Overview

Headquarters
Saratoga Springs, NY
Total Firm Assets
$272 million
Average High-Net-Worth Client Portfolio Size
$2.5 million

Fee Structure

Primary Fee Schedule (TWS ADV2A FIRM BROCHURE)

MinMaxMarginal Fee Rate
$0 $250,000 1.50%
$250,001 $500,000 1.25%
$500,001 $1,000,000 1.05%
$1,000,001 $2,000,000 0.85%
$2,000,001 $5,000,000 0.65%
$5,000,001 and above 0.55%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $12,125 1.21%
$5 million $40,125 0.80%
$10 million $67,625 0.68%
$50 million $287,625 0.58%
$100 million $562,625 0.56%

Clients

High-Net-Worth Share of Firm Assets
63.73%
Number of High-Net-Worth Clients
70
Total Client Accounts
744
Discretionary Accounts
744

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection, Educational Seminars

Regulatory Filings

SEC CRD Number
340266

Primary Brochure: TWS ADV2A FIRM BROCHURE (2026-06-05)

View Document Text
FORM ADV PART 2A: FIRM BROCHURE FORM ADV PART 2A: FIRM BROCHURE 110 Henry Street, Saratoga Springs, NY 12866 (518) 583-4800 www.tailoredwealthsolutions.com Date of Disclosure Brochure: June 5, 2026 This disclosure brochure provides information about the qualifications and business practices Tailored Wealth Solutions, LLC (“TWS”) (also referred to as we and us throughout this disclosure brochure). If you have any questions about the contents of this brochure, please contact us at (518) 583-4800 or mike@tailoredwealthsolutions.com. The information in this disclosure brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Tailored Wealth Solutions is also available on the Internet at www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for Tailored Wealth Solutions or our firm’s CRD number 340266. *Registration as an investment adviser does not imply a certain level of skill or training. SIMPLIFY. ORGANIZE. MAXIMIZE. ITEM 2 - MATERIAL CHANGES ITEM 2 - MATERIAL CHANGES We will ensure that you receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after our firm’s fiscal year ends. Our firm’s fiscal year ends on December 31, so you will receive the summary of material changes no later than April 30 each year. At that time, we will also offer or provide a copy of the most current disclosure brochure. We may also provide other ongoing disclosure information about material changes as necessary. Since our initial filing, we have made changes to Item 5 – Fees and Compensation of this brochure to update our billing calculation method, frequency, and fee schedule. ITEM 2 - MATERIAL CHANGES ITEM 3 - TABLE OF CONTENTS ITEM 3 - TABLE OF CONTENTS Item 1 – Cover Page........................................................................................................................................................... Item 2 – Material Changes........................................................................................................................................... Item 3 – Table of Contents........................................................................................................................................... Item 4 – Advisory Business........................................................................................................................................... Introduction.................................................................................................................................................................... Description of Advisory Services...................................................................................................................... Retirement Plan Rollover Recommendations........................................................................................ Limits Advice to Certain Types of Investments..................................................................................... Tailor Advisory Services to Individual Needs of Clients................................................................... Client Assets Managed by Tailored Wealth Solutions..................................................................... Item 5 – Fees and Compensation.......................................................................................................................... Item 6 – Performance-Based Fees and Side-By-Side Management........................................... Item 7 – Types of Clients................................................................................................................................................ Minimum Investment Amounts Required................................................................................................. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss......................................... Methods of Analysis.................................................................................................................................................. Investment Strategies............................................................................................................................................. Risk of Loss...................................................................................................................................................................... Item 9 – Disciplinary Information............................................................................................................................ Item 10 – Other Financial Industry Activities and Affiliations................................................................ Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading.......... Code of Ethics Summary...................................................................................................................................... Affiliate and Employee Personal Securities Transactions Disclosure.................................... Item 12 – Brokerage Practices.................................................................................................................................... Block Trading Policy.................................................................................................................................................. Item 13 - Review Of Accounts..................................................................................................................................... Account Reviews and Reviewers..................................................................................................................... Statements and Reports. ..................................................................................................................................... Item 14 – Client Referrals and Other Compensation.................................................................................. Item 15 – Custody................................................................................................................................................................ Item 16 – Investment Discretion. .............................................................................................................................. Item 17 – Voting Client Securities............................................................................................................................. Item 18 – Financial Information................................................................................................................................. ITEM 3 - TABLE OF CONTENTS1234458910101115151516161718222326262627292929303031313232 ITEM 4 - ADVISORY BUSINESS ITEM 4 - ADVISORY BUSINESS Tailored Wealth Solutions, LLC is a New York limited liability company founded in August 2020, with its principal place of business in New York. Michael R. Testa, CRPS® is the principal owner of Tailored Wealth Solutions and has focused his practice on customized financial planning & wealth management. Mr. Testa is the Founder and primary control person of Tailored Wealth Solutions. Full details of the education and business background of Mr. Testa are provided in his Form ADV Part 2B Brochure Supplement. Tailored Wealth Solutions filed its initial application with the SEC to become registered as an investment adviser in January 2026. Michael R. Testa, CRPS® As Founder and CEO of Tailored Wealth Solutions, Michael has spent more than 20 years helping individuals, families, and business owners simplify complex decisions, organize their financial lives, and maximize what matters most: long-term wealth, security, and peace of mind. His work is grounded in retirement income planning, tax-aware strategy, and thoughtful planning for business owners. Michael holds FINRA Series 7, 66, and 31 licenses, along with Life, Accident, and Health Insurance licenses, and is a Chartered Retirement Plans Specialist™ (CRPS®). These credentials support a planning-first approach that is both comprehensive and practical. *Chartered Retirement Plans Specialist™ and CRPS® are registered service marks of the College for Financial Planning. Introduction The investment advisory services of Tailored Wealth Solutions are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of Tailored Wealth Solutions (referred to as your investment adviser representative “IAR” or “Advisor” throughout this brochure). The firm focuses on offering individualized wealth management services which may include but are not limited to asset management, investment advice, financial planning, tax planning or estate planning. ITEM 4 - ADVISORY BUSINESS Description of Advisory Services The following are descriptions of the primary advisory services of Tailored Wealth Solutions. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and Tailored Wealth Solutions before we can provide you with the services described below. Asset Management Services We offer discretionary asset management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for asset management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information at the beginning of our advisory relationship. Based on this information, we develop a personalized investment strategy, which may include a written investment policy statement or an asset allocation plan. We then construct and manage the portfolio to align with the agreed-upon targets and investment approach. We provide continuous and customized investment advice based on each client’s unique financial situation, goals, and preferences. We may also invest your assets according to one or more model portfolios developed by an unaffiliated investment adviser firm. Once we select a model portfolio, we will monitor your portfolio's performance on an ongoing basis and will adjust the portfolio as required by changes in market conditions and in your financial circumstances. If you participate in our discretionary asset management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account and the commissions to be paid to brokerage firms without your approval prior to each transaction. We will also have discretion to place all or a portion of your assets with sub-advisors we select. Discretionary authority is typically granted by the Investment Advisory Agreement you sign with our firm and the appropriate trading authorization forms. In managing portfolios, we consider each client’s stated objectives, such as capital appreciation, income, growth, or a combination thereof—as well as relevant tax considerations. Clients may impose reasonable restrictions on investing in specific securities, types of securities, or industry sectors. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. Asset Management Services: Sub-Advisors/Third Party Managers (“TPAs”) As part of our investment advisory services, we often use one or more sub-advisors or third-party money manager(s) (“Other Managers”) to manage a portion of your account on a discretionary basis. Our firm may utilize the services of various Other Managers for the management of client accounts, allocating client assets among such managers as appropriate. In such cases, Other Managers will be responsible for continuously monitoring client accounts and making trades in client accounts when necessary. While the chosen Other Managers will provide advice on specific securities and/or other investments in connection with this service, our firm has discretionary authority to hire and fire such Other Managers and reallocate assets among them as deemed appropriate. We will assist you with identifying your risk tolerance and investment objectives, and, in turn, retain Other Managers in relation to your stated investment objectives and risk tolerance. The Other Managers, if utilized, will charge an additional fee as compensation for their direct management of your account. This fee will not exceed the maximum fee disclosed in your Investment Advisory Agreement with our firm. ITEM 4 - ADVISORY BUSINESS Wrap Fee Programs A wrap fee program is a program under which the client pays a single fee that covers both receipt of investment advice and the execution of securities transactions. TWS does not sponsor a wrap fee program, however we may utilize sub-advisors as described above which sponsor wrap programs. If you participate in a third-party wrap program, it will be on a discretionary basis. The strategies implemented are based on clients' individual investment objectives. When using third-party managers or sub-advisors you may be required to complete additional paperwork for those managers. Additionally, these accounts may participate in wrap programs sponsored by the chosen managers. Please review all disclosures provided by or about third-party managers or sub-advisors to ensure you understand what costs their wrap programs cover. Financial Planning Services Our firm also provides financial planning services. As part of our advisory services, Tailored Wealth Solutions (TWS) provides comprehensive financial planning tailored to each client’s unique circumstances. This process involves an in-depth evaluation of your current and future financial position, considering known variables to project future cash flows, asset values, and withdrawal strategies. We take a holistic approach and examine how various components of your financial life affect one another. Clients who engage in this service will receive a written or electronic financial plan outlining actionable recommendations designed to help meet their stated goals. Financial planning services can be a one-time engagement or an ongoing service based on individual client needs. The Firm may charge additional or separate fees for planning services, which we will detail in the Financial Planning agreement you sign with us. Regardless of the nature of the service, the implementation of all recommendations will be at the client's discretion. A financial plan will address one or more of the following areas: Financial Position: Understanding of a client's current financial situation. Investment Planning: Determining the most suitable way to structure investments to meet financial goals, and determine the appropriate account type (e.g., joint tenants, IRA, Roth IRA, etc.) Personal Tax Planning: Evaluating the current tax situation to help minimize a client's taxes and find more profitable ways to use the extra income generated. Retirement Planning: Assessing retirement needs to help a client determine how much to accumulate, as well as distribution strategies designed to create a source of income during retirement years. Insurance Planning and Risk Management: Evaluating the client's insurance needs and reviewing insurance needs, existing policies, and goals. We analyze potential financial threats from unexpected events such as premature death, disability, or long-term care needs, and offer recommendations for mitigating those risks through insurance or other strategies Estate Planning: Reviewing the client's cash needs at death, income needs of surviving dependents and estate planning goals. Charitable Planning: Providing strategic charitable giving plans for clients and researching and evaluating charitable entities and private foundations. Mortgage/Debt Analysis: Analyzing client's current mortgage debt, home equity, and financing alternatives. Review of Employee Benefit Plans: Reviewing the client's investment options, allocation models and historical performance of client assets held through employee benefit plans. College Savings: We project education funding needs and recommend savings strategies, while also helping clients assess financial aid considerations and gifting strategies for children or grandchildren. ITEM 4 - ADVISORY BUSINESS We gather information at an initial meeting which includes interviews and a review of documents provided by the client. Information gathered includes the client's current financial status, future goals, investment objectives, risk tolerance and family circumstances. Typical financial planning services include one or more of each of the service components. A financial plan could require the services of a specialist such as an insurance specialist, attorney or tax accountant. We will recommend third-party service providers if we feel it is appropriate and in your best interest, but you are under no obligation to use any service provider recommended by us. Likewise, you are under no obligation to act on our financial planning recommendations. We do not receive referral or other fees from third-party service providers. Financial plans are based on the client's financial situation at the time we present the financial plan to the client, and on the information provided to us. The client must promptly notify us if his/her financial situation, goals, objectives or needs change. Certain assumptions are made with respect to interest rates, inflation rates, and use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. We do not offer any guarantees or promises that a client's financial goals will be met. Retirement Planning We provide investment advice and financial planning for your retirement accounts and retirement plans. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and Give you basic information about conflicts of interest. Retirement Plan Rollover Recommendations To the extent we recommend you roll over your account from a current retirement plan to an individual retirement account (“Rollover IRA”), managed by Tailored Wealth Solutions please know that Tailored Wealth Solutions and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to a Rollover IRA managed by Tailored Wealth Solutions. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to a Rollover IRA managed by Tailored Wealth Solutions. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to a Rollover IRA which is a conflict of interest because our recommendation that ITEM 4 - ADVISORY BUSINESS you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Tailored Wealth Solutions receiving unreasonable compensation related to the rollover of funds from the retirement plan to a Rollover IRA, and (iii) fully disclose compensation received by Tailored Wealth Solutions and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to a Rollover IRA and refrain from making any materially misleading statements regarding such rollover. To the extent we provide you investment advice as a participant in a retirement plan regarding whether to maintain investments and/or proceeds in the retirement plan, roll over such investment/proceeds from the retirement plan to a Rollover IRA or make a distribution from the retirement plan, Tailored Wealth Solutions hereby acknowledges our fiduciary obligations to you with regard to our investment advice about whether to maintain, roll over or distribute proceeds from the retirement plan, and as such a fiduciary with respect to its investment advice to you about whether to maintain, roll over or distribute proceeds from the retirement plan. Our investment advisor representatives shall act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Tailored Wealth Solutions or our affiliated personnel. Newsletters, Online Content, and Seminars Tailored Wealth Solutions occasionally prepares general, educational and informational newsletters, videos or social media posts. This content is always offered on an impersonal basis and does not focus on the needs of a specific individual. This content is provided to clients and prospective clients free of charge. We may host occasional Seminars for clients or prospective clients. Seminar topics focus on financial planning topics but can also include other general financial topics. Seminars are always offered on an impersonal basis and do not focus on the individual needs of participants. Seminars are offered to clients and prospects free of charge. ITEM 4 - ADVISORY BUSINESS Limits Advice to Certain Types of Investments Tailored Wealth Solutions can provide investment advice on the following types of investments: Mutual Funds Exchange Traded Funds (ETFs) Exchange-listed Securities Securities Traded Over the Counter Foreign Issues Warrants Corporate Debt Securities Commercial Paper Certificates of Deposit Municipal Securities Variable Annuities Variable Life Insurance US Government Securities Interests in Partnerships Investing in Real Estate Interests in Partnerships Investing in Oil and Gas Interests Securities Properly Exempted from Registration Hedge Funds Non-Traded Real Estate Investment Trusts (REITs) Business Development Companies Private Placements or Equities Structured Notes Cryptocurrency and Crypto Related Securities Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that can be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we can increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. We can modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) ITEM 4 - ADVISORY BUSINESS Tailor Advisory Services to Individual Needs of Clients Tailored Wealth Solutions advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the Accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Our recommendations are crafted with an individualized, detailed financial plan which takes into consideration your overall investment knowledge and goals. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. When managing client Accounts through our firm’s Asset Management Services program, we can manage a client’s Account in accordance with one or more investment models. When client Accounts are managed using models, investment selections are based on the underlying model, and generally we do not develop customized (or individualized) portfolio holdings for every client. However, the determination to use a particular model or models is always based on each client’s individual investment goals, objectives and mandates. We may recommend a mixture of investment models and individualized trade strategies or create an individualized portfolio based on what we believe to be in our clients best interests. Client Assets Managed by Tailored Wealth Solutions As of June 5, 2026, Tailored Wealth Solutions had Discretionary Assets Under Management of $271,777,434. ITEM 4 - ADVISORY BUSINESS ITEM 5 - FEES AND COMPENSATION ITEM 5 - FEES AND COMPENSATION In addition to the information provided in Item 4 – Advisory Business, this section provides additional details regarding our firm’s services along with descriptions of each service’s fees and compensation arrangements. It should be noted that lower fees for comparable service can be available from other sources. The exact fees and other terms will be outlined in the agreement between you and Tailored Wealth Solutions. Fees for Asset Management Services The total annual advisory fee due to us for Asset Management Services (“Advisory Fee”) is negotiable at the sole discretion of our firm and will be outlined in the Investment Advisory Agreement signed by the client and our firm. The maximum annual Advisory Fee charged for these services will be up to 1.5% of the total assets under management, and will not include all fees payable to sub-advisers or third party investment advisers (“TPAs”) we engage on your behalf. Our standard annual fee schedule for Asset Management follows a blended tiered fee schedule which is: Asset Management Fee Asset Level First $0 – $250,000 1.50% Next $250,001 – $500,000 1.25% Next $500,001 – $1,000,000 1.05% Next $1,000,001 – $2,000,000 0.85% Next $2,000,001 – $5,000,000 0.65% Next $5,000,001+ 0.55% This is the current fee schedule for newly onboarded clients of the firm who have entered into an Advisory Agreement with this schedule in place. Previous advisory relationships are subject to different fee schedules and negotiated fee arrangements in accordance with the fee schedule and Advisory Agreement in place at the time they onboarded. The fee schedule does not imply that fees are the same for everyone, including legacy clients. Asset Management Fees are typically billed monthly in advance based on each account's prior month end balance. The final effective fee rate is lower than the highest percentage in the schedule when blended tiers of asset levels are considered. ITEM 5 - FEES AND COMPENSATION Fees for Asset Management: Retirement Plans Fees for Asset Management of retirement plans are typically billed monthly in advance based on the average daily balance during the prior calendar quarter. Our standard fee schedule for asset management of retirement plans is a flat tiered fee schedule which is: Asset Management Fee Asset Level 0 – 500K 1.25% 500K - 3 Million 1.00% 3 - 5 Million 0.75% 5 - 10 Million 0.50% 10 Million + 0.25% For all asset management fees, the first monthly fee shall be prorated based on the portion of such time period remaining when you sign your agreement with us. When services begin the prorated fee is calculated and added to the next billing cycle. Advisory Fees are negotiable and will be deducted from client account(s) by the qualified custodian based on instruction from us and/or a sub-adviser. In rare cases, our firm will agree to direct bill clients. The fee rate for your accounts will always be reflected in your Investment Advisory Agreement with us and the amounts charged will be on your account statements provided by the qualified custodian holding your account(s). Fees for Asset Management Services through Third Party Advisors (“TPAs”) Our above fee schedule includes our standard fees for accounts and does not include fees for accounts managed by third party advisors/sub-advisors we select. The Advisory Fee payable to the sub-adviser or TPA is established and payable in accordance with the brochure provided by each TPA to whom you are recommended. These fees for sub-advisors or TPAs range from 0.02% - 0.60% depending on the manager and strategy selected, and are not negotiable. Furthermore, different models made available through TPAs also charge different fees; accordingly, our net compensation also differs depending upon the model selected. Investment Advisory fees incurred by Client will increase when the Client or TWS elects to use a TPA. Because our clients do not typically pay transaction fees for the investments we recommend, it would not benefit our clients for us to determine whether asset-based or transaction-based pricing is more expensive. Rather, it would only benefit our firm to pay lower transaction fees. However, in order to simplify our business model and eliminate the need for continuous analysis of which transaction pricing models are most profitable to our firm, we have adopted a policy of using only asset-based pricing, which carries a platform fee that is higher than what we would pay for transaction-based pricing. In the absence of this policy, in some situations we would have an incentive to minimize our transaction costs by placing assets in transaction-based accounts and to reduce trading in those accounts. Our policy to use asset-based pricing exclusively eliminates any incentive to recommend those types of accounts to our clients, or to manage the accounts in that manner. ITEM 5 - FEES AND COMPENSATION Our receipt of an asset-based fee presents a conflict of interest. This is because the more assets there are in the client’s account, the more the client will pay in fees. Therefore, we have an incentive to encourage clients to increase the assets in their accounts. We address this conflict of interest by ensuring any such recommendations are in the client’s best interest. Financial Planning & Estate Design Fees We typically charge flat fee amounts for Financial Planning services. Our fees will generally range between $3,000 - $25,000 depending on planning needs and complexity. Fees are charged as one time or ongoing depending on the terms of your Financial Planning Agreement with us. If you terminate the financial planning and consulting services after entering into an agreement with us and the IAR did not waive your fees, you will be responsible for immediate payment of any financial planning and consulting services performed by the firm prior to our receipt of your notice of termination. We may on occasion agree to do specialized projects for a Client at an hourly rate of no more than $500 per hour which will be memorialized in your Financial Planning Agreement with us. You will be invoiced and provided with a reconciliation for hours billed if you engage in this type of agreement. Other Fee Terms You should notify Tailored Wealth Solutions within ten (10) days of receipt of an invoice if you have questions about or dispute any billing entry. All fees paid to TWS for advisory services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders. These fees and expenses are described in each mutual fund’s prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, you may pay an initial or deferred sales charge. Clients incur certain charges imposed by custodians, brokers, and other third parties such as administrative custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Please refer to Item 12 (Brokerage Practices) in this Brochure for additional information. All fees paid to TWS for services are separate and distinct from the commissions, fees, and expenses charged by insurance companies associated with any disability insurance, life insurance, and annuities subsequently acquired by you. If you sell or liquidate certain existing securities positions to acquire any insurance or annuity, you may also pay commissions, fees, and expenses charged by the insurance company for subsequently-acquired insurance and/or annuities in addition to the financial planning and consulting fees paid to TWS for Advisory Services. Please see Item 10 of this brochure for more information about our outside professional activities. To the extent Tailored Wealth Solutions engages an outside professional (i.e., attorney, independent investment adviser or Accountant) while providing advisory services to you, Tailored Wealth Solutions will be responsible for the payment of the fees for the services of such an outside professional, and you will not be required to reimburse Tailored Wealth Solutions for such payments. ITEM 5 - FEES AND COMPENSATION To the extent that you personally engage such an outside professional, you will be responsible for the payment of the fees for the services of such an outside professional, and Tailored Wealth Solutions will not be required to reimburse Client for such payments. Fees for the services of an outside professional (i.e., attorney, independent investment adviser or Accountant) will be in addition to and separate from the fees charged by Tailored Wealth Solutions, and you will be responsible for the payment of the fees for the services of such an outside professional.In no event will the services of an outside professional be engaged without your express approval. Please see Item 10 of this brochure for more information about our outside professional activities. ITEM 5 - FEES AND COMPENSATION ITEM 6 – PERFORMANCE-BASED FEES AND SIDE- ITEM 6 – PERFORMANCE-BASED FEES AND SIDE- BY-SIDE MANAGEMENT BY-SIDE MANAGEMENT Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation of the assets held in a client’s Account. Item 6 is not applicable to this Disclosure Brochure because we do not charge or accept performance-based fees. ITEM 7 – TYPES OF CLIENTS ITEM 7 – TYPES OF CLIENTS Tailored Wealth Solutions generally provides investment advice to the following types of clients: Individuals High net worth individuals Businesses Retirement Plans You are required to execute a written agreement with Tailored Wealth Solutions specifying the particular advisory services in order to establish a client arrangement with Tailored Wealth Solutions. Minimum Investment Amounts Required Tailored Wealth Solutions does not require a minimum account value in order to open an Account. Sub-advisors we recommend may have minimum account and minimum fee requirements in order to participate in their programs. The sub-adviser will disclose its minimum account size and fees in its Form ADV Part 2A Disclosure Brochure. ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT | ITEM 7 - TYPES OF CLIENTS ITEM 8 – METHODS OF ANALYSIS, INVESTMENT ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS STRATEGIES AND RISK OF LOSS Methods of Analysis Tailored Wealth Solutions uses the following methods of analysis in formulating investment advice: Charting - This is a set of techniques used in technical analysis in which charts are used to plot price movements, volume, settlement prices, open interest, and other indicators, in order to anticipate future price movements. Users of these techniques, called chartists, believe that past trends in these indicators can be used to extrapolate future trends. Charting is likely the most subjective analysis of all investment methods since it relies on proper interpretation of chart patterns. The risk of reliance upon chart patterns is that the next day's data can always negate the conclusions reached from prior days' patterns. Also, reliance upon chart patterns bears the risk of a certain pattern being negated by a larger, more encompassing pattern that has not shown itself yet. Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of a company). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Fundamental analysis is considered to be the opposite of technical analysis.Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. The risk associated with fundamental analysis is that it is somewhat subjective. While a quantitative approach is possible, fundamental analysis usually entails a qualitative assessment of how market forces interact with one another in their impact on the investment in question. It is possible for those market forces to point in different directions, thus necessitating an interpretation of which forces will be dominant. This interpretation may be wrong and could therefore lead to an unfavorable investment decision. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Technical – This is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. Technical analysis is even more subjective than fundamental analysis in that it relies on proper interpretation of a given security's price and trading volume data. A decision might be made based on a historical move in a certain direction that was accompanied by heavy volume; however, that heavy volume may only be heavy relative to past volume for the security in question, but not compared to the future trading volume. Therefore, there is the risk of a trading decision being made incorrectly, since future trading volume is unknown. Technical analysis is also done through observation of various market sentiment readings, many of which are quantitative. Market sentiment gauges the relative degree of bullishness and bearishness in a given security, and a contrarian investor utilizes such sentiment advantageously. When most traders are bullish, then there are very few traders left in a position to buy the security in question, so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish, then there are very few traders left in a position to sell the security in question, so it becomes advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical measures is that a very bullish reading can always become more bullish, resulting in lost opportunity if the money manager chooses to act upon the bullish signal by selling out of a position. The reverse is also true in that a bearish reading of sentiment can always become more bearish, which may result in a premature purchase of a security. Investment Strategies Tailored Wealth Solutions may employ the following investment strategies when managing client assets and/or providing investment advice: Long term purchases. Investments held at least a year. Short term purchases. Investments sold within a year. Value Investing. Value Investing can be described as a strategy of selecting stocks that trade for less than their intrinsic values. Value investors typically seek stocks of companies that they believe the market has undervalued. They believe the market overreacts to good and bad news, resulting in stock price movements that do not correspond with the company's long-term fundamentals. The result is an opportunity for value investors to profit by buying when the price is deflated. Often, value investors select stocks with lower-than-average price-to-book or price-to- earnings ratios and/or high dividend yields. The risks associated with value-investing include incorrectly analyzing and overestimating the intrinsic value of a business, concentration risk, under performance relative to major benchmarks, macro-economic risks, investing in value traps i.e., businesses that remain perpetually undervalued, and lost purchasing power on cash holdings in the case of inflation. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Tactical asset allocation. Allows for a range of percentages in each asset class (such as Stocks = 40-50%). The ranges establish minimum and maximum acceptable percentages that permit the investor to take advantage of market conditions within these parameters. Thus, a minor form of market timing is possible, since the investor can move to the higher end of the range when stocks are expected to do better and to the lower end when the economic outlook is bleak. Strategic asset allocation. Calls for setting target allocations and then periodically rebalancing the portfolio back to those targets as investment returns skew the original asset allocation percentages. The concept is akin to a “buy and hold” strategy, rather than an active trading approach. Of course, the strategic asset allocation targets may change over time as the client’s goals and needs change and as the time horizon for major events such as retirement and college funding grow shorter. Investment Model Strategies. Tailored Wealth Solutions has created proprietary Model Portfolios. Based on the information you provide us, we consider multiple time horizons (long, medium and short-term) when determining investment strategies. Depending on our clients’ needs, we may recommend one or several of our investment management models. In the development and management of our Model Portfolios, Tailored Wealth Solutions uses industry standard techniques that include technical analysis, fundamental analysis and charting. We may engage various types of execution tactics such as long term and short-term buys and value investing as well as asset allocation strategies to achieve the Model Portfolios’ objectives. Each model engages in its own type of techniques, execution tactics and use of research tools to enhance the ability to manage its assets effectively to its stated philosophy. Tailored Wealth Solutions actively manages each model’s investment objective, driven by its investment philosophy and style. Primarily Recommend One Type of Security We do not primarily recommend one type of security to clients. Instead, we recommend any product that may be suitable for each client relative to that client’s specific circumstances and needs. Risk of Loss Past performance is not indicative of future results. Therefore, you should never assume that the future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing in securities through our investment management program, as described below: ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Alternative Investments Risk – Alternative investments typically do not correlate to the stock market, which means they can be used to add diversification to a portfolio and help mitigate volatility. Alternative Investments can be illiquid due to restrictions on transfer and the lack of a secondary trading market. These investments may lack transparency as to share price, valuation, and portfolio holdings. Complex tax structures often result in delayed tax reporting. Compared to mutual funds, private funds are subject to less regulation and often charge higher fees. Alternative investments encompass a broad array of strategies, each with its own unique return and risk characteristics to be considered on a case- specific basis. Collateralized Loan Obligation (“CLO”) Risk – A CLO is a single security backed by a pool of debt. That pool of debt often consists of a bundle of corporate loans that are ranked below investment grade. CLOs are securities subject to credit, liquidity, and interest rate risks. The investor will receive scheduled debt payments from the underlying loans, assuming most of the risk if the borrowers of those loans default. A CLO usually has multiple “tranches.” Each tranche is a piece of the CLO, and the order of the tranches dictates in what order the investors will be paid when the underlying loan payments are made. The tranches also dictate the associated risk since investors who are paid last have the highest overall risk of loss. Those paid first have less risk and are therefore paid smaller interest payments—whereas those paid last receive higher interest payments to compensate for the risk. Company Risk. When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as an unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. Cybersecurity Risk – With the increased use of technologies to conduct business, companies are susceptible to operational, information security, and related risks. In general, information and cyber- incidents can result from deliberate attacks or unintentional events and arise from external or internal sources. Cyber-attacks include unauthorized access to digital systems (such as through “hacking” or malicious software coding) for purposes of misappropriating assets or sensitive information; corrupting data, equipment, or systems; or causing operational disruption. Cyber-attacks may also be carried out in a manner that does not require gaining unauthorized access, such as causing denial of service attacks on websites (making network services unavailable to intended users). Cyber-incidents may cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Duration Risk – Duration is a way to measure a bond’s price sensitivity to changes in interest rates. The duration of a bond is determined by its maturity date, coupon rate, and call feature. Duration is a method to compare how different bonds will react to interest rate changes. For example, if a bond has a duration of five (5) years, it means that the value of that security will decline by approximately five percent (5%) for every one percent (1%) increase in interest rates. Emerging Markets Risk – The risks associated with foreign investments are heightened when investing in emerging markets. The governments and economies of emerging market countries may show greater instability than those of more developed countries. Such investments tend to fluctuate in price more widely and to be less liquid than other foreign investments. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change.If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds.You will also incur brokerage costs when purchasing ETFs. Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments.Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. International Investing Risk – International investing, especially in emerging markets, involves special risks, such as currency exchange and price fluctuations and political and economic risks. Interval Fund Risk – Interval funds are classified as closed-end funds, but they are distinct because the shares do not trade on the secondary market, but instead periodically the fund offers to buy back a percentage of outstanding shares at net asset value. This results in the funds being largely illiquid. There is no guarantee that investors will be able to sell their shares at any given time or in the desired amount. Additionally, repurchase is done on a pro-rata basis; therefore, there is no guarantee you can redeem the number of shares you want during a given redemption. Liquidity Risk – Liquidity is how easily an asset or security can be bought or sold in the market and converted to cash. Generally, the less liquid an asset is, the greater the risk that if an investor needed to sell the asset quickly, the asset will be sold at a loss. Simple assets tend to be more liquid than complex assets. An asset tends to be more liquid if it represents a standardized product or security and there are many traders interested in making a market in that product or security. Some investments, like Qualified Opportunity Zone Funds, are considered private investments and are illiquid because there is no public market that currently exists for the investment type. Therefore, the inability to quickly sell or liquidate this investment carries a higher risk for a loss in the investment. Management Risk – Your investment with our firm varies with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease. Margins Risk – A margin transaction occurs when an investor uses borrowed assets by using other securities as collateral to purchase financial instruments. The effect of purchasing a security using margin is to magnify any gains or losses sustained by the purchase of the financial instruments on margin. Margin trading involves interest charges and risks, including the potential to lose more than deposited or the need to deposit additional collateral in a falling market. Some Sub-Advisor strategies may require the use of margin accounts. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Options Risk. Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. Private Investments Risk – A private investment is a financial asset outside public market assets, meaning they are not listed on an exchange. Investors often access private investments through a private investment fund. A private investment fund is an investment company that doesn’t solicit capital from retail investors or the public. Hedge funds and private equity funds are two of the most common types of private investment funds. Private equity investing often has high investment minimums and they may also have higher liquidity risks since private equity investors are expected to invest their funds with the firm for several years, on average. Investors often utilize private investments to diversify their portfolio and reduce overall risk exposure across specific sectors. However, because there is no major public exchange for these investments, a fund manager may find it difficult to liquidate the investments in a fund in times of economic stress. REITs and Real Estate Risk – Real estate investment trusts (REITs) are popular investment vehicles that pay dividends to investors. The value of an investment in REITs may change in response to a change in the real estate market. REITs may subject an investment to additional risks such as decline in the value of real estate, changes in interest rates may result in lack of available mortgage funds or other capital and financing limits, extended vacancies of properties, increases in property taxes and operating expenses, and changes in zoning laws and regulations. When traded like shares of stock on exchanges, REITs can give exposure to diversified real estate holdings. Structured Notes Risk – Structured notes are complex instruments consisting of a bond component and an imbedded derivative component that adjusts the security’s risk-return profile. There are both principal-at-risk and principal-protected notes. Principal-protected notes offer full principal protection, subject to the credit risk of the issuer, even if the market is down at the note’s maturity. Principal-at-risk notes offer no principal protection, and an investor can lose some or all of their invested principal at maturity. A structured note will result in loss of principal if the reference asset declines by more than the stated buffer or barrier level, either at maturity, or on a scheduled observation date. Structured notes are classified as senior unsecured debt and are therefore subject to the risk of default. They lack liquidity, are not listed on securities exchanges, and do not participate in dividends. Typically, the issuer will maintain a secondary market; but there is no obligation to do so. Therefore, there may be little to no secondary market available. To the extent a secondary market may exist, a sale in the secondary market prior to maturity may result in a significant discount in the sale price of the note resulting in a loss of principal. Structured notes are also subject to credit and call risks. The credit risk involves a situation where, if the issuer were to default on its payment obligations, you may not receive any amount owed under the structured note and you could lose your entire principal investment. Certain notes may be callable automatically or at the option of the issuer. If a note is called, the investor will not receive any interest payments that would have been payable for the remainder of the term of the note. 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 interest rates or foreign exchange rates, or market volatility. After issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value given their complexity. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ITEM 9 – DISCIPLINARY INFORMATION ITEM 9 – DISCIPLINARY INFORMATION Our firm and our financial professionals are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of us, our business or the integrity of our management or associated persons. Information regarding our firm and associated persons is always available by searching the firm or individuals name on the Investment Adviser Public Disclosure website: https://adviserinfo.sec.gov/. The firm has no disciplinary information which would be material to a client’s evaluation of us. Our principal owner Mr. Testa has one civil disclosure related to a dismissed allegation from a former employer. ITEM 10 – OTHER FINANCIAL INDUSTRY ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ACTIVITIES AND AFFILIATIONS Tailored Wealth Solutions is not and does not have a related person that is a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), another investment adviser or financial planner, a futures commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift institution, or a sponsor or syndicator of limited partnerships. Tailored Wealth Solutions does have Investment Advisor Representatives, including control persons, who are engaged in separate business activities as an insurance agency or agent, and a business consultant. Clients are never under any obligation to utilize outside services or products which may be offered by their advisors in these separate capacities. All outside activities of your advisor are disclosed in their individual brochure supplement (ADV 2B) along with any conflicts of interest such activities may present. Compensation received as part of an outside activity is separate from and in addition to the Advisory Fees you pay us for Advisory Services. Please refer to Item 5 – Fees and Compensation for information regarding fees our firm charges for Advisory Services. Insurance Product Recommendations Through unaffiliated insurance agencies, our financial representatives can sell other products or provide services outside of their role as investment adviser representatives with us. Due to the firm’s financial planning philosophy, it is common for our financial professionals to recommend that clients utilize insurance products (for example, a fixed index annuity (“FIA”)) as part of the client’s overall financial plan in lieu of separately managed accounts (specifically, in lieu of cash and fixed income asset classes). You should be aware that there are a number of conflicts of interests that are present due to our planning philosophy and recommendations to utilize insurance products in this nature. As an estimate, our financial professionals that are registered as investment advisor representatives spend a portion of their time on insurance sales and services a portion of their time on investment advisory ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS | ITEM 9 - DISCIPLINARY INFORMATION services in the future. Please refer to Item 5 – Fees and Compensation and Item 14 – Client Referrals and Other Compensation for more details. You may therefore work with your financial professional in both their capacity as an investment adviser representative of Tailored Wealth Solutions, as well as in their capacity as an insurance agent. As such, your TWS financial professional, in their dual capacity as an IAR and insurance agent, may advise you to purchase insurance products (general disability insurance, life insurance, annuities, and other insurance products to you), and then assist you in implementing the recommendations by selling you those same products through an insurance agency. For the reasons described below, this creates a variety of conflicts of interest that you should be aware of. Commissions: Although Tailored Wealth Solutions, LLC and its investment adviser representatives owe you a fiduciary duty, it should be noted that the receipt of a commission provides a variety of incentives for our financial professionals to recommend these products. For example, your financial professional will earn a larger commission the more assets are invested in an annuity, therefore they are economically incentivized to recommend that you purchase an annuity over placing those assets in a brokerage or advisory account, which may provide lower total compensation. Our financial professional could also be incentivized to recommend a product that pays a commission now, versus an advisory product that pays fees over a longer period of time. As an example, all other variables held equal, a 5% commission paid by an insurance company upon sale of a $100,000 annuity product, may be more attractive to a financial professional than a one percent (1%) advisory fee charged on a $100,000 account paid over a period of five (5) years, despite the overall pre-tax compensation paid to the financial professional being equal. Note that some products pay a higher street or bonus commission than others, increasing this incentive and creating an economic incentive to favor higher fee-paying products. Additional Compensation: Our financial professionals also receive additional compensation or incentives in the form of bonus commissions, gifts, meals or entertainment, reimbursement for training, marketing, education, advertising, or travel expenses associated with sponsored conferences or events. The exact compensation cannot be accurately calculated at the time of recommendation because they rely on sales goals, but you should be aware that there are a variety of forms of indirect compensation paid by carriers and insurance marketing organizations, and this compensation creates a conflict of interest. In addition, each of the individual insurance carriers that our financial professionals work with may also separately provide incentive-based bonuses or awards in exchange for sales-related production over specific periods of time, which is a conflict of interest. They may also provide indirect compensation by providing marketing assistance, business development tools, technology, back office/operations support, business succession planning, business conferences, and incentive trips. These incentive programs do not directly affect fees paid by the client. Although some of these services can benefit a client, other services obtained by our IARs such as marketing assistance, business development, and incentive trips, will not benefit an existing client and is a conflict of interest. At times, our financial professionals receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are the result of informal expense sharing arrangements in which product sponsors will underwrite costs incurred for marketing, such as client appreciation events, advertising, publishing, and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are made by those sponsors for which sales have been made or for which it is ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of clients. Exchanges & Replacement Recommendations: Your financial professional may recommend that you exchange or replace an existing annuity with a new annuity if they believe it is appropriate. You should be aware that the firm and financial professional receive additional commission when an exchange or replacement is made, in the form of commissions and bonuses, and other additional compensation described above. You may also incur a surrender charge on the old annuity. The new purchase be also subject to the commencement of a new surrender period, lose existing benefits, such as accumulated value, death, living or other contractual benefits, or be subject to increased fees, or additional charges for riders and similar product enhancements. The sale of commission-based products is supervised by the firm’s Chief Executive Officer, and the firm makes periodic reviews of its insurance recommendations to ensure that our financial professionals act in accordance with our fiduciary duty. If you have any questions or concerns about annuity recommendations made during the financial planning process, we encourage you to immediately bring them to the attention of the Chief Executive Officer. Finally, you should be aware that there are other insurance products that are offered by other insurance agents other than those recommended by our financial professionals. You are under no obligation to implement any insurance or annuity transaction through our financial professionals. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ITEM 11 – CODE OF ETHICS, PARTICIPATION IN ITEM 11 – CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL TRADING CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics Summary An investment adviser is considered a fiduciary and has a fiduciary duty to all clients. Tailored Wealth Solutions has established a Code of Ethics to comply with the requirements of the securities laws and regulations that reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires compliance with federal securities laws. Tailored Wealth Solutions’ Code of Ethics covers all individuals that are classified as “supervised persons”. All employees, officers, directors and investment adviser representatives are classified as supervised persons. Tailored Wealth Solutions requires its supervised persons to consistently act in your best interest in all advisory activities.Tailored Wealth Solutions imposes certain requirements on its affiliates and supervised persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct required is higher than ordinarily required and encountered in commercial business. This section is intended to provide a summary description of the Code of Ethics of Tailored Wealth Solutions. If you wish to review the Code of Ethics in its entirety, you should send us a written request and upon receipt of your request, we will promptly provide a copy of the Code of Ethics to you. Affiliate and Employee Personal Securities Transactions Disclosure Tailored Wealth Solutions or supervised persons of the firm can buy or sell for their personal accounts investments identical to those recommended to clients. This creates a conflict of interest. It is the express policy of Tailored Wealth Solutions that all persons supervised in any manner by our firm must place clients’ interests ahead of their own when implementing personal investments. As is required by our internal procedures manual, Tailored Wealth Solutions and its supervised persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with our firm unless the information is also available to the investing public upon reasonable inquiry. We are now and will continue to be in compliance with applicable state and federal rules and regulations. To prevent conflicts of interest, we have developed written supervisory procedures that include personal investment and trading policies for our representatives, employees and their immediate family members (collectively, supervised persons). Any supervised person not observing our policies is subject to sanctions up to and including termination. ITEM 11 – CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL TRADING ITEM 12 – BROKERAGE PRACTICES ITEM 12 – BROKERAGE PRACTICES Best execution does not necessarily mean that clients receive the lowest possible commission costs but that the qualitative execution is best. In other words, all conditions considered, the transaction execution is in your best interest. When considering best execution, we look at a number of factors besides prices and rates including, but not limited to: Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with our existing systems, ease of monitoring investments) Products and services offered (e.g., investment programs, back-office services, technology, regulatory compliance assistance, research and analytic services) Financial strength, stability and responsibility Reputation and integrity Ability to maintain confidentiality We exercise reasonable due diligence to make certain that best execution is obtained for all clients when implementing any transaction by considering the back-office services, technology and pricing of services offered. At least annually, we will review alternative custodians in the marketplace for comparison to the currently used custodian, evaluating criteria such as overall expertise, cost competitiveness, and financial condition. Quality of execution for custodians will be reviewed through trade journal evaluations. We recommend the brokerage and custodial services of Schwab Institutional, a division of Charles Schwab & Co., Inc. ("Schwab Institutional"), a securities broker-dealer and a member of NYSE/SIPC. Clients are advised that there may be transaction charges involved when purchasing or selling securities. Our firm does not share in any portion of the brokerage fees/transaction charges imposed by Schwab Institutional. Additionally, the commission/transaction fees charged by Schwab Institutional may be higher or lower than those charged by other broker-dealer/custodians. Schwab Institutional provides our firm with access to its institutional trading and operations services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers at no charge to them so long as a total of at least $10 million of the adviser's clients account assets are maintained at Schwab Institutional. Schwab Institutional services may include research, brokerage, custody, access to mutual funds and other investments that are otherwise available only to institutional investors or would require significantly higher minimum initial investments. Schwab Institutional also makes available to our firm other products and services that benefit our firm but may not benefit its clients' accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution, provide research, pricing information and other market data, and provide custodial services which facilitate payment of our firm's fees from its clients' accounts and clients reports. The availability to our firm of the foregoing products and services is not contingent upon our firm committing to Schwab Institutional any specific amount of business (assets in custody or trading). We believe that Schwab Institutional provides quality execution services at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by Schwab Institutional, including the value of research provided, the firm's reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. ITEM 12 – BROKERAGE PRACTICES In recognition of the value of research services and additional brokerage products and services Schwab Institutional provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Non-Soft Dollar Research and Additional Benefits Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, TWS may receive from Schwab (or another broker- dealer/custodian, investment manager, platform or fund sponsor, or vendor) without cost (and/or at a discount) support services and/or products, certain of which assist TWS to better monitor and service client accounts maintained at such institutions. Included within the support services that may be obtained by TWS may be investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support-including client events, computer hardware and/or software and/or other products used by TWS in furtherance of its investment advisory business operations. As indicated above, certain of the support services and/or products that may be received may assist TWS in managing and administering client accounts. Others do not directly provide such assistance but rather assist TWS to manage and further develop its business enterprise. TWS’ clients do not pay more for investment transactions effected and/or assets maintained at Schwab because of this arrangement. There is no corresponding commitment made by TWS to Schwab or any other any entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as result of the above arrangement. Directed Brokerage TWS recommends that its clients utilize the brokerage and custodial services provided by Schwab. TWS generally does not accept directed brokerage arrangements (when a client requires that account transactions be affected through a specific broker-dealer). In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and TWS will not seek better execution services or prices from other broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers with orders for other accounts managed by TWS As a result, a client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Please Note: In the event that the client directs TWS to effect securities transactions for the client’s accounts through a specific broker- dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative clearing arrangements that may be available through TWS. Higher transaction costs adversely impact account performance. Please Also Note: Transactions for directed accounts will generally be executed following the execution of portfolio transactions for non-directed accounts. Trade Away/Prime Broker Fees Relative our discretionary investment management services (and sub-advisors), when beneficial to the ITEM 12 – BROKERAGE PRACTICES client, TWS or sub-advisors, may purchase individual fixed income securities through broker-dealers other than the account custodian, in which event, the client generally will incur the fee (commission, mark-up, mark-down) charged by the executing broker-dealer and potentially, a separate "trade away" and/or prime broker fee charged by the account custodian. Block Trading Policy We often elect to purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading or block trading and is used by our firm when Tailored Wealth Solutions believes such action may prove advantageous to clients. If and when we aggregate client orders, allocating securities among client Accounts is done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. Tailored Wealth Solutions uses the pro rata allocation method for transaction allocation. Under this procedure, pro rata trade allocation means an allocation of the trade at issue among applicable advisory clients in amounts that are proportional to the participating advisory client’s intended investable assets. Tailored Wealth Solutions will calculate the pro rata share of each transaction included in a block order and assign the appropriate number of shares of each allocated transaction executed for the client’s Account. If and when we determine to aggregate client orders for the purchase or sale of securities, including securities in which Tailored Wealth Solutions or our associated persons may invest, we will do so in accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither we nor our associated persons receive any additional compensation as a result of block trades. ITEM 13 – REVIEW OF ACCOUNTS ITEM 13 – REVIEW OF ACCOUNTS Account Reviews and Reviewers Managed Accounts are reviewed at least annually but reviews may occur more frequently based on your IARs assessment of your financial needs and investment strategy. While the calendar is the main triggering factor, reviews can also be conducted at your request. Account reviews will include investment strategy and objectives review and making a change if strategy and objectives have changed. Reviews are conducted by your Advisor on record, with reviews performed in accordance with your investment goals and objectives. Statements and Reports For our asset management services, you are provided with transaction confirmation notices and regular quarterly Account statements in writing directly from the qualified custodian. Additionally, Tailored Wealth Solutions may provide position or performance reports to you quarterly and upon request. Financial Planning client receive reports as agreed in the Financial Planning Agreement with us which may or may not be ongoing. You are encouraged to always compare any reports or statements provided by us or a co-adviser against the Account statements delivered from the qualified custodian. When you have questions about your Account statement, you should contact our firm and the qualified custodian preparing the statement. ITEM 12 – BROKERAGE PRACTICES | ITEM 13 - REVIEW OF ACCOUNTS ITEM 14 – CLIENT REFERRALS AND OTHER ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION COMPENSATION Tailored Wealth Solutions does not currently participate in referral arrangements with affiliated and unaffiliated third parties. In the event we engage in such arrangement, before we compensate a third party for referrals, clear and prominent disclosures are provided to you on the material terms of the compensation arrangement between the referral source and our Firm, whether there is any affiliation between the referral source and our Firm, and whether the client bears any costs with respect to the referral. Additionally, we disclose that fees paid by a referred client may differ from fees paid by other similarly situated clients who are not introduced to Tailored Wealth Solutions through a referral. We strongly recommend prospective clients review the disclosures carefully to help address any potential conflicts of interest. As disclosed under the "Fees and Compensation" section in this Brochure, our financial professionals providing investment advice on behalf of our firm are also licensed insurance agents and earn commission-based compensation for selling insurance products. Our representatives who are licensed insurance agents also receive certain benefits from insurance carriers, including small gifts such as fruit baskets or snacks, event sponsorships, or bonuses. These practices present conflicts of interest because our representatives who are licensed insurance agents have an incentive to recommend insurance products, as well as insurance products through specific carriers, to you based on the receipt of these benefits. For information on how we address the conflicts associated with the sale of insurance products, please refer to the "Fees and Compensation" and "Other Financial Industry Activities and Affiliations" sections of this Brochure. The Firm and its supervised persons may receive certain benefits from third-party managers or vendors, including sales awards and trips, based in part on the amount of advisory business directed to the third- party manager or business with the vendor. This presents a conflict of interest because we have an incentive to recommend the services of the third-party manager or vendor. We address this conflict by ensuring the recommendation for a third party manager is in your best interest. ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ITEM 15 – CUSTODY ITEM 15 – CUSTODY Custody, as it applies to investment advisors, has been defined by regulators as having access to or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment adviser has the ability to access or control client funds or securities, the investment adviser is deemed to have custody and must ensure proper procedures are implemented. For all of our managed accounts, we have established procedures to ensure all client funds and securities are held by a qualified custodian in a separate account for each client under that client’s name. Clients will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained.Finally, account statements are delivered directly from the qualified custodian to each client, at least quarterly.Clients should carefully review those statements and are urged to compare the statements against reports received from Tailored Wealth Solutions. When clients have questions about their account statements, they should contact Tailored Wealth Solutions or the qualified custodian preparing the statement. ITEM 16 – INVESTMENT DISCRETION ITEM 16 – INVESTMENT DISCRETION When providing asset management services, Tailored Wealth Solutions maintains trading authorization over your Account and can provide management services on a discretionary basis. When discretionary authority is granted, we will have the authority to determine the type of securities and the amount of securities that can be bought or sold for your portfolio without obtaining your consent for each transaction. You also give Tailored Wealth Solutions discretionary authority to select third party asset managers and to change managers as needed. However, it is the policy of Tailored Wealth Solutions to consult with you prior to making significant changes in the Account even when discretionary trading authority is granted. If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact you prior to implementing changes in your Account. Therefore, you will be contacted and required to accept or reject our investment recommendations including: The security being recommended The number of shares or units Whether to buy or sell Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your Accounts are managed on a non-discretionary basis, “Client Managed” you need to know that if we are not able to reach you or you are slow to respond to our request, it can have an adverse impact on the timing of trade implementations, and we may not achieve the optimal trading price. You will have the ability to place reasonable restrictions on the types of investments that may be purchased in your Account. You may also place reasonable limitations on the discretionary power granted to Tailored Wealth Solutions so long as the limitations are specifically set forth or included as an attachment to the client agreement. ITEM 15 – CUSTODY | ITEM 16 - INVESTMENT DISCRETION ITEM 17 – VOTING CLIENT SECURITIES ITEM 17 – VOTING CLIENT SECURITIES Tailored Wealth Solutions does not vote proxies on behalf of Clients. We have determined that taking on the responsibility for voting client securities does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting client securities. Therefore, it is your responsibility to vote all proxies for securities held in Account. You will receive proxies directly from the qualified custodian or transfer agent; we will not provide you with the proxies. You are encouraged to read through the information provided with the proxy-voting documents and make a determination based on the information provided. ITEM 18 – FINANCIAL INFORMATION ITEM 18 – FINANCIAL INFORMATION This Item 18 is not applicable to this brochure. Tailored Wealth Solutions does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for the most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, Tailored Wealth Solutions has not been the subject of a bankruptcy petition at any time. ITEM 17 – VOTING CLIENT SECURITIES | ITEM 18 - FINANCIAL INFORMATION

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