Services That May Not Directly Benefit Clients. Schwab also makes other products and services available to STUDIO that benefit the Firm but may not directly benefit the client or the client’s accounts. These products and services assist STUDIO in managing and administering its client accounts. The products and services include investment research, both Schwab’s own and that of third par3es, though none of this research is dependent upon client securi3es transac3ons or associated fees or commissions. STUDIO may use this research to service all or a substan3al number of our clients’ accounts, including accounts not maintained at Schwab. In addi3on to investment research, Schwab also makes available the following: • access to client account data (such as duplicate trade confirma3ons and account statements) • trade execu3on and allocate aggregated trade orders for mul3ple client accounts • pricing and other market data • payment of the Firm’s fees from clients’ accounts • back-office func3ons, recordkeeping, and client repor3ng • educa3onal conferences and events • consul3ng on technology, compliance, legal, and business needs • publica3ons and conferences on prac3ce management and business succession • access to employee benefits providers, human capital consultants, and insurance providers Interest in Schwab’s Services The availability of these services from Schwab benefits STUDIO because the Firm does not have to produce or purchase them. This is a poten3al conflict of interest. Beyond that, these services are not con3ngent upon the Firm commiqng any specific amount of business to Schwab in trading commissions or assets in custody. The Firm’s recommenda3on is primarily supported by the scope, quality, and price of Schwab’s services (see “Recommenda3on of Custodians”) and not Schwab’s services that benefit only STUDIO. Best ExecuNon STUDIO will seek to obtain the most favorable execu3on – Best Execu3on (“Best Execu3on”) – under the prevailing circumstances when placing client orders. The Firm recognizes that the analysis of execution quality involves several qualitative and quantitative factors. These factors may include but are not limited to the following: ADV 2A V250313 | 03/13/2025 | Page 13 of 16  • financial strength and reputa3on • execu3on capabili3es • opera3onal capabili3es • efficiency of error resolu3on • block trading capabili3es • commissions and fees • accuracy of statements • electronic capabili3es • research tools • conflicts of interest Sob-Dollar Arrangements STUDIO does not have any arrangement or commitment to u3lize research, research-related products, or other services obtained from broker-dealers, or third par3es, on a sop-dollar-commission basis. Brokerage for Client Referrals STUDIO does not direct brokerage commissions in exchange for the referral of advisory clients. Directed Brokerage STUDIO does not accept clients’ instruc3ons for direc3ng their brokerage transac3ons to a par3cular broker-dealer. Order AggregaNon Orders for the same security entered on behalf of more than one client may be aggregated (i.e., blocked or bunched or batched or combined) to achieve a bePer price or other efficiencies. Subsequent orders for the same security entered during the same trading day may be aggregated with any previously unfilled orders. All clients par3cipa3ng in each aggregated order will receive the average price and a pro rata alloca3on of transacted shares. Trades conducted through the custodian will be subject to the commission rate nego3ated directly between the custodian and the client. In cases in which STUDIO is responsible for alloca3ng commissions to client accounts, such client accounts will pay a pro rata por3on of any aggregated commissions, subject to any minimum per-trade charges. ADV 2A V250313 | 03/13/2025 | Page 14 of 16  Item 13 – Review of Accounts Reviews STUDIO’s investment advisors review client pordolios at least quarterly to confirm they are consistent with the client’s investment objec3ves and risk profile. More frequent reviews may occur when STUDIO has new informa3on or perspec3ve on a client’s financial circumstances or a par3cular security, asset class, or other pordolio item. STUDIO’s investment advisors review clients’ wriPen investment guidelines and restric3ons at least annually to confirm that they are consistent with client pordolios. STUDIO will contact each client at least annually to aPempt to update contact informa3on, investment guidelines and restric3ons, risk tolerance, or other factors that may affect the client’s overall financial posi3on. Reports STUDIO provides quarterly reports to advisory clients regarding the accounts the firm manages, including the beginning-of-period market value, end-of-period market value, and performance data. The client’s independent custodian also provides regular wriPen account statements directly to the client. The custodian’s statement is the official record of the client’s account and supersedes any statements or reports created on behalf of the client by STUDIO. Item 14 – Client Referrals and Other Compensa@on STUDIO engages independent solicitors to provide client referrals. If a client is referred to STUDIO by a solicitor, this prac3ce is disclosed to the client in wri3ng by the solicitor, and STUDIO pays the solicitor out of its own funds. Specifically, STUDIO pays the solicitor a por3on of the fees earned for advising the referred client. The use of solicitors is strictly regulated under applicable federal and state law. STUDIO fully complies with Rule 206(4)-3 requirements under the Investment Advisers Act of 1940, as amended, and similar state rules, as applicable. STUDIO may receive client referrals from Zoe Financial, Inc. (“Zoe”) through its par3cipa3on in the Zoe Advisor Network (ZAN). Zoe is independent of and unaffiliated with STUDIO, and the two companies have no employee rela3onship. Zoe established the ZAN to refer individuals and other investors seeking fiduciary investment advisory services or financial-planning services to independent investment advisors. Zoe does not supervise STUDIO and has no responsibility for STUDIO’s management of client pordolios or STUDIO’s other advice or services. STUDIO pays Zoe an ongoing fee for each successful client referral. The fee paid to Zoe by STUDIO is a por3on of the fee that the client pays to STUDIO. Clients referred to STUDIO through the ZAN will not be charged fees greater than STUDIO’s standard fee schedule. For informa3on regarding addi3onal or other fees paid directly or indirectly to Zoe, please refer to the Zoe Financial Disclosure and Acknowledgement Form, provided to the client by Zoe. Please see Item 12 for a discussion on benefits received from Schwab Advisor Services™. ADV 2A V250313 | 03/13/2025 | Page 15 of 16  Item 15 – Custody Client securi3es and other funds are held with a qualified custodian, and clients choose which custodians will custody their assets. STUDIO does not maintain physical custody of client funds or securi3es. All client assets are held by qualified custodians that provide account statements on at least a quarterly basis. STUDIO has the authority to deduct fees directly from some client accounts. STUDIO will provide clients a quarterly statement containing account balances and holdings, and the custodian will provide clients with its own statement at least quarterly; STUDIO recommends that clients compare the two statements for consistency and no3fy the Firm if any statement is not received promptly or if any inconsistencies exist. Statements may be provided in electronic form. STUDIO also has the authority to transfer money from some client accounts, which cons3tutes standing authority (also known as a standing lePer of authoriza3on or SLOA). The authority to disburse money to a third-party on a client’s behalf pursuant to a SLOA cons3tutes custody. The SEC has provided seven condi3ons that relieve STUDIO of the custody rule’s annual surprise-examina3on requirement if sa3sfied. Accordingly, STUDIO will follow the safeguards and condi3ons specified by the SEC rather than undergo an annual independent verifica3on (i.e., a surprise accountant’s examina3on). Item 16 – Investment Discre@on Under STUDIO’s investment advisory agreement, which advisory clients must execute, clients grant a limited power of aPorney to the Firm with respect to trading ac3vity in their accounts. In these cases, STUDIO will exercise full discre3on as to the nature and type of securi3es to be purchased and sold and the number of securi3es for such transac3ons without preapproval by the client. Investment guidelines and restric3ons may be designated by the client as outlined in the investment advisory agreement. Item 17 – Vo@ng Client Securi@es STUDIO does not exercise authority with respect to vo3ng proxies on behalf of the Firm’s clients. In no event will STUDIO exercise authority with respect to vo3ng proxies on behalf of its clients. Custodians are responsible for delivering proxy materials to clients on a 3mely basis, according to their direct agreements with clients. Item 18 – Financial Informa@on Registered investment advisers are required to provide certain financial informa3on or disclosures about their firms. STUDIO has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. STUDIO does not take physical custody of client funds or securi3es, and the Firm does not require the prepayment of more than $1,200 in fees six or more months in advance. Therefore, STUDIO is not required to include a financial statement with this brochure. ADV 2A V250313 | 03/13/2025 | Page 16 of 16