Overview

Headquarters
Milwaukee, WI
Average Client Assets
$2.6 million
SEC CRD Number
108931

Fee Structure

Primary Fee Schedule (ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $500,000 1.20%
$500,001 $2,000,000 0.75%
$2,000,001 $5,000,000 0.50%
$5,000,001 and above 0.25%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $9,750 0.98%
$5 million $32,250 0.64%
$10 million $44,750 0.45%
$50 million $144,750 0.29%
$100 million $269,750 0.27%

Clients

HNW Share of Firm Assets
94.02%
Total Client Accounts
822
Discretionary Accounts
820
Non-Discretionary Accounts
2

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Regulatory Filings

Primary Brochure: ADV PART 2A (2026-03-25)

View Document Text
Item 1 Cover Page The MilWealth Group, LLC Form ADV Part 2A 125 South 84th Street, Suite 130 Milwaukee, WI 53214 (414) 475-1369 www.milwealth.com March 25, 2026 This brochure provides information about the qualifications and business practices of The MilWealth Group, LLC (The MilWealth Group). If you have any questions about the contents of this brochure, please contact us at (414) 475-1369 or mmiler@milwealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about The MilWealth Group also is available on the SEC’s website at www.adviserinfo.sec.gov. The MilWealth Group is an SEC registered investment adviser. Registration of an adviser with the SEC does not imply a certain level of skill or training. The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 Item 2 Material Changes Below is a summary of material changes made to our Form ADV Part 2A since our January 17, 2025 annual update filing. Item 8-Methods of Analysis, Investment Strategies and Risk of Loss We updated this item to add risks related to the use of artificial intelligence. 2 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 Item 3 Table of Contents Item 1 Cover Page ................................................................................................................................... 1 Item 2 Material Changes ........................................................................................................................ 2 Item 3 Table of Contents ........................................................................................................................ 3 Item 4 Advisory Business ....................................................................................................................... 4 Item 5 Fees and Compensation .............................................................................................................. 5 Item 6 Performance-Based Fees and Side-by-Side Management ....................................................... 6 Item 7 Types of Clients ........................................................................................................................... 6 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 7 Item 9 Disciplinary Information .......................................................................................................... 11 Item 10 Other Financial Industry Activities and Affiliations ............................................................. 11 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 11 Item 12 Brokerage Practices .................................................................................................................. 12 Item 13 Review of Accounts ................................................................................................................... 14 Item 14 Client Referrals and Other Compensation ............................................................................. 14 Item 15 Custody ...................................................................................................................................... 15 Item 16 Investment Discretion ............................................................................................................... 15 Item 17 Voting Client Securities ............................................................................................................ 15 Item 18 Financial Information ............................................................................................................... 15 Other Information .................................................................................................................................... 15 3 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 Item 4 Advisory Business The MilWealth Group, LLC was originally founded in 1995 as McCarthy Financial Management LLC. Matt Miler and Jaqueline Schneider are the principal owners. Our legal name changed as of January 1, 2025 from McCarthy Grittinger Financial Group, LLC to The MilWealth Group, LLC. The MilWealth Group is an independent, fee only, financial planning and investment advisory firm investing primarily in Exchanged Traded Funds (“ETFs”) and mutual funds for our clients. Our primary service offered is discretionary ongoing investment management services, utilizing a comprehensive financial planning approach. We may also provide general counsel to clients in the areas of financial, tax, retirement, insurance and estate planning, including tax preparation services for select clients. We work with clients to develop and maintain a comprehensive document reflecting their current wealth situation. After understanding the client’s situation, the client accounts are generally invested in one of our investment models that is meant to achieve their objectives and goals. When provided to our investment management clients, financial planning services are offered at no additional fees. We also offer financial planning services to non-investment management clients for a fee. As noted in Item 12, Schwab Institutional (“Schwab”) and Transamerica– (collectively our clients’ “Primary Custodians”) provide custodial services to our clients, with Schwab providing custody services for the majority of our clients’ assets. However, at the discretion of our client, we may consider accounts and assets held outside of these custodians’ accounts when providing advisory services to the client. Retirement Plan Advisory Services We manage on a non-discretionary basis certain retirement accounts through Tamarac using the Yodlee aggregator. This allows clients to give us view only access to these types of accounts. It is the responsibility of the client(s) to place the trades as recommended by The MilWealth Group, as we do not have any direct access to these accounts. These accounts are considered managed accounts and are included in non-discretionary assets under management. Assets Under Management as of December 31, 2025 Non-Discretionary: $ 8,535,712 Discretionary: $ 488,364,912 4 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 Item 5 Fees and Compensation Fee Information for Investment Management Clients We charge clients an investment advisory fee based on a percentage of assets under management. We use a tiered fee schedule with breakpoints that result in decreasing fee rates as assets under management rise. Investment advisory fees are calculated using security prices provided by the client’s custodian and are billed quarterly in arrears based on the market value of the client’s account on the last day of the quarter. We may aggregate accounts for related members of the same family for fee billing purposes. Based on written client authorization, fees are deducted automatically from the client’s custodial accounts at the end of the quarter and fully disclosed on quarterly client account statements. When entering into a new investment advisory agreement with us, a client’s initial fee will be calculated as follows: • • • • If the first deposit is made to any account that is part of the client relationship in the first month of a quarter, the client will be charged a full investment advisory fee on all assets received during the quarter. If the first deposit is made to any account that is part of the client relationship in the second month of a quarter, the client will pay 67% of the investment advisory fee for all assets received during the quarter. If the first deposit is made to any account that is part of the client relationship in the first two weeks of the third month of a quarter, the client will pay 33% of the investment advisory fee for all assets received during the quarter. If the first deposit is made to any account that is part of the client relationship in the final two weeks of the third month of a quarter, the client will not pay a fee for that quarter. • A full investment advisory fee will be assessed thereafter. Clients separately incur custody and fund fees and expenses imbedded within mutual funds and ETFs. Clients also pay fees on any Retirement Plan Advisory Services accounts held within The MilWealth Group managed accounts. Please see Item 12 for additional information on our brokerage practices and courtesy trades. New clients pay investment advisory fees according to the fee schedule noted below and The MilWealth Group does not negotiate fees with new clients. Clients of The MilWealth Group retained prior to March 2020 pay investment advisory fees based on a lower standard fee schedule. 5 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 Standard New Client Account Fee Schedule (effective March 2020) Market Value First $500,000 $500,001 - $2,000,000 $2,000,001 - $5,000,000 Over $5,000,001 Annual Fee 1.20% .75% .50% .25% Fee Information for Financial Planning Clients We offer financial planning services to clients who do not utilize our investment management services. Clients using this service will be charged a flat fee based on the complexity of the planning to be performed. Account Valuation Practices The MilWealth Group uses pricing information provided by the client’s custodian for purposes of valuing client portfolios, whether for fee billing or investment performance calculations. Prices of securities we routinely recommend to clients are widely available through financial publications, and do not generally require us to independently determine a value. We maintain account valuation (including fair valuation) policies and procedures designed to provide reasonable assurance the prices we use for fee billing and investment performance calculation purposes are accurate. Item 6 Performance-Based Fees and Side-by-Side Management We do not charge our clients performance-based fees (fees based on a share of capital gains or capital appreciation of the assets in a client’s account). Item 7 Types of Clients The MilWealth Group provides investment management services to individuals, high-net worth individuals and corporations. All clients are required to enter into an investment advisory agreement with us prior to us providing any services. We do not have a minimum account size requirement. We manage separate accounts for family members and friends. These clients receive standard client reporting and are not involved in our day-to-day operations. They also have no knowledge of our trading or investment activities and do not receive a reduction in fees. In addition, if the employee who serves as the primary contact is the client’s relative or friend then we will assign another employee to be the secondary contact to perform periodic reviews of the account. 6 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 Either you or we may terminate the investment advisory agreement at any time by giving 30 days written notice. Termination of an advisory agreement by you will not affect transactions we have initiated on your behalf prior to the effective date of such termination. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Analyses and Strategies We make specific investment recommendations utilizing the broadly accepted investment theory of asset allocation. Asset allocation focuses on designing well-diversified investment portfolios covering multiple “asset classes” or types of investments utilizing mostly open-end mutual funds, ETFs, US Treasury debt, variable annuities and brokered certificates of deposit (“Brokered CDs”). We work with clients to develop and maintain a comprehensive document reflecting their current wealth situation. After understanding the client’s situation, the client accounts are generally invested in one of our investment models that is meant to achieve their objectives and goals. The mutual funds and ETFs recommended by The MilWealth Group primarily invest in U.S. stocks of any market capitalization, foreign stocks including emerging markets, fixed income securities, U.S. Government and Government Agency securities, corporate debt and municipal securities. The MilWealth Group receives no fees or compensation from any mutual fund or ETF. Like all marketable securities, clients face a risk of the value of these securities fluctuating, both up and down. While we cannot control market and economic factors which influence the price of these securities, we utilize an Investment Committee to monitor and perform due diligence on investment options. When providing advisory services to accounts held outside of the Primary Custodians, our advice may be limited by a menu of options established by an unaffiliated entity (such as a retirement plan’s trustees). In such cases, we will advise the clients with respect to the securities available for investment, and we do not actively monitor the investment merits of such securities. The MilWealth Group's main sources of information include, but are not limited to, financial newspapers and magazines, research subscriptions, annual reports, prospectuses, public filings and company press releases and fund company notifications. General Risks We do not offer any products or services that guarantee rates of return on investments for any time period to any client. All clients assume the risk that investment returns may be negative or below the rates of return of other investment advisers, market indices or investment products. Security Risks Client accounts may be subject to the following risks: 7 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 • Market Risk. Clients should have a long-term perspective and be able to tolerate potentially sharp declines in market value. Market risks, including but not limited to political, regulatory, economic and social developments, and developments that impact specific economic sectors, industries or segments of the market, can affect the prices of securities held by mutual funds or ETFs in which clients invest which impacts the value of client accounts. In addition, turbulence in financial markets and reduced liquidity in equity, credit and/or fixed income markets may negatively affect many companies, which could adversely affect client accounts. These risks may be magnified if certain events or developments adversely interrupt the global supply chain. In these and other circumstances, such risks might affect companies on a worldwide scale. Recent examples include risks related to the coronavirus pandemic and the implementation of broad-based tariffs. • Allocation Risk. At times, our judgments as to the asset classes in which client accounts should invest may prove to be wrong, as some asset classes may perform worse than others or the equity markets generally from time to time or for extended periods of time. • Mutual Fund Risk. Mutual funds vary in risk depending on their investments, with aggressive growth funds being more risky than conservative, income-oriented funds. Mutual funds are subject to investment advisory, transactional, operating, and other expenses. The value of mutual funds’ investments and the net asset value of the funds’ shares will fluctuate in response to changes in market and economic conditions, as well as the financial condition and prospects of companies in which the funds invest. The performance of each fund will depend on whether the fund’s investment adviser is successful in pursuing the fund’s investment strategy. • ETF Risk. You may lose money investing in an ETF if the value of securities owned by the ETF declines. You could pay more to purchase ETF shares, or receive less in a sale of shares, than the actual net asset value of the shares. In addition, when you invest in an ETF, you will bear additional expenses based on your pro rata share of the ETF’s operating expenses. The risk of owning an ETF generally reflects the risks of the underlying securities that the ETF is designed to track and the investment strategies employed by such ETF. The ETF may not track the underlying index. • Equity Securities Risk. Mutual funds and ETFs in which clients invest may invest in common stocks and other equity securities. Stocks generally increase or decrease in value based on the earnings of a company and based on general industry and market conditions. The value of a company’s share price may decline as a result of poor decisions made by management, lower demand for the company’s services or products or if the company’s revenues fall short of expectations. There are also risks associated with the stock market overall. The stock market may experience periods of turbulence and instability. • Fixed Income Risk. Mutual funds and ETFs in which clients invest may invest in bonds. A bond’s market value is affected significantly by changes in interest rates – generally, when interest rates rise, the bond’s market value declines and when interest rates decline, 8 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 its market value rises. Generally, a bond with a longer maturity will entail greater interest rate risk but may have a higher yield. Conversely, a bond with a shorter maturity will entail less interest rate risk but may have a lower yield. An additional risk is reinvestment risk that future cash flows will need to be invested in lower yielding securities. A bond’s value may also be affected by changes in its credit quality rating or the issuer’s financial condition. • Foreign Securities Risk. Mutual funds and ETFs 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, country risks (political, diplomatic, regional conflicts, 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 the mutual funds or ETFs 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. • Municipal Securities. Funds in which clients invest may invest in municipal securities. Municipal securities carry different risks than other fixed 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 may be taxable in individual states other than the state in which both the investor and municipal issuer are domiciled. • Brokered CDs Risk. Brokered CDs are certificates of deposit purchased through a brokerage firm, not a bank. A Brokered CD is subject to interest rate risk if the CD would need to be sold before maturity, a client could receive less proceeds than the purchase price if interest rates have risen since purchase. • Longevity Risk. This is the risk of outliving your savings. This risk is particularly relevant for people who are retired or are nearing retirement. • Environmental, Social and Governance (“ESG”) Risk. ESG mutual funds and ETFs in which clients invest in companies that have an ESG focus. This may result in the funds investing in securities or industry sectors that underperform the market as a whole or underperform other funds screened for ESG standards. 9 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 Cybersecurity Risk We rely on information technology and electronic communications to conduct business, which subjects us and our clients to the risk of cyber incidents. While we have controls we believe are reasonably designed to protect against cyber incidents resulting in unauthorized access to confidential information or business disruptions, not all cyber incidents are preventable. Should a cyber incident occur, it would likely have a negative impact on our firm and its clients. Natural Disaster/Epidemic/Pandemic Risk Natural or environmental disasters, such as severe weather and widespread disease, including pandemics and epidemics, have been and can be highly disruptive to economies and markets, adversely impacting individual companies, sectors, industries, markets, currencies, interest and inflation rates, credit ratings, investor sentiment, and other factors affecting the value of client accounts. Given the increasing interdependence of global economies and markets, conditions in one country, market, or region are increasingly likely to adversely affect markets, issuers, and/or foreign exchange rates in other countries, including the U.S. These disruptions could prevent The MilWealth Group from executing advantageous investment decisions in a timely manner and negatively impact The MilWealth Group’s ability to achieve the investment objectives of its asset allocations. These disruptions could also prevent The MilWealth Group and its vendors or service providers from maintaining normal business operations or could result in the loss of services of key personnel on a temporary or long-term basis due to illness or other reasons. Any such event(s) could have a significant adverse impact on the value of client accounts and the risk profile of clients’ asset allocations. Artificial Intelligence Risk The MilWealth Group currently utilizes certain Artificial Intelligence (“AI”) programs, software, and vendors for the purposes of enhancing an employee’s productivity or efficiency. The MilWealth Group’s Managing Partner oversees the use of AI. Given the rapidly evolving nature of AI tools, The MilWealth Group may begin using AI for other purposes in the future. Use of AI can result in enhanced productivity and efficiency, however use of such technology also leads to additional risk to The MilWealth Group and its clients. AI tools could potentially rely on outdated, inaccurate, incomplete or biased data which could create inaccurate output. Use of AI tools creates risk around security, privacy and confidentiality of data entered into AI tools. Additionally, because of the evolving nature of AI technology and common uses by businesses in the financial service industry, AI use could be subject to rapidly evolving regulatory environment which may impact if and how The MilWealth Group is able to use AI in the future. Finally, The MilWealth Group’s service providers may utilize AI tools, potentially without The MilWealth Group’s knowledge, despite efforts to oversee such service providers, leading to additional AI risk exposure. The MilWealth Group maintains an Artificial Intelligence Policy to govern the use 10 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 of AI which aims to ensure any risks or conflicts of interest associated with such tools are evaluated and mitigated. The Artificial Intelligence Policy includes provisions for the review and approval of AI tools prior to their use, a requirement for human oversight of the output of any AI tool, controls around maintaining the confidentiality of data associated with AI tools and a requirement that The MilWealth Group employees be appropriately trained on AI use and related risks. Item 9 Disciplinary Information We have no disciplinary events to disclose. Item 10 Other Financial Industry Activities and Affiliations We have no other financial industry activities or affiliations. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading We maintain a Code of Ethics and Personal Trading Policy (the “Code”), which applies to all employees and principals. As a fiduciary, we have a duty of utmost good faith to act solely in the best interests of each of our clients. We strive to foster a healthy culture of compliance within all aspects of our business. Further, we expect our employees to avoid potential conflicts of interest or even the appearance of such conflicts. These principles represent the expected basis of all dealings with clients. Our Code outlines the standards of conduct expected of our employees and includes limitations on personal trading, giving and accepting gifts, serving as a director or trustee for an external organization, participating in external investment organizations and engaging in outside business activities. In addition, employees are prohibited from using nonpublic inside information to trade in personal accounts or on behalf of our clients. We require all employees to obtain preapproval for trading certain types of securities. In addition, our Code requires all employees to report certain transactions quarterly and security holdings initially upon employment and on an annual basis thereafter. Employees are permitted to buy and sell securities they also recommend for purchase and sale to our clients. This may create an incentive for employees to place their own interests ahead of our clients. To mitigate this risk, our Code requires employees to obtain preapproval for certain types 11 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 of securities and to routinely report personal transactions and holdings. However, due to the immaterial nature of our employee’s ownership interests in these securities and the size and nature of the individual securities managed by the employee, we believe our employees’ personal trading activity has a negligible impact on the value of these securities. A copy of our Code is available upon request. Item 12 Brokerage Practices Selection of Brokers To efficiently service our clients’ accounts, we have established custodial and brokerage relationships with two organizations: Schwab and Transamerica. Schwab provides custody services for the majority of our clients’ assets. Our clients who choose an alternative custodian may pay additional advisory or custodial fees. From time to time, a client may hold an annuity, and The MilWealth Group generally recommends our client hold that annuity through Transamerica (variable annuities). The choice of the underlying insurance company is determined by Transamerica. Our determining factors in choosing brokers include but are not limited to: quality of execution; record-keeping and reporting; servicing capabilities; custody fees; and transaction costs. Our clients may pay additional trading costs if we place transactions through a broker not affiliated with the client’s custodian. For this reason, we take into consideration these additional trading costs when placing trades for client portfolios, and this consideration typically results in placing trades through the client custodian’s affiliated broker. In rare instances, we may believe the broker we normally use to execute trades is not suitable for a specific trade. In such situations, we will attempt to locate a more suitable broker. Research & Other Soft Dollar Benefits We participate in Schwab’s institutional adviser program. There is no direct link between our participation in the Program and the investment advice we give to our clients, although we receive economic benefits through our participation in the Program that are typically not available to Schwab retail investors but are available to all investment advisers who participate in the Program. We use standard technology and research services provided by Schwab to service client accounts which includes services related to trade execution, clearance and settlement functions, trading software and general economic commentary and analyses. Other benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and confirmations; research-related products and tools; electronic document signing software; consulting services; access to a trading desk serving our clients; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to 12 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 client accounts); the ability to have advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to The MilWealth Group by third-party vendors. Schwab also may provide complementary conference registration fees to The MilWealth Group. All services provided by Schwab are available to all participating advisors and may be used to service all of The MilWealth Group’s accounts. Trade Aggregation Due to the nature of the securities in which we actively trade (specifically, mutual funds, ETFs and US Treasury bonds) and the firm’s investment philosophy to consider each client’s needs and objectives, securities held in client accounts are generally traded on an individual basis. When we decide it is in our clients’ best interest, we will aggregate (or “block”) ETF trades. This will generally occur when we buy or sell an ETF across multiple client accounts. If a block order is filled (full or partial fill) at several prices through multiple trades, an average price will be calculated for all trades executed by the broker for the block, and all participants in the block trade will receive the average price. Only trades executed within the block on the single day may be combined for purposes of calculating the average price. On the rare occasion where the firm receives a partial fill, the partial fill may be allocated on a pro rata basis, subject to rounding and reasonable efforts to minimize trading costs. Trade Errors It is our policy to ensure clients are made whole following any trade error. When we cause a trade error to occur in a client account that results in a loss, we will reimburse the client, unless the executing broker’s policy is to absorb de minimis losses (e.g., under $100). If a trade error results in a gain, the client shall keep the gain, unless the executing broker’s or other third party’s (responsible for processing errors) policy is to: a) offset the gain against losses within a certain number of days; b) retain; or c) donate to charity. We maintain policies and controls surrounding trade errors, designed to provide reasonable assurance trade errors are properly addressed. Courtesy Trades We may, at times, execute trades within the client’s custodial account upon receipt of written or verbal direction from a client as a courtesy. While we discourage the extensive use of such “courtesy trades” we provide reports on such assets and include all assets held within the client’s custodian account (including assets purchased via courtesy trades) within our fee calculation. 13 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 Item 13 Review of Accounts Nature and Frequency of Reviews We provide an initial investment review for all of our new clients, and our advisors conduct an ongoing review at least annually. Significant market events, changes in client circumstances, requests by our clients, or at the suggestion of a client service professional may trigger an advisor to review. Client Reports All of our clients receive regular account statements from their respective custodians. Transamerica sends quarterly account statements that provide quarter-end investment balances as well as details of all account activity during the quarter. Schwab sends monthly account statements for accounts with qualifying activities of deposits, withdrawals, trades, stock dividend distributions and reinvestments that provide month-end investment balances as well as details of all account activity during the month. If a Schwab account does not have qualifying activities, then Schwab sends quarterly account statements that provide quarter-end investment balances as well as details of all account activity during the quarter. We periodically send a communication piece which is primarily an educational tool for clients. Item 14 Client Referrals and Other Compensation We receive consulting services and invitations to investor symposiums from sponsors of mutual funds and ETFs we use in client accounts. We understand these benefits are part of the sponsors’ standard offerings. We do not receive any compensation for utilizing any fund or ETF in a client portfolio. We may invite clients to attend the symposiums with us. These services provide an incentive for us to continue to place client assets in these products. We employ a disciplined investment process which results in utilizing those funds and ETFs we believe are in the best interest of our clients. Further, we maintain policies and procedures to address such conflicts of interest. Financial professionals are compensated with a salary and may receive a discretionary bonus. Compensation is based on how well they service our clients, individual performance and firm performance. Owners of the firm share in firm profits. Any recommendation to manage assets creates some conflicts with your interests as the recommendation leads to revenue for the firm. 14 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 Item 15 Custody We do not maintain custody of client assets, except as a consequence of our ability to withdraw our advisory fee directly from client accounts and our ability to direct transactions to third parties’ contingent upon a signed standing letter of authorization from a client and certain other requirements being met. We have written authority from these clients to engage in these transactions and comply with the appropriate regulatory guidance. In addition, all transactions are fully disclosed on client account statements sent by the qualified custodian. We encourage you to review these statements carefully. We send statements to clients on an as needed or by request basis. We also maintain policies and procedures designed to provide reasonable assurance our client’s qualified custodian is sending monthly and quarterly statements to our clients and that we do not inadvertently obtain further custody over client assets. We encourage clients to compare information in our reports to reports provided by the client’s qualified custodian. We have no affiliated qualified custodians. Item 16 Investment Discretion We provide portfolio management services on a discretionary and non-discretionary basis. All accounts are subject to a written investment advisory agreement which describes investment authority, fees and other matters. Item 17 Voting Client Securities We do not vote proxies on behalf of its clients. We or the custodian send all proxy materials directly to our clients, who are responsible for voting proxies. Upon our client’s request, we will provide advice and information to clients to assist you in making a determination of how to vote a specific proxy. The final decision of how to vote a proxy, however, rests with our client. Item 18 Financial Information We have no financial conditions to disclose which would impair our ability to meet our contractual commitments to our clients. Other Information We do not participate in legal proceedings, including class actions, on behalf of our clients. Our CCO, Matt Miler, serves as Managing Partner and Advisor which could result in competing priorities. The MilWealth Group maintains policies, procedures and controls to assist in mitigating this conflict, and does not believe it results in unfair treatment of its clients. 15 The MilWealth Group, LLC Form ADV Part 2A March 25, 2026 Privacy Notice Our Commitment to You When you become a client of The MilWealth Group you entrust us with not only your financial assets but also with personal information about you. We treat this information as confidential and recognize the importance of protecting access to it. The Type of Information We Collect About You In the course of doing business with our clients, we collect nonpublic information about you. You typically provide personal information when you become a client or when you request a transaction that involves The MilWealth Group. This nonpublic information may include information regarding your name and address, social security number, assets, income, account balance, bank account information, personal tax information and investment activity. What We Do With Your Personal Information We do not sell information about our current or former clients to third parties, and we do not disclose it to third parties unless requested by our client or necessary to process a transaction, service an account, or as permitted by law. We may share information with companies that perform administrative services for us. However, our contracts restrict the companies from using our client information for any other purpose than that for which they have been hired. How We Safeguard Your Personal Information To protect your personal information, we maintain physical, electronic and procedural safeguards to guard your personal information. Our Privacy Policy, which applies to all our employees, restricts the use of client information and requires that it be held in strict confidence. We’ll Keep You Informed If we change our Privacy Policy with regard to disclosing your confidential information, we are required by law, to notify you and provide you a revised notice. Should you have any questions regarding our privacy policy, please contact us at 414-475-1369. 16

Frequently Asked Questions