Sundial Wealth LLC

FORM ADV PART 2A DISCLOSURE BROCHURE Sundial Wealth LLC Of�ice Address: th Avenue 904 SE 5 Tel: Delray Beach, FL 33483 Email: 561-302-4371 greg@sundialwealth.com Website: www.sundialwealth.com July 1, 2026 This brochure provides information about the quali�ications and business practices of Sundial Wealth LLC. Being registered as an investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 561- 302-4371. The information in this brochure has not been approved or veri�ied by the United States Securities and Exchange Commission, or by any state securities authority. Additional Information about Sundial Wealth LLC (CRD# 321900) is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. th On July 1, 2026, we moved to a new location: 904 SE 5 Avenue, Delray Beach, FL 33483. th On January 28 , 2026 we submitted our annual updating amendment �iling for �iscal year 2025. We have updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management of approximately $125,789,000. We did not have any non-discretionary assets under management. In addition, we amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Direct Indexing, Securities Backed Lines of Credit (SBLOCs), Political Risk and Arti�icial Intelligence ("AI") Risk. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm.  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes ............................................................................................................................... 2 Annual Update ............................................................................................................................................................................... 2 Item 3: Table of Contents ............................................................................................................................... 3 Full Brochure Available .............................................................................................................................................................. 2 Item 4: Advisory Business ............................................................................................................................. 1 Firm Description ........................................................................................................................................................................... 1 Types of Advisory Services ....................................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ........................................................................................... 5 Wrap Fee Programs ..................................................................................................................................................................... 5 Item 5: Fees and Compensation .................................................................................................................. 6 Client Assets under Management .......................................................................................................................................... 5 Method of Compensation and Fee Schedule...................................................................................................................... 6 Client Payment of Fees ............................................................................................................................................................... 8 Additional Client Fees Charged ............................................................................................................................................... 8 Prepayment of Client Fees ........................................................................................................................................................ 9 Item 6: Performance-Based Fees and Side-by-Side Management ................................................... 9 External Compensation for the Sale of Securities to Clients ....................................................................................... 9 Item 7: Types of Clients ................................................................................................................................ 10 Sharing of Capital Gains ............................................................................................................................................................. 9 Description .................................................................................................................................................................................... 10 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 11 Account Minimums .................................................................................................................................................................... 10 Methods of Analysis ................................................................................................................................................................... 11 Investment Philosophy ............................................................................................................................................................ 11 Item 9: Disciplinary Information .............................................................................................................. 24 Security Speci�ic Material Risks ............................................................................................................................................ 14 Criminal or Civil Actions .......................................................................................................................................................... 24 Administrative Enforcement Proceedings ....................................................................................................................... 24 Item 10: Other Financial Industry Activities and Af�iliations ........................................................ 24 Self- Regulatory Organization Enforcement Proceedings ......................................................................................... 24 Broker-Dealer or Representative Registration .............................................................................................................. 24 Futures or Commodity Registration ................................................................................................................................... 24 Material Relationships Maintained by Management Persons and Associated Con�licts of Interest ........ 25 Recommendations or Selections of Other Investment Advisors and Con�licts of Interest .......................... 26  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............................................................................................................................................................. 26 Code of Ethics Description ...................................................................................................................................................... 26 Investment Recommendations Involving a Material Financial Interest and Con�lict of Interest .............. 27 Advisory Firm Purchase of Same Securities Recommended to Clients and Con�licts of Interest.............. 28 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Item 12: Brokerage Practices ..................................................................................................................... 28 Transactions and Con�licts of Interest ............................................................................................................................... 28 Factors Used to Select Broker-Dealers for Client Transactions ............................................................................... 28 Item 13: Review of Accounts ...................................................................................................................... 30 Aggregating Securities Transactions for Client Accounts .......................................................................................... 29 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ........................................................................................................................................................................................................... 30 Review of Client Accounts on Non-Periodic Basis ........................................................................................................ 30 Item 14: Client Referrals and Other Compensation ........................................................................... 30 Content of Client Provided Reports and Frequency ..................................................................................................... 30 Item 15: Custody ............................................................................................................................................. 31 Advisory Firm Payments for Client Referrals ................................................................................................................. 31 Item 16: Investment Discretion ................................................................................................................ 32 Account Statements ................................................................................................................................................................... 31 Item 17: Voting Client Securities .............................................................................................................. 32 Discretionary Authority for Trading ................................................................................................................................... 32 Item 18: Financial Information .............................................................................................................. 333 Proxy Votes .................................................................................................................................................................................... 32 Balance Sheet ............................................................................................................................................................................ 333 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ..................................................................................................................................................................................... 333 Item 19: Requirements for State Registered Advisors ................................................................... 333 Bankruptcy Petitions during the Past Ten Years ........................................................................................................ 333 Brochure Supplement (Part 2B of Form ADV) ....................................................................................... 1 Principal Executive Of�icer – Paul Gregory Babij, CFA ................................................................................................... 2 Item 2 - Educational Background and Business Experience ...................................................................................... 2 Item 3 - Disciplinary Information .......................................................................................................................................... 2 Item 4 - Other Business Activities ......................................................................................................................................... 2 Item 5 - Additional Compensation ........................................................................................................................................ 3 Item 6 - Supervision .................................................................................................................................................................... 3 Item 7 - Requirements for State-Registered Advisors ................................................................................................... 3  Item 4: Advisory Business Firm Description Sundial Wealth LLC (“Sundial Wealth”, or “Advisor” or “we”), a Florida limited liability company, was founded in May 2022 to provide discretionary investment advisory and consulting services. The Advisor is wholly owned by Speculare B LLC, a Delaware Limited Liability Company and True North Capital, LLC, a Florida Limited Liability Company. Paul Gregory Babij is Sundial Wealth’s sole Managing Member and owns substantially all of the membership interests of Speculare B LLC. Andrew James Hill owns substantially all of the membership interests of True North Capital, LLC. Types of Advisory Services DISCRETIONARY INVESTMENT ADVISORY SERVICES: Sundial Wealth offers highly personalized investment management, �inancial planning and consulting services to individuals, ultra-high net worth individuals and family of�ices, both in their individual capacities and through trusts, retirement plans, business entities, and family limited partnerships. Clients can engage Sundial Wealth to manage all or a portion of their assets which may include all or a portion of the �inancial planning services discussed below. Sundial Wealth will generally have full discretion over client assets and will invest these assets in accordance with the �irm’s investment process. When deemed appropriate for the Client, Sundial Wealth may hire independent, third-party Sub-Advisors to manage all or a portion of the assets in the Client account, or to assist the �irm with trading and certain back-of�ice operations. Sundial Wealth has full discretion to hire and �ire Sub-Advisors as they deem suitable. In some cases, Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and Sundial Wealth and will execute trades on behalf of Sundial Wealth in Client accounts. Sundial Wealth will be responsible for the overall direct relationship with the Client. Sundial Wealth retains the authority to terminate the Sub-Advisor relationship at Sundial Wealth’s discretion. The Advisor is in no way af�iliated with these Sub-Advisors and does not receive any remuneration when selecting them to manage Client assets. Prior to advising or making investment allocations on behalf of a Client, Sundial Wealth will attempt to learn about the Client’s existing and expected �inancial needs and the anticipated �inancial needs for the next generations. Sundial Wealth will also review the Client’s current levels of taxation, risk tolerance, goals, investment experience, income and liquidity needs, age, investment time horizon, as well as the other investments that a Client may hold including non-investment assets such as businesses and real estate. This information forms the basis of a holistic evaluation that Sundial Wealth develops into a written Investment Policy Statement (“IPS”) that Sundial Wealth and the Client will enter into and update periodically. The IPS informs Sundial Wealth’s decisions with respect to investment selection, asset allocation, portfolio implementation and ongoing oversight. The Client will authorize - 1 -  Sundial Wealth discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Sundial Wealth may allocate Clients’ assets to mutual funds and exchange-traded funds (“ETFs”) that are passively and actively managed, individual debt and equity securities, U.S. Government securities, Municipal securities, options and warrants, money market funds and other cash instruments, separately managed accounts, structured products and derivatives, and other securities in accordance with their individual investment objectives. In addition, when consistent with the Clients’ investment objectives, Sundial Wealth may recommend that Clients who are “accredited investors” as de�ined under Rule 501 of the Securities Act of 1933 (“Securities Act”) or “quali�ied purchasers” as de�ined under Section 2(a)(51) of the Investment Company Act of 1940 (“Investment Company Act”), as amended, invest in strategies offered through private placement securities, which may include debt, equity, and/or pooled investment vehicles (e.g., hedge funds, private equity funds, venture capital funds or commercial real estate funds), Private Placement Securities valuations can lag a month or more and are received from the issuer’s third-party administrator. Sundial Wealth’s monthly fee calculation uses this data from the third-party administrator to calculate the monthly fee. For Clients that typically do not require the same level of investment complexity due to smaller account sizes or their current �inancial needs, Sundial Wealth may offer more limited model portfolios. These model portfolios utilize the same investment philosophy and asset allocation as our larger customized portfolios however, to help control costs, the mix of funds selected for inclusion within these model portfolios are usually more limited than those used in the ultra-high net worth and family of�ice portfolios. In order to provide these services at a cost-effective rate, the number of investments included may be narrower than those utilized in larger portfolios. Model portfolios typically will include a blend of mutual funds and exchange-traded funds (“ETFs”) that are passively and actively managed, individual debt and equity securities, U.S. Government securities, Municipal securities, options and warrants, money market funds and other cash instruments. Within those broad asset classes, Sundial Wealth may recommend additional sub-asset classes such as large, mid, and small cap as well as value and growth styles for implementation. The model portfolios risk, return, and liquidity posture are, in large part, a function of the asset classes that are to be included in the portfolio. the Client. Our Sundial Wealth will periodically rebalance the Client’s investment portfolio to conform to the asset allocation/asset class guidelines accepted by investment recommendations or model portfolios are not limited to any speci�ic product or service offered by a broker/dealer. From time to time, Clients may ask Sundial Wealth to dispose of certain investments that the Client invested in prior to engaging in Sundial Wealth’s services. Upon written direction, - 2 -  Sundial Wealth will dispose of the securities for the Client’s portfolio but without speci�ic directions from the Client, Sundial Wealth will not liquidate these holdings. In certain instances, Clients may hold investments purchased prior to engaging Sundial Wealth that they are unwilling to sell for reasons that may include tax implications, client driven investment considerations or sentiment. To the extent that the investments are held in a Sundial Wealth managed account, Sundial Wealth will monitor the holdings and may recommend when the Client should consider selling the security based on the Client’s IPS or other considerations (such as to offset tax gains). Sundial Wealth may suggest actions to be taken with respect to the security, but it will generally not have investment discretion and ultimately, the Client will have to direct or approve any transaction. Sundial Wealth will take the Client’s legacy holdings into account when making other discretionary investment decisions with respect to the Client’s portfolio. In certain instances, Sundial Wealth will apply its extensive quantitative and derivative experience to create customized hedging strategies or other sophisticated transactions to address speci�ic Client needs. SUB MANAGER OF AMBRUS SUNDIAL L.P. Sundial Wealth and Paul Gregory “Greg” Babij have been engaged to serve as a discretionary sub-manager with respect to a portion of Ambrus Sundial L.P.’s (the “Fund”) portfolio. The Fund is exempt from registration under the Investment Company Act of 1940 pursuant to Section 3(c)(1) of that Act. Investors in the Partnership must be “accredited investors” within the meaning of Rule 501 of Regulation D under the 1933 Act. Ambrus Sundial GP, LLC, the General Partner to the Fund is af�iliated with Sundial Wealth through common control. The Fund seeks to achieve its investment objective by employing a systematic equity momentum strategy and a tail risk strategy. Clients of Sundial Wealth may be solicited to invest in the Fund. Prior to investing in the Fund, clients should carefully review the Fund’s private placement memorandum and subscription agreement for detailed information about the Fund’s investment objectives, fees and expenses, risks, con�licts, valuation, and other important disclosures. FINANCIAL PLANNING AND CONSULTING SERVICES Sundial Wealth offers Clients a broad range of comprehensive �inancial planning, and consulting services. These services are tailored to the individual needs of the Client, but may include income planning, cash �low analysis and budgeting. Sundial Wealth’s concierge services include assistance with the essential lifestyle demands of ultra-high net worth Clients, such as coordination of accounting, commercial banking, estate planning, and assistance with travel planning. Prior to engaging Sundial Wealth to provide �inancial planning or consulting services, Clients are required to enter into a written agreement with Sundial Wealth setting forth the terms and conditions of the engagement. Sundial Wealth provides �inancial planning services pursuant to a �inancial planning agreement. Such services may include a comprehensive evaluation of the Client’s current and future �inancial state and will be provided by using currently known facts and variables to - 3 -  predict future cash �lows, asset values and withdrawal plans. Sundial Wealth will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing �inancial plans. • Financial Position Typical topics reviewed in a �inancial plan may include but are not limited to: : Understanding of a Client's current �inancial situation. Sources of evaluation include income, expenses, assets, liabilities, etc. • Financial Goals : Based on a Client’s clearly de�ined �inancial goals, including funding education for the children, purchasing real estate, starting a business, a retirement timeline, or leaving a legacy. Financial goals should be quanti�ied and set to milestones for tracking. • Personal Net Worth Statement : A snapshot of assets and liabilities serves as a benchmark for measuring progress towards �inancial goals. • Cash Flow Analysis : An income and spending plan determines how much can be set • Investment Planning aside for debt repayment, savings and investing each month. e.g : Determining the most suitable way to structure investments to meet �inancial goals, and determine the appropriate account type ( ., joint tenants, IRA, Roth IRA, etc.). Investment planning may include a customized asset allocation strategy based on speci�ic investment objectives and a risk pro�ile. • Retirement Planning : Assessing retirement needs to help the Client determine how much to accumulate, as well as distribution strategies designed to create a source of income during retirement years. • Comprehensive Insurance and Risk Management Plan : Identify all risk exposures and provide the necessary coverage to protect the family and its assets against �inancial loss. The risk management plan includes a full review of life and disability insurance, personal liability coverage, property and casualty coverage, and catastrophic coverage. • Estate Planning : Reviewing the Client's cash needs at death; income needs of surviving dependents; and estate planning goals. Sundial Wealth gathers information through interviews and review of documents provided by the Client, including questionnaires. Information gathered includes the Client's current �inancial status, future goals, investment objectives, risk tolerance and family circumstances. Typical �inancial planning services include one or more of each of the aforementioned service components. A �inancial plan may require the services of a specialist such as an insurance - 4 -  specialist, attorney, or tax accountant. We may recommend third-party service providers, but the Client is under no obligation to use any service provider recommended by us. The Advisor is in no way af�iliated with these third-party service providers and does not receive any remuneration when recommending them to Clients. Financial plans are based on the Client's �inancial situation at the time we present the �inancial plan to the Client, and on the information provided to us. The Client must promptly notify us if his/her �inancial situation, goals, objectives or needs change. Certain assumptions may be made with respect to interest rates, in�lation rates, and use of past trends and performance of the market and economy. Past performance is not indicative of future performance. We cannot offer any guarantees or promises that the Client's �inancial goals will be met. Unless the Client has engaged Sundial Wealth to provide discretionary investment advisory services pursuant to a �inancial plan, the Client is under no obligation to act upon Sundial Wealth’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through Sundial Wealth. Financial plans will generally be completed and delivered inside of thirty (30) days contingent upon timely delivery of all required documentation. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client �iles. Investment strategies are created that re�lect the stated goals and objectives. Clients may impose reasonable restrictions and guidelines on investing in certain securities, types of securities or industry sectors. We expect all such restrictions to be timely communicated to us. Client restrictions and guidelines may negatively affect investment performance. We also expect Clients to inform us of any changes to their �inancial circumstances, investment objectives or risk tolerance, or of any modi�ications or restrictions that should be imposed on the management of the Client's assets. If Sundial Wealth determines that the restrictions imposed by the Client impede its ability to manage the Client’s account or otherwise provide services to the Client, Sundial will terminate its engagement by the Client. A Client’s engagement, including the advisory agreement may not be assigned without written Client consent. Wrap Fee Programs Sundial Wealth does not sponsor any wrap fee programs. Client Assets under Management As of December 31, 2025, Sundial Wealth has $125,789,000 in discretionary client assets under management and $0 in non-discretionary assets. - 5 -  Item 5: Fees and Compensation Method of Compensation and Fee Schedule DIECRETIONARY INVESTMENT ADVISORY FEES Sundial Wealth offers discretionary investment management services to advisory Clients. Sundial Wealth typically charges an annual investment advisory fee based on the total assets under management as follows: Assets Under Management Up to $500,000 $500,0001 to $1,000,000 $1,000,001 to $10,000,000 Over $10,000,000 Annual Fee 2.00% 1.50% 1.25% 1.00% Monthly Fee .1667% .1250% .1041% .0833% This is a �lat fee/breakpoint fee schedule, the entire portfolio is charged the same asset management fee. For example, a Client with $750,000 under management would pay $11,250 on an annual basis. $750,000 x 1.50% = $11,250. If a Client elects to engage Sundial Wealth for a single strategy that is not designed to be a total portfolio solution, but instead be a complimentary investment strategy to the Client’s portfolio managed elsewhere, Sundial Wealth charges a �lat fee regardless of investment amount, and the management fee ranges from 0.50% to 1.50% annually depending on the speci�ic strategy chosen by the Client. Sundial Wealth will consider all accounts managed by the Advisor that belong to certain familial relations of the Client, which is typically referred to as “householding”. Speci�ically, the total assets under management of a Client’s account(s) will be aggregated with the total assets under management of all managed accounts belonging to a Client’s spouse, custodial accounts for minor children who reside at the same address of Client, and any trust assets where the trustees, trustors and current bene�iciaries all reside at the same address as Client (collectively, a “household”). Clients are required to notify Sundial Wealth of any such “household” relationships. Sundial Wealth reserves the right to include additional related accounts at the �irm’s discretion. Sundial Wealth’s investment advisory fee is agreed upon individually with each Client. The annual fee is negotiable at the sole discretion of the Advisor. Client fees will take into consideration several factors, including aggregate assets under management, anticipated future additional assets, the complexity of the services to be provided, and the overall relationship with the Advisor. Fees are billed monthly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous month. If margin is utilized, the fees will be billed based on the net asset value of the account. All investment advisory fees paid to the Advisor are re�lected on the client’s monthly (or quarterly) brokerage statements, which are independently prepared and provided to the client by the custodian. Clients are strongly - 6 -  advised to verify the accuracy of the fee, as their custodian will not determine whether the fee is properly calculated. Clients may terminate their account within �ive (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial �ive (5) business days, the agreement may be terminated by Sundial Wealth with thirty (30) days written notice to Client and by the Client at any time with written notice to Sundial Wealth. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to Sundial Wealth. Client shall be given thirty (30) days prior written notice of any increase in fees, not including account balance based fee changes related to transitioning between tiers on the above fee schedule. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Sundial Wealth’s annual fees do not include custody, brokerage, and other third-party fees such as deferred sales charges, transfer taxes, wire transfer, electronic fund fees, brokerage commissions, transaction fees, and other related costs and expenses that may be incurred by a client. All securities held in accounts managed by Sundial Wealth will be independently valued by the Client’s custodian, or other independent third-party source. Sundial Wealth may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios. Sundial Wealth will enter into Sub-Advisor agreements with other registered investment advisor �irms. When using Sub-Advisors, the Client will pay additional fees depending on the account value, investment style and types of securities used. The Sub- Advisors fee will be disclosed to and acknowledged by the client in Sundial Wealth’s Investment Advisory Agreement. The Sub-Advisor’s fees and the custodian’s fees are not included in the fees charged by Sundial Wealth. Sub-Advisor directly deducts their portion of the fee separately from Sundial Wealth. – Private Fund Investments For private fund investments, the Client shall be required to complete the applicable private placement and/or account opening documents to establish these investments. The Advisor will debit its fee for providing investment advisory services with respect to these relationships directly from an account designated by the Client held at the custodian. For private fund investments, the Advisor may not receive updated investment valuations prior to its fee billing calculation. In such instances, the Advisor will bill the annual rate as de�ined above based on the most recent valuation available for the calculation of investment advisory fees. A client could invest in a mutual fund, ETF, or private fund directly, without our services. In that case, the client would not receive the services provided by the Advisor which are designed, among other things, to assist the client in determining which investments are most appropriate to each client's �inancial condition and objectives. Accordingly, the client should review all fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. - 7 -  FINANCIAL PLANNING AND CONSULTING FEES Sundial Wealth charges an hourly fee for �inancial planning. An estimate of overall costs will be provided to the Client prior to engaging for these services. If it is determined that the estimate is materially incorrect, we will provide the Client with an updated estimate as soon as reasonably determined. Services are completed and delivered inside of thirty (30) days contingent upon timely delivery of all required documentation. Either party may terminate the �inancial planning agreement, at any time, by providing advance written notice to the other party. Client may cancel within �ive (5) business days of signing Agreement with no obligation and without penalty. If the Client cancels after �ive (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to Sundial Wealth. All refunds will be pro-rata based on the amount of time already spent by Sundial Wealth. HOURLY FEES Financial Planning Services are offered based on an hourly fee of $500 per hour. Fees for �inancial plans are: Due upon delivery of the completed plan. • Clients can choose to pay for �inancial planning via the following methods: • Deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. • Check – to be remitted by Client to Sundial Wealth • Deducted from a non-quali�ied account managed by Sundial Wealth Electronic Payment via ACH Client Payment of Fees • Fees for investment management services are: • Deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. Check – to be remitted by Client to Sundial Wealth Fees for �inancial plans will be • billed: • Deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. • Check – to be remitted by Client to Sundial Wealth • Deducted from a non-quali�ied account managed by Sundial Wealth Additional Client Fees Charged Electronic Payment via ACH Custodians may charge transaction fees other related costs on the purchases or sales of mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money market funds and exchange-traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. Margin interest may also apply for Client electing to utilize margin on their account(s). Sundial Wealth does not receive any compensation from these - 8 -  fees. All of these fees are in addition to the management fee you pay to Sundial Wealth. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Client Fees Sundial Wealth does not require any prepayment of fees. External Compensation for the Sale of Securities to Clients Sundial Wealth does not receive any external compensation for the sale of securities, commodities, insurance or other investment products to Clients, nor do any of the investment advisor representatives of Sundial Wealth. IRA Rollover Considerations ___________________________________________________________________________________________________________ As a normal extension of �inancial advice, we provide education or recommendations related to the rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique �inancial needs and retirement plans. The complexity of these choices may lead an investor to seek assistance from us. An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and expenses will increase to the investor as a result because the above-described fees will apply to assets rolled over to an IRA and outlined ongoing services will be extended to these assets. We are �iduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also �iduciaries 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. We have to act in your best interests and not put our interest ahead of yours. At the same time, the way we make money creates some con�licts with your interests. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Performance-based fees (aka incentive allocation) are fees based on a share of capital gains on or capital appreciation of the client’s assets. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. - 9 -  Sundial Wealth, as sub-manager of Ambrus Sundial L.P. (The Fund)(described in more detail in Item 10 below) may receive a portion of the performance-based fees collected from investors in the Fund by the General Partner to the Fund. Associated persons of our �irm, in their various capacities at the Fund, will directly or indirectly receive a portion of those fees. Prior to investing in the Fund, clients should carefully review the Fund’s private placement memorandum and subscription agreement for detailed information about the Fund’s fees and expenses (including performance-based fees), con�licts, and other important disclosures. In some cases, the combined management fee and incentive allocation charged to the Fund will be in excess of 3.00% of assets under management in the Fund. Such fees are in excess of industry standards and similar advisory services may be available for lower fees. However, clients should note that a fee in excess of 3.00% will only be charged in cases where the Fund has signi�icant investment returns. We charge performance-based fees only to “Quali�ied Clients” who have a net worth greater than $2,200,000, or those for whom we manage a minimum of $1,100,000, from the beginning of our agreement for services. Performance-based fees create an incentive for our �irm to make investments that are riskier or more speculative than would be the case absent a performance fee arrangement. Performance-based fees may also create an incentive for our �irm to overvalue investments, which lack a market quotation. In order to address such con�lict, we have adopted policies and procedures that require our �irm to "fairly value" any investments, which do not have a readily ascertainable value. Item 7: Types of Clients Description Sundial Wealth generally provides investment advice to individuals, high and ultra-high net individuals, family of�ices, trusts, corporations or business entities. Client worth relationships vary in scope and length of service. Account Minimums Sundial Wealth requires a minimum of $100,000 to open an account. Sundial Wealth generally requires a minimum account size of $1,000,000, and that the Client quali�ies as an Accredited Investor if a customized portfolio is desired. Sundial reserves the right to diverge from these general account minimums where the engagement warrants it. Investors in the Fund must qualify as “Accredited Investors” under Regulation D of the Securities Act of 1933 or meet the investor suitability standards set forth in the private placement memorandum. The �irm may, on a temporary basis or otherwise, in its sole and absolute discretion, accept lesser amounts and raise the minimum investment requirement in the future. Investors in the Fund should refer to the funds offering documents for further information about minimum investment requirements in the funds. - 10 -  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Investment Philosophy Our investment philosophy regarding portfolio and risk management is built on a goals based approach. This philosophy differs from the more common approach of maximizing risk in order to maximize return in comparison to an arti�icial benchmark. In a goals-based framework, the relative return to a benchmark is an inadequate measure of success, primarily because it is possible to create returns in excess of the benchmark and still not meet a Client’s goal. Sundial Wealth instead constructs dynamic all-weather portfolios which attempt to achieve positive returns regardless of the macroeconomic regime, such as positive or negative growth, or an in�lationary or de�lationary environment. This objective is achieved through the use of multiple asset classes and strategies along with the expectation that noncorrelated return streams will result in long-term capital appreciation and limited drawdowns. Portfolios typically will contain both tactical (active) and passive exposures to equity securities and indices, �ixed income securities and other uncorrelated yield generating investments, real assets and other in�lation bene�itting investments, investments that employ trend following and momentum-based strategies, and investments that have a long volatility or positive convexity bias. Portfolios are also rebalanced opportunistically. The tactical equity strategies utilized are generally rules-based, and actively reduce exposure when market conditions are less favorable. This increases the probability of smaller overall portfolio drawdowns and is expected to lower portfolio volatility in times of sustained equity market declines. This also allows for portfolio returns to compound from a higher base when markets recover, and conditions become more favorable. Method of Analysis Sundial Wealth utilizes a proprietary combination of fundamental, technical, quantitative and macroeconomic methods of analysis, and also includes an examination of the correlation between investments and to major equity and �ixed income markets. Sundial Wealth may speci�ically use one or more of the following methods of analysis for evaluating different types of investments: Fundamental analysis involves an assessment of the fundamental �inancial value of an asset. Sundial Wealth generally analyzes the �inancial condition, expected cash �lows, uncertainty and risks to those cash �lows. Fundamental analysis does not attempt to anticipate market movements. The primary risk in using fundamental analysis is in assessing the uncertainty of the �inancial conditions and cash �lows of various assets. Technical analysis attempts to analyze past market movements and apply that analysis to the present to recognize recurring patterns of investor behavior and potentially predict future - 11 -  price movement. Generally, it is used to predict trends within the security during speci�ied time frames. Technical analysis generally involves the use of charts, price and volume data and/or mathematics-based metrics to identify market patterns and trends that may be premised on investor sentiment rather than the fundamentals of an asset. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Sundial Wealth will be able to accurately predict such a reoccurrence. Quantitative Analysis attempts to use models and statistics to analyze historical price and volume data, performance data, standard deviation and related risk metrics, how the investment performs relative to the overall market, earnings data, options market data, and other related data. Although we measure and back test with historical data, we are forward- looking in our views, incorporating macro trends and correlations to construct the recommended portfolios. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Quantitative analysis does not necessarily factor in all variables. Macroeconomic analysis involves the assessment of market conditions at a macroeconomic level (entire market/economy, sectors, and asset classes), rather than the overall fundamental analysis of the health of a particular asset. Macroeconomic analysis requires many inputs and a risk is that not every variable may be factored in. Another risk to macroeconomic analysis includes that there is no guarantee that the current macroeconomic in market conditions anticipated based on similar previous regime will result macroeconomic regimes. attempts to identify an appropriate combination of investments Asset Allocation Analysis suitable to the Client’s goals and risk tolerance. Asset allocation includes attempting to classify the macroeconomic regimes (growth, recession, in�lation, de�lation) that each investment may perform well or may perform poorly. Asset allocation may also include an attempt to classify each investment as having either a short volatility or a long volatility bias. A risk of asset allocation analysis is that investments may not behave in the future similar to have they behaved in past similar macro-economic regimes. Another risk is that the ratio of investments will change over time due to market movements and, if not corrected, will no longer be fully aligned with the Client's goals. . Mutual Fund and/or ETF Analysis attempts to look at the experience and track record of the manager of the mutual fund or exchange traded fund (ETF) in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. This analysis also looks at the underlying assets in a mutual fund or ETF in an attempt to determine if there is signi�icant overlap in the underlying investments held in another fund[s] in the Client's portfolio Private Placement Investments analysis includes evaluation and due diligence of the portfolio manager’s investment framework and experience, performance history, liquidity of investment, current and future cash �low potential, and associated risks. - 12 -  Sundial Wealth also performs qualitative research and reviews research material prepared by others, as well as corporate �ilings, corporate rating services, and a variety of �inancial publications. Sundial Wealth may employ outside vendors or utilize third-party software, as needed, to assist in formulating investment recommendations to Clients. In some cases, we utilize trade signals published by an unaf�iliated signal providers. In such cases, we will follow the signal provider’s recommendations. However, Sundial Wealth reservices the right to modify or override the signal provider’s recommendations. Sundial Wealth will conduct an initial and ongoing due diligence reviews and will maintain records of such reviews in the �irm’s compliance �iles. Investment Strategy incorporate the Sundial Wealth’s investment approach seeks to offer institutional-quality portfolio construction and risk management to all Clients of the �irm. In developing Client portfolios, Sundial Wealth seeks to latest portfolio management research complemented with extensive internal research. Sundial Wealth may incorporate the following strategies in managing Client portfolios. Additionally, investment strategies and advice may vary depending upon each Client's speci�ic �inancial situation. As such, we determine investments and allocations based upon the Client's prede�ined objectives, risk tolerance, time horizon, �inancial information, liquidity needs, and other various suitability factors. The Client's direction, restrictions, and guidelines may affect the composition of their portfolio. Long-term Purchases . This strategy purchases securities with the idea of holding them in the Client's account for a year or longer. Typically, Sundial Wealth employs this strategy when we want exposure to a particular asset class over time, regardless of the current projection for this class. Short-term Purchases . When utilizing this strategy, we purchase securities with the idea of selling them when they reach their price targets, their stoploss targets or there is a realization of an anticipated catalyst. We do this to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. Margin Transactions . If granted authority to do so, we may purchase stocks for Client portfolios with money borrowed from your brokerage account. This allows you to purchase more stock than you would be able to with your available cash and allows us to purchase stock without selling other holdings. Margin trading may be used if it is suitable given a Client's stated investment objectives and tolerance for risk. Trading in Options and Warrants . We may use options as an investment strategy. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such - 13 -  as a share of stock) at a speci�ic price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative because it derives its value from an underlying asset. We may also utilize structured notes, closed end funds or mutual funds that utilize options strategies. The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a speci�ic period of time. We will buy a call if we anticipate that the stock price will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a speci�ic period of time. We will buy a put if we want to position for a material decline in the price of a security before the option expires. We may use options to speculate on the possibility of a sharp price swing. We may also use options to "hedge" a purchase of the underlying security; in other words, we will use an option purchase to limit the potential upside and downside of a security we have purchased for your portfolio. We also may utilize a "covered call" strategy, in which we sell a call option on a security you own. In this strategy, you receive a fee also called a premium for making the option available, and the counterparty purchasing the option has the right to buy the security from you at an agreed upon price. We may also trade combinations of options in a combined strategy which effectively provides for an exposure to price movements within a speci�ied range. Option writing is not a core part of Sundial Wealth’s overall investment strategy, but we may use this strategy very occasionally when given authority and we determine that it is suitable given a Client's stated investment objectives and tolerance for risk. Tax Loss Harvesting. Sundial Wealth will engage in tax loss harvesting when applicable. Sundial Wealth will attempt to capture capital losses when they occur which can subsequently be used to offset other realized capital gains or be inventoried to offset future gains. This strategy will be utilized when Sundial Wealth determines that the tax bene�its of such a strategy exceed related transaction costs and risk. Portfolio Rebalancing. Sundial Wealth will periodically rebalance the Client’s investment portfolio to conform to the asset allocation/asset class guidelines accepted by the Client. The collective use of the above investment strategies are designed not to maximize portfolio returns in the near term, but instead to compound gains over a long time without signi�icant capital impairments along the way. Our investment recommendations or model portfolios are not limited to any speci�ic product or service offered by a broker/dealer. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Security Speci�ic Material Risks Investing involves a risk of loss. Clients should be prepared to bear investment losses, including the loss of the original principal amount invested. Clients should never presume that future performance of any speci�ic investment or investment strategy will be pro�itable. Further, there may be varying degrees of risk depending on different types of investments. Clients should know that all investments carry a certain degree of risk ranging from the variability of market values to the possibility of permanent loss of capital. Risks to capital - 14 -  include, but may not be limited to, changes in the economy, market volatility, company results, industry sectors, accounting standards and changes in interest rates. Investments are generally subject to risks inherent in governmental actions, exchange rates, in�lation, de�lation, and �iscal and monetary policies. Market risks also include changes in market sentiment in general and styles of investing. Diversi�ication will not fully protect an investor from these risks and �luctuations. Although portfolios seek to minimize the risk of large drawdowns, asset allocation and investment decisions may not achieve this goal in all cases. There is no guarantee a portfolio will meet a target return or an investment objective. Investors face the following investment risks and should discuss these risks with Sundial Asset Allocation Risk: Wealth: The selection of and weighting of asset classes and/or underlying funds can cause it to underperform other funds with a similar investment objective. Concentration Risk: Some Clients may choose to have their investment portfolios heavily weighted in one security, one industry or industry sector, one geographic location, one investment manager, or one type of investment instrument (equities versus �ixed income) and will experience greater risk and volatility in their portfolios. Clients who have diversi�ied portfolios, generally incur less volatility and therefore less �luctuation in portfolio value than those who have concentrated holdings. Concentrated holdings offer the potential for higher gain, but also offer the potential for signi�icant loss. Market Risk: Either the stock markets as a whole, or the value of an individual company, goes down resulting in a decrease in the value of Client investments. Stocks are susceptible to general stock market �luctuations and to volatility increases and subsequent decreases in value as market con�idence in and perceptions of their issuers change. Common stock (or its equivalent) is generally exposed to greater risk than preferred stocks and debt obligations of an issuer. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. Equity Securities Risk: Equity securities (common, convertible preferred stocks and other securities whose values are tied to the price of stocks, such as rights, warrants and convertible debt securities) could decline in value if the issuer's �inancial condition declines or in response to overall market and economic conditions. A fund's principal market segment(s) – such as large cap, mid cap or small cap stocks, or growth or value stocks – can underperform other market segments or the equity markets as a whole. Investments in smaller companies and mid-size companies can involve greater risk and price volatility than investments in larger, more mature companies. Exchange Traded Funds Risk: Investing in ETFs involves risk. Speci�ically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Also, ETFs require more frequent portfolio reporting by regulators and are thereby more susceptible to actions by activist funds that could have a negative impact on - 15 -  the price of the ETF. Certain ETFs employ leverage, which creates additional volatility and price risk depending on the amount of leverage utilized, the collateral, and the liquidity of the supporting collateral. Further, the use of leverage (i.e., employing the use of margin) generally results in additional interest costs to the ETF. Market volatility and low liquidity can severely and negatively impact the price of the ETF’s underlying portfolio securities, thereby causing signi�icant price �luctuations of the ETF. Mutual Fund Securities Risk: Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the amount of individual company diversi�ication, the type and amount of industry diversi�ication, and the type and amount of sector diversi�ication within speci�ic industries. In addition, mutual funds tend to be tax inef�icient and therefore investors may pay capital gains taxes on fund investments while not having yet sold the fund. Fixed-Income and Municipal Securities Risk: Fixed-income securities are subject to interest rate risk and credit quality risk. The market value of �ixed-income securities generally declines when interest rates rise, and an issuer of �ixed-income securities could default on its payment obligations. Municipal securities carry different risks than those of other �ixed income securities described above. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax-free at the federal level but can be taxable in individual states other than the state in which both the investor and municipal issuer are domiciled. Foreign Securities Risk: Funds in which Clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, periods of illiquidity, country risks (political, diplomatic, regional con�licts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. Liquid Alternatives Fund Risk: Certain alternative funds may employ use of derivatives, options, futures and/or short sales. Use of derivatives, options or futures by a fund may be for purposes of gaining exposure to a particular asset group, for hedging purposes or for leverage purposes. The use of derivatives, options and futures exposes the funds to additional risks and transaction costs. In addition, if the fund uses leverage through activities such as engaging in short sales or purchasing derivative instruments, there are additional risks, including the fund having the risk that losses may exceed the net assets of the fund. The net - 16 -  asset value of a fund while employing leverage will be more volatile and sensitive to market movements. Clients should carefully review the fund’s prospectus or offering memorandum to more fully understand the risk of funds employing the use of derivatives, options, futures and/or short sales. Investments in these funds should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. Options Trading Risks: The risks involved with trading options are that they are highly time sensitive investments. Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying asset. This leverage can compound gains or losses. The risks of covered call writing include the potential for the market to rise sharply, resulting in the underlying asset being called away and the account will no longer hold that asset. When purchasing options there is the risk that the entire premium paid for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (“writing”) options, the risk of loss can be much greater if the options are written uncovered (“naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. Derivatives Risk: Funds in a Client’s portfolio may use derivative instruments. The value of these derivative instruments derives from the value of an underlying asset, currency or index. Investments by a fund in such underlying funds may involve the risk that the value of the underlying fund’s derivatives may rise or fall more rapidly than other investments, and the risk that an underlying fund may lose more than the amount that it invested in the derivative instrument in the �irst place. Derivative instruments also involve the risk that other parties to the derivative contract may fail to meet their obligations, which could cause losses. Private Placement Risks: A private placement (non-public offering) is an illiquid security sold to quali�ied investors and are not publicly traded nor registered with the Securities and Private placements generally carry a higher degree of risk due to Exchange Commission. illiquidity. Most securities that are acquired in a private placement will be restricted securities and must be held for an extended amount of time and therefore cannot be sold easily. Private placements can have higher volatility, may have delays in tax reporting, and may have higher fees than ETFs and mutual funds. The range of risks are dependent on the nature of the partnership and are disclosed in the offering documents. In�lation Risk: When any type of in�lation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of in�lation. Currency Risk: Overseas investments are subject to �luctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. - 17 -  Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to �ixed income securities. Liquidity Risks: Generally, assets are more liquid if many investors are interested in a standardized product making the product relatively easy to convert into cash. Specialized investments may have reduced liquidity. Trading Risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. Trading on Margin: In a cash account, the risk is limited to the amount of money that has been invested. In a margin account, risk includes the amount of money invested plus the amount that has been loaned. As market conditions �luctuate, the value of marginable securities will also �luctuate, causing a change in the overall account balance and debt ratio. As a result, if the value of the securities held in a margin account depreciates, the Client will be required to deposit additional cash or make full payment of the margin loan to bring account back up to maintenance levels. Clients who cannot comply with such a margin call may be sold out or bought in by the brokerage �irm. Risks Associated with Investing in Inverse and Leveraged Funds: Leveraged mutual funds and ETFs generally seek to deliver multiples of the daily performance of the index or benchmark that they track. Inverse mutual funds and ETFs generally seek to deliver the opposite of the daily performance of the index or benchmark that they track. Inverse funds often are marketed as a way for investors to pro�it from, or at least hedge their exposure to, downward-moving markets. Some Inverse funds are both inverse and leveraged, meaning that they seek a return that is a multiple of the inverse performance of the underlying index. To accomplish their objectives, leveraged and inverse funds use a range of investment strategies, including swaps, futures contracts, and other derivative instruments. Leveraged, inverse, and leveraged inverse funds are more volatile and riskier than traditional funds due to their exposure to leverage and derivatives, particularly total return swaps and futures. At times, we will recommend leveraged and/or inversed funds, which may amplify gains and losses. Most leveraged funds are typically designed to achieve their desired exposure on a daily (in a few cases, monthly) basis, and reset their leverage daily. A "single day" is measured from the time the leveraged fund calculates its net asset value ("NAV") to the time of the leveraged fund's next NAV calculation. The return of the leveraged fund for periods longer than a single day will be the result of each day's returns compounded over the period. Due to the effect of this mathematical compounding, their performance over longer periods of time can differ signi�icantly from the performance (or inverse performance) of their underlying index or benchmark during the same period of time. For periods longer than a single day, the leveraged fund will lose money when the level of the Index is �lat, and the leveraged fund may lose money even if the level of the Index rises. Longer holding periods, higher index volatility, and greater leverage all exacerbate the impact of compounding on an investor's returns. During periods of higher Index volatility, the volatility of the Index may affect the leveraged - 18 -  fund's return as much as or more than the return of the Index itself. Therefore, holding leveraged, inverse, and leveraged inverse funds for longer periods of time increases their risk due to the effects of compounding and the inherent dif�iculty in market timing. Leveraged funds are riskier than similarly benchmarked funds that do not use leverage. Non-traditional funds are highly volatile and not suitable for all investors. They provide the potential for signi�icant losses. Risks Associated with Investing in Buffer ETFs: Buffer ETFs are also known as de�ined outcome ETFs since the ETF is designed to offer downside protection for a speci�ied period of time. These ETFs are modeled after options-based structured notes, but are generally cheaper, and offer more liquidity. Buffer ETFs are designed to safeguard against market downturns by employing complex options strategies. Buffer ETFs typically charge higher management fees that are considerably more than the index funds whose performance they attempt to track. Additionally, because buffer funds own options, they do not receive dividends from their equity holdings. Both factors result in the underperformance of the Buffer ETF compared to the index they attempt to track. Clients should carefully read the prospectus for a buffer ETF to fully understand the cost structures, risks, and features of these complex products. Structured Notes: Below are some speci�ic risks related to the structured notes • Complexity recommended by our �irm: • Market risk : Structured notes are complex �inancial instruments. Clients should understand the reference asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s) or index(es) in calculating the note’s performance. This payoff calculation may include leverage multiplied by the performance of the reference asset or index, protection from losses should the reference asset or index produce negative returns, and/or fees. Structured notes may have complicated payoff structures that can make it dif�icult for clients to accurately assess their value, risk and potential for growth through the term of the structured note. Determining the performance of each note can be complex and this calculation can vary signi�icantly from note to note depending on the structure. Notes can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or inverse-leveraged, which may result in larger returns or losses. Clients should carefully read the prospectus for a structured note to fully understand how the payoff on a note will be calculated and discuss these issues with our �irm. • . Some structured notes provide for the repayment of principal at maturity, which is often referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing �inancial institution. Many structured notes do not offer this feature. For structured notes that do not offer principal protection, the performance of the linked asset or index may cause clients to lose some, or all, of their principal. Depending on the nature of the linked asset or index, the market risk of the structured note may include changes in equity or commodity prices, changes in Issuance price and note value interest rates or foreign exchange rates, and/or market volatility. : The price of a structured note at issuance will likely be higher than the fair value of the structured note on the date of issuance. Issuers now generally disclose an estimated value of the structured note on the cover page of the offering prospectus, allowing investors to gauge the difference between the issuer’s - 19 -  • Liquidity estimated value of the note and the issuance price. The estimated value of the notes is likely lower than the issuance price of the note to investors because issuers include the costs for selling, structuring, and/or hedging the exposure on the note in the initial price of their notes. After issuance, structured notes may not be re-sold on a daily basis and thus may be dif�icult to value given their complexity. : The ability to trade or sell structured notes in a secondary market is often • Credit risk very limited, as structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on securities exchanges. As a result, the only potential buyer for a structured note may be the issuing �inancial institution’s broker-dealer af�iliate or the broker-dealer distributor of the structured note. In addition, issuers often speci�ically disclaim their intention to repurchase or make markets in the notes they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date or risk selling the note at a discount to its value at the time of sale. : Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is obligated to make payments on the notes as promised. These promises, including any principal protection, are only as good as the �inancial health of the structured note issuer. If the structured note issuer defaults on these obligations, investors may lose some, or all, of the principal amount they invested in the structured notes as well as any other payments that may be due on the structured notes. Environmental, Social, and Governance Investment Criteria Risk: If a portfolio is subject to certain environmental, social and governance (ESG) investment criteria it may avoid purchasing certain securities for ESG reasons when it is otherwise economically advantageous to purchase those securities, or may sell certain securities for ESG reasons when it is otherwise economically advantageous to hold those securities. In general, the application of the portfolio’s ESG investment criteria may affect the portfolio’s exposure to certain issuers, industries, sectors and geographic areas, which may affect the �inancial performance of the portfolio, positively or negatively, depending on whether these issuers, industries, sectors or geographic areas are in or out of favor. An adviser can vary materially from other advisers with respect to its methodology for constructing ESG portfolios or screens, including with respect to the factors and data that it collects and evaluates as part of its process. As a result, an adviser’s ESG portfolio or screen may materially differ from or contradict the conclusions reached by other ESG advisers concerning the same issuers. Further, ESG criteria are dependent on data and are subject to the risk that such data reported by issuers or received from third-party sources may be subjective, or it may be objective in principle but not veri�ied or reliable. Management Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a speci�ic asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. Location and Infrastructure Risk Sundial Wealth and its key personnel are physically located in one building in Delray Beach, Florida. Damage to or loss of the building and/or the key personnel, whether through �ire, terrorist action, earthquake, or some other catastrophic - 20 -  event, could adversely affect Sundial Wealth’s operations and the investment returns. A serious impairment to the infrastructure of the building, such as an extended loss of power or communications, or a prolonged restriction of physical access to the building by governmental authorities, also could adversely affect Sundial Wealth’s operations and the investment returns. Similar location and infrastructure risks may apply to Sundial Wealth’s trading partners and key suppliers of its research, trading, communications, and information technology infrastructure. Sundial Wealth has a disaster recovery procedure which it believes will mitigate or eliminate these risks but there can be no assurance the procedure will work in all cases and address all possible situations. Custodian and Counterparty Risks : All investors are subject to the risk of the inability of their custodians, brokers and dealers and counterparties to safeguard assets or to perform with respect to transactions, whether due to bankruptcy, insolvency, or other causes. There is a risk that any of such institutions could become bankrupt or insolvent. The bankruptcy or insolvency of any such institutions may result in an investor losing all or a portion of their assets held with such institutions or the termination of any outstanding transactions. In addition, brokers and dealers, custodians and counterparties may use sub-custodians and Pandemic Risk: disclaim responsibility for any losses which may result therefrom. Pandemic risk can result in market volatility and may have long-term effects many nations including the United States, individual companies, and the market(s). Pandemics may cause extreme volatility and disruption in both the U.S. and global markets causing uncertainty and risks to economic growth, etc. Sundial Wealth cannot predict the effects of signi�icant future events on the global economy and securities markets. A similar disruption of the �inancial markets could impact interest rates, credit risk, in�lation, and other factors. Cyber Risk: Investment advisers must rely in part on digital and network technologies (“cyber networks”) to maintain substantial computerized data about activities for Client accounts and otherwise conduct their businesses. Such cyber networks might in some circumstances be subject to a variety of possible cybersecurity incidents or similar events that could potentially result in the inadvertent disclosure of con�idential computerized data or Client data to unintended parties, or the intentional misappropriation or destruction of data by malicious hackers seeking to compromise sensitive information, corrupt data, or cause operational disruption. Cyber-attacks might potentially be carried out by persons using techniques that could range from efforts to electronically circumvent network security or overwhelm websites to intelligence gathering and social engineering functions aimed at obtaining information necessary to gain access. Sundial Wealth maintains policies and procedures on information technology security, it has certain technical and physical safeguards intended to protect the con�identiality of its internal data and takes other reasonable precautions to limit the potential for cybersecurity incidents, and to protect data from inadvertent disclosure or wrongful misappropriation or destruction. Nevertheless, despite reasonable precautions, the risk remains that cybersecurity incidents could potentially occur, and such incidents, in some circumstances, might result in unauthorized access to sensitive information about Sundial Wealth or its Clients or their investors, and/or - 21 -  cause damage to Client accounts or Sundial Wealth’s activities for Clients or their investors. Sundial Wealth will seek to promptly notify affected Clients and investors of any known cybersecurity incident that may pose a substantial risk of exposing con�idential personal data about such Clients or investors to unintended parties. Sub-Advisor Risk: The risks associated with utilizing Sub-Advisors include manager risk where the Sub-Advisor fails to execute the stated investment strategy and business risk where the Sub-Advisor has �inancial or regulatory problems. There are also additional risks associated with a Sub-Advisor’s portfolio which is disclosed in the Sub-Advisor’s Form ADV part 2. Additionally, 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 Sundial Wealth. Private Fund Risks: Private investment funds are not registered with the Securities and Exchange Commission and may not be registered with any other regulatory authority. Accordingly, they are not subject to certain regulatory restrictions and oversight to which other issuers are subject. There may be little public information available about their investments and performance. Moreover, as sales of shares of private investment companies are generally restricted to certain quali�ied purchasers, it could be dif�icult for a client to sell its shares of a private investment company at an advantageous price and time. Since shares of private investment companies are not publicly traded, it may be dif�icult to establish a fair value for the client’s investment in these companies. Private investment funds often engage in leveraging and other speculative investment practices that may increase the risk of investment loss. A Private investment fund's performance can be volatile. An investor could lose all or a substantial portion of their investment. There may be no secondary market for the investor's interest in the fund. Private investment funds can be highly illiquid and there may be restrictions on transferring interests in the fund. Private investment funds are not required to provide periodic pricing or valuation information to investors. Private investment funds may have complex tax structures. There may be delays in distributing important tax information. Private investment funds are not subject to the same regulatory requirements as mutual funds. Private investment funds often charge high fees. The fund's high fees and expenses may offset the fund's trading pro�its. Additional information about the risks associated with a private investment fund is available in the fund’s private placement memorandum and other subscription documents. Direct Indexing: Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing can provide a more tax ef�icient means of investing, and allows for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential bene�its of direct indexing, however, will not necessarily be realized if a client does not take advantage of tax planning or impose account restrictions, such as account level security or sector-based - 22 -  restrictions or customizations based on speci�ic tax, Environmental, Social, and Governance or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of the account and the number of securities in the index the account seeks to replicate also limit the ability of the account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index and can cause a portfolio to underperform the index, including as a result of customization. Securities Backed Lines of Credit (SBLOCs): SBLOCs are non-purpose loans where you pledge assets in your account as collateral in return for a loan. The loan proceeds can be used for purposes other than to purchase or trade securities. Depending on your objectives, we can help you apply for a SBLOC. This can be a strategic alternative to liquidating assets to pay for unexpected expenses, a business opportunity, or a personal goal, any of which could trigger capital gain taxes. While we do not receive a fee for arranging these loans, our assistance in this process presents a con�lict of interest, as we have an incentive for you to maintain these assets in your account instead of liquidating them, as liquidation could decrease the asset-based fees that we earn for managing your account. To address this con�lict, we only make recommendations to obtain such loans when we believe obtaining a SBLOC is in the best interests of clients. Clients should note that they retain the ultimate decision to obtain such loans. The following are some of the primary risks associated with obtaining a SBLOC: • • • • • Interest rate payments on the principal balance of the loan are not �ixed and may increase; If the value of the securities pledged as collateral decrease, you will be liable for any de�iciency; The lender can force the sale or liquidation of securities held as collateral without contacting you in advance to meet collateral requirements and you are not entitled to choose which securities are liquidated or sold; You are only entitled to draw on the line to the extent there is credit availability; and There may be additional risks when money funds or similar investments may produce less interest income or other yield than the interest you are paying on the loan. We urge our clients to carefully read all disclosures and agreements prior to entering into an SBLOC or non-purpose loan. While we can assist in the application process, we are not involved in the approval process. Political Risk: Each administration presents its own set of policy risks that could impact investors. One of the policy tools that an administration can implement is the imposition of tariffs, or the threats thereof. The scope, implementation, and duration of tariffs can create uncertainty domestically and globally. Industries that rely on imported raw material or that have heavily integrated cross-border manufacturing practices may be most impacted by the imposition of tariffs. However, it is challenging to predict the impact of actual and/or threatened tariffs and impossible to predict future policy decisions. When tariffs are imposed, there is also a higher probability that retaliatory tariffs could be imposed, which could further - 23 -  impact industries and products. Tariffs in general can also permanently alter global supply chains and have far-reaching indirect impacts. Tariffs can hurt economic growth and add to in�lation, which can lead to rising interest rates. Arti�icial Intelligence ("AI") Risk: We may rely on programs and systems that utilize AI, machine learning, probabilistic modeling, and other data science technologies ("AI Tools") when delivering our services. AI Tools are also used to record and transcribe client meetings. Clients should note that AI Tools are highly complex, and are known to have been �lawed, hallucinate, re�lect biases included in the data on which such tools are trained, be of poor quality, or be otherwise harmful. AI Tools present Cybersecurity Risk. The U.S. and global legal and regulatory environment relating to the use of AI Tools is uncertain and rapidly evolving, and could require changes in the �irm’s implementation of AI Tools and increase compliance costs and the risk of non-compliance. Further, the �irm may rely on AI Tools developed by third parties, and the �irm has limited control over the accuracy and completeness of such AI Tools. Clients who do not want us to record their meetings have the option to opt out at the time of the meeting. Item 9: Disciplinary Information Criminal or Civil Actions Sundial Wealth and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings Sundial Wealth and its management have not been involved in administrative enforcement proceedings. Self- Regulatory Organization Enforcement Proceedings Sundial Wealth and its management have not been involved in any self-regulatory organizational enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of Sundial Wealth or the integrity of its management. Item 10: Other Financial Industry Activities and Af�iliations Broker-Dealer or Representative Registration Sundial Wealth is not registered as a broker-dealer and no af�iliated representatives of Sundial Wealth are registered representatives of a broker-dealer. Futures or Commodity Registration Neither Sundial Wealth nor its af�iliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. - 24 -  Material Relationships Maintained by Management Persons and Associated Con�licts of Interest Several actual and potential con�licts of interest exist as a result of Mr. Babij’s and Mr. Hill’s involvement in certain outside business activities. For starters, the time and resources devoted by Mr. Babij and Mr. Hill to these activities means that less time and resources would be spent on managing the business of Sundial Wealth and in Mr. Babij’s case, rendering advisory services to Sundial Wealth’s clients. Paul Gregory Babij and Andrew James Hill each own 50% of Sundial Real Estate Partners, LLC, which is a separate entity that may enter into joint venture agreements with Commercial Real Estate Private Equity Sponsors, or participate in commercial real estate direct syndications. Paul Gregory Babij has an active real estate license; however, Mr. Babij is not currently providing these services. Since Mr. Babij is not currently providing these services, this is not a con�lict of interest. Speculare B LLC, an entity owned by Paul Gregory Babij, and True North Capital, LLC, an entity owned by Andrew James Hill, have a majority ownership interest in Sundial Advisory Group, LLC an accounting practice based in Fort Pierce, Florida. Mr. Babij and Mr. Hill and other associates of Sundial Wealth may recommend Sundial Advisory Group, LLC to their clients, and conversely Sundial Advisory Group, LLC may be recommended to advisory clients of Sundial Wealth. Clients are instructed that the fees paid to our �irm for investment advisory services are separate and distinct from fees paid to Sundial Advisory Group, LLC for accounting and tax services. Clients to whom we offer advisory services are informed that they are under no obligation to use Sundial Advisory Group, LLC for accounting and tax services and may use the accounting �irm of their choice. Paul Gregory Babij and Andrew James Hill each own 50% of Sundial Founders, LLC, the Managing Member of Sundial Holdings I, LLC, a private placement that has been organized as a Delaware limited liability company. Sundial Holdings I, LLC has made an investment in a Florida based land surveying services company. Certain clients of Sundial Wealth have made investments in Sundial Holdings I, LLC. Please see Item 11 below for additional information about this activity. Prior to making in investment, clients should carefully review Sundial Holdings I, LLC Limited Liability Company Agreement and subscription agreement for detailed information about Sundial Holdings I, LLC’s investment objectives, fees and expenses, risks, con�licts, and other important disclosures. AMBRUS SUNDIAL L.P. Paul Gregory Babij and Andrew James Hill are Principals of Ambrus Sundial GP, LLC a Delaware limited liability company (the “General Partner”) that acts as the general partner of Ambrus Sundial L.P. (the “Fund”). Ambrus Capital Management, LLC, a Delaware limited liability company, is the investment manager (the “Investment Manager”) of the Fund. The Investment Manager has entered into a sub-management agreement with Sundial Wealth. Pursuant to the Sub-Management Agreement, the Investment Manager has engaged Sundial Wealth to serve as a discretionary sub-manager with respect to a portion of the Partnership’s - 25 -  portfolio. Mr. Babij has been appointed as a portfolio manager alongside Sundial Wealth of certain portions of the Fund’s portfolio. Clients of Sundial Wealth who meet certain quali�ication thresholds may be solicited to invest in the Fund. Prior to investing in the Fund, clients should carefully review the Fund’s private placement memorandum and subscription agreement for detailed information about the Fund’s investment objectives, fees and expenses, risks, con�licts, valuation, and other important disclosures. The practices and af�iliations listed in this item represent various con�licts of interest because they give our �irm and our associates an incentive to recommend products or services based on the compensation received rather than based on the client’s needs. These con�licts are mitigated by disclosures, procedures and the �irm’s �iduciary obligation to place the best interest of the Client �irst. Clients are not required to purchase any products or services. Clients have the option to purchase these products through another consultant of their choosing. Recommendations or Selections of Other Investment Advisors and Con�licts of Interest Sundial Wealth may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and Sundial Wealth. Sub-Advisors execute all trades on behalf of Sundial Wealth in Client accounts. Sundial Wealth will be responsible for the overall direct relationship with the Client. Sundial Wealth retains the authority to terminate the Sub- Advisor relationship at Sundial Wealth’s discretion. In addition to the authority granted to Sundial Wealth, Clients will grant Sundial Wealth full discretionary authority and authorizes Sundial Wealth to select and appoint one or more independent investment advisors (“Advisors”) to provide investment advisory services to Client without prior consultation with or the prior consent of Client. Such Advisors shall have all of the same authority relating to the management of Client’s investment accounts as is granted to Sundial Wealth in the Agreement. In addition, at Sundial Wealth’s discretion, Sundial Wealth may grant such Advisors full authority to further delegate such discretionary investment authority to additional Advisors. Sundial Wealth ensures that before selecting other advisors for Client that the other advisors are properly licensed or registered as an investment advisor. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The af�iliated persons (af�iliated persons independent contractors) of Sundial Wealth have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of Sundial Wealth af�iliated persons and addresses con�licts that may arise. The Code de�ines acceptable behavior for af�iliated - 26 -  persons of Sundial Wealth. The Code re�lects Sundial Wealth and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when af�iliated persons buy or sell securities for their personal accounts and how to mitigate any con�lict of interest with our Clients. We do not allow any af�iliated persons to use non-public material information for their personal pro�it or to use internal research for their personal bene�it in con�lict with the bene�it to our Clients. Sundial Wealth’s policy prohibits any person from acting upon or otherwise misusing nonpublic or inside information. No advisory representative or other af�iliated person, of�icer or director of Sundial Wealth may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. Sundial Wealth’s Code is based on the guiding principle that the interests of the Client are our top priority. Sundial Wealth’s of�icers, directors, advisors, and other af�iliated persons have a �iduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and con�idence of our Clients. When a con�lict arises, it is our obligation to put the Client’s interests over the interests of either af�iliated persons or the company. The Code applies to “Access” persons. “Access” persons are af�iliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. Sundial Wealth will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Con�lict of Interest Ambrus Sundial L.P. Clients of Sundial Wealth may be invested in or solicited to invest in Ambrus Sundial L.P. (the “Fund”). Clients should note that the recommendation of investments in the Fund creates a con�lict of interest because our �irm, our af�iliates, and our Associated Persons have an incentive to recommend the af�iliated Fund over funds that have no relationship with Sundial Wealth, to generate additional revenue for the �irm and for themselves. Sundial Wealth and its associates address this con�lict by upholding their �iduciary duties of always acting in our clients’ best interests. Clients should note that investors in the Fund are charged a management fee and may be charged an incentive fee as described in Item 6 above. In cases where the client receives portfolio management services from Sundial Wealth and, as part of this service, is advised to invest in the Fund, Sundial Wealth will waive its portfolio management services fee on the portion of assets invested in the Fund. However, the �irm will receive a fee for sub- management services provided to the Fund along with a portion of the incentive allocation received by the General Partner. - 27 -  Sundial Holdings I, LLC Certain clients of Sundial Wealth have invested in Sundial Holdings I, LLC. Clients should note that the recommendation of investments in our af�iliated private placement creates a con�lict of interest because our �irm, our af�iliates, and our Associated Persons have an incentive to recommend the af�iliated private placement over investments that have no relationship with Sundial Wealth, to generate additional revenue for themselves. Sundial Wealth and its associates address this con�lict by upholding their �iduciary duties of always acting in our clients’ best interests. Further, Sundial Wealth will waive its portfolio management services fee on the portion of client assets invested in its af�iliated private placement. We urge our clients to carefully review each Fund’s private placement memorandum and subscription agreement for detailed information about the Funds’ fees and expenses, incentive allocation, and other important disclosures. Advisory Firm Purchase of Same Securities Recommended to Clients and Con�licts of Interest Sundial Wealth and its af�iliated persons may buy or sell securities that are also held by Clients. In order to mitigate con�licts of interest such as trading ahead of Client transactions, af�iliated persons are required to disclose all reportable securities transactions as well as provide Sundial Wealth with copies of their brokerage statements. The Chief Compliance Of�icer of Sundial Wealth is Paul Gregory Babij. He reviews all trades of the af�iliated persons each quarter. The personal trading reviews ensure that the personal trading of af�iliated persons does not affect the markets and that Clients of the �irm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Con�licts of Interest Af�iliated persons of Sundial Wealth may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate con�licts of interest such as front running, af�iliated persons are required to disclose all reportable securities transactions as well as provide Sundial Wealth with copies of their brokerage statements. The Chief Compliance Of�icer of Sundial Wealth is Paul Gregory Babij. He reviews all trades of the af�iliated persons each quarter. The personal trading reviews ensure that the personal trading of af�iliated persons does not affect the markets and that Clients of the �irm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions Sundial Wealth requires that clients engaging it for investment management services open brokerage accounts at Charles Schwab and Company (“Schwab”) Sundial selected Schwab - 28 -  • Research and Other Soft Dollar Bene�its because it considers it to provide appropriate “best execution” for Clients, meaning they have an obligation to obtain the most favorable terms when purchasing and selling securities for a Client. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the ef�iciency with which the transaction is affected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the �inancial strength and stability of the broker. Because of the complexity of maintaining relationships with multiple broker- dealers, it is not feasible for Sundial Wealth to maintain more than one custodial preference at this time. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by Sundial Wealth. Sundial Wealth does not receive any portion of the trading fees or other charges assessed by Schwab. The Securities and Exchange Commission de�ines soft dollar practices as arrangement under which products or services other than execution services are obtained by Sundial Wealth from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. Although Sundial Wealth has no formal soft dollar arrangements, Sundial Wealth may receive products, research and/or other services from custodians or broker-dealers connected to Client transactions or “soft dollar bene�its”. Such products and services include security analysis reports, daily market summaries, weekly and monthly market reports, etc. As permitted by Section 28(e) of the Securities Exchange Act of 1934, Sundial Wealth receives economic bene�its as a result of commissions generated from securities transactions by the custodian or broker-dealer from the accounts of Sundial Wealth. Sundial Wealth cannot ensure that a particular Client will bene�it from soft dollars or the Client’s transactions paid for the soft dollar bene�its. Sundial Wealth does not seek to proportionately allocate bene�its to Client accounts to any soft dollar bene�its generated by the accounts. • Brokerage for Client Referrals A con�lict of interest exists when Sundial Wealth receives soft dollars which could result in higher commissions charged to Clients. This con�lict is mitigated by the fact that Sundial Wealth has a �iduciary responsibility to act in the best interest of its Clients and the services received are bene�icial to all Clients. • Directed Brokerage Sundial Wealth does not receive Client referrals from any custodian or third party in exchange for using that broker-dealer or third party. Sundial Wealth does not allow directed brokerage accounts. Aggregating Securities Transactions for Client Accounts Sundial Wealth is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of Sundial Wealth. All Clients participating in the aggregated order - 29 -  shall receive an average share price with all other transaction costs shared on a prorated basis. If aggregation if not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-lot trades, etc.) an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by the Chief Compliance Of�icer of Sundial Wealth, Paul Gregory Babij. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target allocations of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Financial plans generated are updated as requested by the Client and pursuant to a new or amended agreement, Sundial Wealth suggests updating at least annually. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Content of Client Provided Reports and Frequency Clients receive written account statements no less than monthly for managed accounts. Account statements are issued by Sundial Wealth’s custodian. Client receives a summary of transactions in their accounts from the custodian. Sundial Wealth provides additional reports to Clients along with a Billing summary report. Both of these items are created by Advyzon’s reporting and billing software platform Item 14: Client Referrals and Other Compensation Custodial Bene�its As described in Item 12 above, we receive economic bene�its from our custodial broker dealer in the form of support products and services they make available to us and other independent investment advisors whose clients maintain their accounts at these custodial broker dealers. The availability of custodial products and services is not dependent upon or based on the speci�ic investment advice we provide our clients, such as buying or selling speci�ic securities or speci�ic types of securities for our clients. The products and services provided by the custodial broker dealer, how they bene�it us, and the related con�licts of interest are described above (see Item 12 – Brokerage Practices). - 30 -  Economic Bene�its Received from Vendors and Product Sponsors Occasionally, our �irm and our Associated Persons will receive additional compensation from vendors. Compensation could include such items as gifts; an occasional dinner or ticket to a sporting event; reimbursement in connection with educational meetings with an Associated Person, reimbursement for consulting services, client workshops, or events; or marketing events or advertising initiatives, including services for identifying prospective clients. Receipt of additional economic bene�its presents a con�lict of interest because our �irm and Associated Persons have an incentive to recommend and use vendors based on the additional economic bene�its obtained rather than solely on the client’s needs. We address this con�lict of interest by recommending vendors that we, in good faith, believe are appropriate for the client’s particular needs. Clients are under no obligation contractually or otherwise, to use any of the vendors recommended by us. Advisory Firm Payments for Client Referrals Sundial Wealth does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at quali�ied custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to carefully compare the account statements received directly from their custodians to any documentation or reports prepared by Sundial Wealth. Sundial Wealth is deemed to have custody because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of Sundial Wealth, pursuant to authority granted by the Client. Where Sundial Wealth is authorized or permitted to deduct fees directly from the account by the custodian: • • • Sundial Wealth will provide the Client with an invoice concurrent to instructing the custodian to deduct the fee stating the amount of the fee, the formula used to calculate the fee, the amount of assets under management the fee is based on and the time period covered by the fee; Sundial Wealth will obtain written authorization signed by the Client allowing the fees to be deducted; and The Client will receive monthly or quarterly statements directly from the custodian or from Advyzon’s reporting and billing software platform which disclose the fees deducted. Sundial Wealth is deemed to have custody of client assets invested in Ambrus Sundial L.P. and Sundial Holdings I, LLC because its related persons serve as the General Partner or Managing Member, and therefore have access to Ambrus Sundial L.P.’s and Sundial Holdings I, LLC’s funds and securities. As required by relevant state and SEC rules and in conformity with industry practice, Ambrus Sundial L.P.’s and Sundial Holdings I, LLC are subject to an audit at least annually and distribute their audited �inancial statements prepared in accordance with - 31 -  generally accepted accounting principles to all respective investors. Also, as required, the audits are conducted by an independent public accountant that is registered with the Public Company Accounting Oversight Board in accordance with its rules. Sundial Wealth will be deemed to have custody of client funds in cases where clients of Sundial Advisory Group, LLC give our related accounting �irm access to their account for bill payment purposes. These accounts will be held with a bank, broker-dealer, or other independent, quali�ied custodian. We will comply with all requirements set forth under relevant state and SEC rules, including the requirement to engage an independent certi�ied public accountant to verify by actual examination, the client funds and securities of which we have custody, on at least an annual basis. Item 16: Investment Discretion Discretionary Authority for Trading Sundial Wealth requires discretionary authority to manage securities accounts on behalf of Clients. Sundial Wealth has the authority to determine, without obtaining speci�ic Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Client will authorize Sundial Wealth discretionary authority stated within the Investment Advisory Agreement. Sundial Wealth allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. These restrictions must be provided to Sundial Wealth in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. Sundial Wealth does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes Sundial Wealth does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. is requested, Sundial Wealth will provide When assistance on voting proxies recommendations to the Client. If a con�lict of interest exists, it will be disclosed to the Client. If the Client requires assistance or has questions, they can reach out to the investment advisor representatives of the �irm at the contact information on the cover page of this document. - 32 -  Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided to Clients because Sundial Wealth does not serve as a custodian for Client funds or securities and Sundial Wealth does not require prepayment of fees of more than $1,200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Sundial Wealth has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years Sundial Wealth has not had any bankruptcy petitions in the last ten years. Item 19: Requirements for State Registered Advisors This section is not applicable because our �irm is SEC registered. - 33 -  Item 1 Cover Page SUPERVISED PERSON BROCHURE F O R M A D V P A R T 2 B Paul Gregory Babij, CFA Sundial Wealth LLC Of�ice Address: th Avenue 904 SE 5 Tel: Delray Beach, FL 33483 561-302-4371 Email: greg@sundialwealth.com Website: www.sundialwealth.com July 1, 2026 This brochure supplement provides information about Paul Gregory Babij and supplements the Sundial Wealth LLC brochure. You should have received a copy of that brochure. Please contact Paul Gregory Babij if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional Information about Paul Gregory Babij (CRD#2655181) is available on the SEC’s website at www.adviserinfo.sec.gov. Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure - 1 -  Principal Executive Of�icer – Paul Gregory Babij, CFA • Year of birth: 1972 Item 2 - Educational Background and Business Experience • Educational Background: Bucknell University; Bachelor of Science – Civil Engineering; 1995 • Business Experience: • Sundial Wealth LLC.; Managing Member/Investment Advisor Representative; 05/2022- Present • Sundial Holdings, LLC & Sundial Real Estate Partners, LLC; Managing Member, 01/2022 - Present • Principal - Ambrus Sundial GP, LLC; 02/2025 - Present • Ascent Systematic Advisors LLC; Consultant; 04/2022 – 12/2022 • Paul Gregory Babij, Sole Proprietor; Real Estate Agent; 06/2021 - Present • Ascent Systematic Advisors LLC; CEO/CCO; 09/2021-04/2022 Bunkport Capital LLC; CEO; 01/2018-08/2021 Paul Gregory Babij Professional Certi�ications: has earned certi�ications and credentials that are required to be explained in further detail. • Chartered Financial Analyst (CFA): Chartered Financial Analysts designation is awarded by the CFA Institute. CFA certi�ication requirements: • • • • Hold a bachelor’s degree from an accredited institution or have equivalent educational or work experience. Successful completion of all three exam levels of the CFA Program. Have 48 months of acceptable professional work experience in the investment decision- making process. Ful�ill society requirements, which vary by society. Unless you are upgrading from af�iliate membership, all societies require two sponsor statements as part of each application; these are submitted online by your sponsors. Agree to adhere to and sign the Member's Agreement, a Professional Conduct Statement, and any additional documentation requested by CFA Institute. Item 3 - Disciplinary Information Mr. Babij does not have any material disciplinary events to report in this section. Item 4 - Other Business Activities Paul Gregory Babij is an owner in Sundial Real Estate Partners, LLC, which is a separate entity that may enter into joint venture agreements with Commercial Real Estate Private Equity Sponsors, or participate in commercial real estate direct syndications. - 2 -  Paul Gregory Babij has an active real estate license, however Mr. Babij is not currently providing these services. Since Mr. Babij is not currently providing these services, this is not a con�lict of interest. Paul Gregory Babij is a 50% owner of Sundial Founders, LLC, the Managing Member of Sundial Holdings I, LLC, a private placement that has been organized as a Delaware limited liability company. Sundial Holdings I, LLC has made an investment in a Florida based land surveying services company. Certain clients of Sundial Wealth have made investments in Sundial Holdings I, LLC. Please see Item 11 below for additional information about this activity. Prior to making in investment, clients should carefully review Sundial Holdings I, LLC Limited Liability Company Agreement and subscription agreement for detailed information about Sundial Holdings I, LLC’s investment objectives, fees and expenses, risks, con�licts, and other important disclosures. Paul Gregory Babij is a Principal of Ambrus Sundial GP, LLC a Delaware limited liability company (the “General Partner”) that acts as the general partner of Ambrus Sundial L.P. (the “Fund”). Clients of Sundial Wealth may be solicited to invest in the Fund. Prior to investing in the Fund, clients should carefully review the Fund’s private placement memorandum and subscription agreement for detailed information about the Fund’s investment objectives, fees and expenses, risks, con�licts, valuation, and other important disclosures. The practices and af�iliations listed in this item represent various con�licts of interest because it gives our �irm and our associates an incentive to recommend products or services based on the compensation received rather than based on the client’s needs. These con�licts are mitigated by disclosures, procedures and the �irm’s �iduciary obligation to place the best interest of the Client �irst. Clients are not required to purchase any products or services. Clients have the option to purchase these products through another consultant of their choosing. Item 5 - Additional Compensation Apart from the receipt of compensation for the activities listed in Item 4 above, Mr. Babij does not receive any additional compensation for performing advisory services. Item 6 - Supervision Since Mr. Babij is the sole owner and investment adviser representative of Sundial Wealth and is solely responsible for all supervision and formulation and monitoring of investment advice offered to Clients. He will adhere to the policies and procedures as described in the �irm’s Compliance Manual. He can be reached at greg@sundialwealth.com or 561-302-4371. Item 7 - Requirements for State-Registered Advisors This section is not applicable because our �irm is SEC registered. - 3 -