THE PINES WEALTH MANAGEMENT, LLC

The Pines Wealth Management, LLC Form ADV Part 2A – Disclosure Brochure Effective: August 14, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of The Pines Wealth Management, LLC (“TPWM” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (910) 475-8312 or via email at info@thepineswealth.com. TPWM is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about TPWM to assist you in determining whether to retain the Advisor. Additional information about TPWM and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 326353. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of TPWM. For convenience, the Advisor has combined these documents into a single disclosure document. TPWM believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. TPWM encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes This is the Advisors first annual amendment filing. There have been no material changes to this disclosure brochure since its last filing and distribution to clients in July 2024. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 326353. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (910) 475-8312. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page 1 Item 2 – Material Changes....................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................... 3 Item 4 – Advisory Services ..................................................................................................................................... 4 A. Firm Information .............................................................................................................................................................. 4 B. Advisory Services Offered ............................................................................................................................................... 4 C. Client Account Management ........................................................................................................................................... 6 D. Wrap Fee Programs ........................................................................................................................................................ 6 E. Assets Under Management ............................................................................................................................................. 6 Item 5 – Fees and Compensation ........................................................................................................................... 6 A. Fees for Advisory Services.............................................................................................................................................. 7 B. Fee Billing........................................................................................................................................................................ 7 C. Other Fees and Expenses .............................................................................................................................................. 8 D. Advance Payment of Fees and Termination ................................................................................................................... 8 E. Compensation for Sales of Securities ............................................................................................................................. 9 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................... 9 Item 7 – Types of Clients......................................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 9 A. Methods of Analysis ........................................................................................................................................................ 9 B. Risk of Loss ................................................................................................................................................................... 10 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 ............... 12 A. Code of Ethics ............................................................................................................................................................... 12 B. Personal Trading with Material Interest ......................................................................................................................... 12 C. Personal Trading in Same Securities as Clients ........................................................................................................... 12 D. Personal Trading at Same Time as Client .................................................................................................................... 12 Item 12 – Brokerage Practices ............................................................................................................................. 13 A. Recommendation of Custodian[s] ................................................................................................................................. 13 B. Aggregating and Allocating Trades ............................................................................................................................... 14 Item 13 – Review of Accounts .............................................................................................................................. 14 A. Frequency of Reviews ................................................................................................................................................... 14 B. Causes for Reviews ...................................................................................................................................................... 14 C. Review Reports ............................................................................................................................................................. 14 Item 14 – Client Referrals and Other Compensation ......................................................................................... 14 A. Compensation Received by TPWM .............................................................................................................................. 14 B. Compensation for Client Referrals ................................................................................................................................ 15 Item 15 – Custody .................................................................................................................................................. 15 Item 16 – Investment Discretion ........................................................................................................................... 15 Item 17 – Voting Client Securities ........................................................................................................................ 15 Item 18 – Financial Information ............................................................................................................................ 16 Form ADV Part 2A – Appendix 1 .......................................................................................................................... 17 Form ADV Part 2B – Brochure Supplement ........................................................................................................ 25 Form ADV Part 2B – Brochure Supplement ........................................................................................................ 28 Privacy Policy......................................................................................................................................................... 31 The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 3  Item 4 – Advisory Services A. Firm Information The Pines Wealth Management, LLC (“TPWM” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Delaware. TPWM was founded in March 2023 and became a registered investment advisor in March 2024. TPWM is owned and operated by Howell (Evans) Neville, CFP® (Founder, Principal and Wealth Manager) and Michelle (Shelly) C. Robinson, CFP® (Founder, Chief Compliance Officer, Principal and Wealth Manager). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by TPWM. For information regarding this Disclosure Brochure, please contact Michelle Robinson (Chief Compliance Officer) at (910) 500-0132 or via email at info@thepineswealth.com. B. Advisory Services Offered TPWM offers wealth management services including investment management and financial planning services to individuals, high net worth individuals, trusts, estates, charitable organizations, businesses, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. TPWM’ fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services TPWM provides customized wealth management services for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related planning and advisory services. TPWM works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. TPWM will then construct an investment portfolio, consisting of exchange-traded funds (“ETFs”) and/or mutual funds to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, individual bonds, unaffiliated money managers (See “Independent Managers” below), and/or other types of investments, as appropriate, to meet the needs of the Client. The Advisor may retain other types of investments from the Clinet’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. TPWM’ investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. TPWM will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. TPWM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. TPWM may recommend, on occasion, redistributing investment allocations to diversify the portfolio. TPWM may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. TPWM may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 4  At no time will TPWM accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Use of Independent Managers – TPWM will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Participant Account Management – As part of the Advisor’s Wealth Management Services, the Advisor will use a third-party platform to facilitate the discretionary investment management of held away assets such as defined contribution plan participant accounts. The platform enables the Advisor to gain access to the Client account[s] without having access through the Client’s login credentials. The Client will be provided an electronic link that will allow the connection of Client account[s] to the platform. The Advisor is not affiliated with the platform and does not receive any compensation from the platform. Financial Planning Services TPWM will typically provide a variety of financial planning and consulting services to Clients as part of its wealth management services. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. TPWM may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 5  recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services TPWM provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring Investment Oversight ● Vendor Analysis ● Plan Participant Enrollment and Education Tracking ● ● ● Ongoing Investment Recommendation and Assistance These services are provided by TPWM serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of TPWM’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging TPWM to provide wealth management services, each Client is required to enter into a wealth management agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – TPWM, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – TPWM will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. ● Portfolio Construction – TPWM will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – TPWM will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs TPWM includes securities transaction costs as part of its wealth management fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors the TPWM Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of December 31, 2024, TPWM manages $419,546,459 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 6  A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid monthly, advance of each month, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior month. Wealth management fees range up to 1.50% based on the following tiered fee schedule: Annual Rate (%) Assets Under Management ($) Up to $499,999 $500,000 to $999,999 $1,000,000 to $2,999,999 $3,000,000 to $4,999,999 $5,000,000 to $9,999,999 $10,000,000 t0 $19,999,999 $20,000,000 and above 1.50% 1.30% 1.00% 0.90% 0.80% 0.75% Negotiable The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may be offered a fixed annual rate or a fixed annual fee or a fee schedule that differs from above. Certain clients may also be charged additional fixed fees up to $500 for additional out-of-scope services. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by TPWM will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its wealth management fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The Advisor will allocate a portion of the advisory fee collected to the Independent Manager pursuant to the terms of the executed agreement between the Advisor and the Independent Manager. If the Client is required to authorize and enter into a wealth management agreement with an Independent Manage then the terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. Independent Managers may have a fee billing methodology or billing intervals that differ from the Advisor. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 0.75% and are billed quarterly in advance, pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees may be negotiable depending on the size and complexity of the Plan. B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the month. The amount due is calculated by applying the monthly rate (annual rate divided by 12) to the total assets under management with TPWM at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the wealth management fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by TPWM to be paid directly from their account[s] held The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 7  by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Use of Independent Managers For Client accounts implemented through an Independent Manager, the Client’s overall fees may include TPWM’ wealth management fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s]. TPWM includes Covered Costs as part of its overall wealth management fee through the TPWM Wrap Fee Program. Securities transaction fees for Client-directed trades may be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program Brochure. In addition, all fees paid to TPWM for wealth management services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of TPWM, but would not receive the services provided by TPWM which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by TPWM to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services TPWM may be compensated for its investment management services in advance of the month in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the month. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest or a Client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the Client or the Advisor and the Independent Manager. TPWM will assist the Client with the termination and transition as appropriate. Retirement Plan Advisory Services TPWM is compensated for its services at the beginning/end of the quarter before/after advisory services are rendered. Either party may request to terminate a retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for wealth management fees up to and including the effective date of termination. [OR if Advance] The Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the quarter. The Client’s retirement plan services agreement with the Advisor is non-transferable without the Client’s prior consent. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 8  E. Compensation for Sales of Securities TPWM does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the wealth management fees noted above. Certain Advisory Persons are also licensed as an independent insurance professionals. As an independent insurance professional, an Advisory Person may earn commission-based compensation for selling insurance products, including insurance products offered to Clients of the Advisor. Insurance commissions earned by Advisory Person are separate and in addition to our advisory fees. This practice presents a conflict of interest as an Advisory Person who is also an insurance agent may have an incentive to recommend insurance products to the Client for the purpose of generating commissions rather than solely based on the Client’s needs. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Please also see Item 10 below. Certain Advisory Persons is/are also a Registered Representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”), a registered broker-dealer (CRD# 35747) and member FINRA, SIPC. In an Advisory Person’s separate capacity as a Registered Representative, the Advisory Person may implement securities transactions through PKS and not through TPWM. In such instances, the Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by the Advisory Person, in one’s capacity as a Registered Representative, is separate and in addition to the Advisor’s fees. This practice presents a conflict of interest as the Advisory Person may have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on the Client’s needs. Clients are not obligated to implement any recommendation provided by the Advisor nor Advisory Persons. Neither the Advisor nor Advisory Persons will earn ongoing investment advisory fees in connection with any products or services implemented in the Advisory Person’s separate capacity as a Registered Representative. Please see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management TPWM does not charge performance-based fees for its wealth management services. The fees charged by TPWM are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. TPWM does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients TPWM offers wealth management services to individuals, high net worth individuals, trusts, estates, charitable organizations, businesses, and retirement plans. TPWM generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis TPWM primarily employs a fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from TPWM are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 9  these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that TPWM will be able to accurately predict such a reoccurrence. As noted above, TPWM generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. TPWM will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, TPWM may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. TPWM will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. There is also a risk that Authorized Participants are unable to fulfill their responsibilities. Authorized Participants are one of the major parties involved with ETF creation/redemption mechanism in the markets. The Authorized The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 10  Participants play a critical role in the liquidity of ETFs and essentially have the exclusive right to change the supply of ETF shares in the market. If the Authorized Participants does not fulfill this expected role, there could be an adverse impact on liquidity and the valuation of an ETF. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving TPWM or its management persons. TPWM values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 326353. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation As noted in Item 5, certain Advisory Persons are also Registered Representatives of PKS. In one’s separate capacity as a Registered Representative, the Advisory Person may receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by the Advisory Person. Neither the Advisor nor the Advisory Person will earn ongoing investment advisory fees in connection with any services implemented in the Advisory Person’s separate capacity as a Registered Representative. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 11  Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person’s role with TPWM. As an insurance professional, an Advisory Person may receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Advisory Persons or the Advisor. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more Independent Managers. The Advisor does not receive any compensation nor does this present a material conflict of interest. The Advisor will only earn its wealth management fee as described in Item 5.A. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics TPWM has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with TPWM (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. TPWM and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of TPWM’ Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (910) 475-8312 or via email at info@thepineswealth.com. B. Personal Trading with Material Interest TPWM allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. TPWM does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. TPWM does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients TPWM allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by TPWM requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While TPWM allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will TPWM, or any Supervised Person of TPWM, transact in any security to the detriment of any Client. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 12  Item 12 – Brokerage Practices A. Recommendation of Custodian[s] TPWM does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize TPWM to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, TPWM does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade- by-trade basis. Where TPWM does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost associated with using a custodian not recommended by TPWM. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. TPWM may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. TPWM may recommend the Custodian based on criteria such as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. As certain Advisory Persons are also Registered Representatives of PKS (Please see Item 10), PKS must approve the use of any outside broker-dealer/custodian. TPWM will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. TPWM maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. TPWM has established an institutional relationship with Schwab to assist the Advisor in managing Client account[s]. Access to the Schwab platform is provided at no charge to the Advisor. The Schwab platform includes brokerage, custody, administrative support, record keeping, technology and related services designed to support registered investment advisors like TPWM in serving Clients. These services are intended to serve the best interests of the Advisor’s Clients. Schwab may charge brokerage commissions (securities transaction fees) for effecting certain securities transactions. Schwab enables the Advisor to obtain certain no-load mutual funds without securities transaction fees and other no-load funds at nominal transaction charges. Schwab’s commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Schwab may be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14 below for additional information. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. TPWM does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - TPWM does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where TPWM will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). TPWM will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 13  B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. TPWM will execute its transactions through the Custodian as authorized by the Client. TPWM may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of TPWM Advisors and periodically by the CCO. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify TPWM if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by TPWM TPWM may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, TPWM may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform TPWM has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like TPWM. As a registered investment advisor participating on the Schwab Advisor Services platform, TPWM receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 14  to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to TPWM that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. TPWM believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody TPWM does not accept or maintain custody of any Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom TPWM exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct TPWM to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by TPWM to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Money Movement Authorization - For instances where Clients authorize TPWM to move funds between their accounts, TPWM and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Item 16 – Investment Discretion TPWM generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by TPWM. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by TPWM will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities TPWM does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. If the Client directs proxies to the Advisor, this action does not authorize or empower the Advisor to vote proxies on the Client’s behalf The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 15  Item 18 – Financial Information Neither TPWM, nor its management, have any adverse financial situations that would reasonably impair the ability of TPWM to meet all obligations to its Clients. Neither TPWM, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. TPWM is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 16  The Pines Wealth Management, LLC Form ADV Part 2A – Appendix 1 (“Wrap Fee Program Brochure”) Effective: August 14, 2025 This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices for The Pines Wealth Management, LLC (“TPWM” or the “Advisor”) services when offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the TPWM Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not receive the complete TPWM Disclosure Brochure or you have any questions about the contents of this Wrap Fee Program Brochure or the TPWM Disclosure Brochure, please contact the Advisor at (910) 475-8312 or via email at info@thepineswealth.com. TPWM is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Wrap Fee Program Brochure provides information about TPWM to assist you in determining whether to retain the Advisor. Additional information about TPWM and its advisory persons are available on the SEC’s website at www.adviserinfo.sec.gov by searching the Advisor’s firm name or CRD# 326353. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 17  Item 2 – Material Changes Form ADV 2A - Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the Wrap Fee Program offered by the Advisor. Material Changes This is the Advisors first annual amendment filing. There have been no material changes to this disclosure brochure since its last filing and distribution to clients in July 2024. Future Changes From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Wrap Fee Program Brochure (along with the complete TPWM Disclosure Brochure) or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of TPWM. At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name or CRD# 326353. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (910) 475-8312 or via email at info@thepineswealth.com. Item 3 – Table of Contents Item 2 – Material Changes Item 3 – Table of Contents Item 4 – Services Fees and Compensation Item 5 – Account Requirements and Types of Clients Item 6 – Portfolio Manager Selection and Evaluation Item 7 – Client Information Provided to Portfolio Managers Item 8 – Client Contact with Portfolio Managers Item 9 – Additional Information 18 18 19 20 20 22 22 22 The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 18  Item 4 – Services Fees and Compensation A. Services The Pines Wealth Management, LLC (TPWM” or the “Advisor”) provides customized wealth management services for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the TPWM Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full details of the business practices and fees when selecting TPWM as your investment advisor. As part of the wealth management fees noted in Item 5 of the Disclosure Brochure, TPWM includes securities transaction fees (herein “Covered Costs”) as part of the overall wealth management fee. Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”. The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of Covered Costs into a single “bundled” wealth management fee. This Wrap Fee Program Brochure references back to the TPWM Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on TPWM’ investment philosophy and related services. B. Program Costs Advisory services provided by TPWM are offered in a wrap fee structure whereby Covered Costs are included in the overall wealth management fee paid to TPWM. As the level of activity in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the Covered Costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on services to be provided to each Client, however, the Client is not charged more if there is higher trading activity or other Covered Costs. A Wrap Fee structure presents a conflict of interest as the Advisor is incentivized to limit the number of trades placed in the Client’s account[s] or to utilize securities that do not have transaction fees. Therefore, the Advisor is incentivized to utilize ETFs and other equity securities to limit the overall cost to the Advisor. The Advisor will only place Client assets into a Wrap Fee Program when it is believed to be in the Client’s best interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees. C. Fees Wealth management fees are paid monthly, advance of each month, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior month. Wealth management fees range up to 1.50% based on the following tiered fee schedule: Annual Rate (%) Assets Under Management ($) Up to $499,999 $500,000 to $999,999 $1,000,000 to $2,999,999 $3,000,000 to $4,999,999 $5,000,000 to $9,999,999 $10,000,000 t0 $19,999,999 $20,000,000 and above 1.50% 1.30% 1.00% 0.90% 0.80% 0.75% Negotiable The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may be offered a fixed annual rate or a fixed annual fee. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by TPWM will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. As noted above, the Wrap Fee Program includes Covered Costs incurred in connection with the discretionary investment management services provided by TPWM, as part of its overall wealth management fee. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 19  In addition, all fees paid to TPWM for wealth management services or part of the Wrap Fee Program are separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. Securities transaction fees for Client- directed trades will be charged back to the Client. In connection with the discretionary investment management services provided by TPWM, the Client will incur other costs assessed by the Custodian or other third parties, other than the Covered Costs noted above, such as wire transfer fees, fees for trades executed away from the Custodian and other fees. The Advisor does not control nor share in these fees. The Client should review both the fees charged by the fund[s] and the fees charged by TPWM to fully understand the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included with this Wrap Fee Program Brochure). D. Compensation TPWM is the sponsor and portfolio manager of this Wrap Fee Program. TPWM receives wealth management fees paid by Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the management of the Client’s account[s]. Item 5 – Account Requirements and Types of Clients TPWM offers wealth management services to individuals, high net worth individuals, trusts, estates, charitable organizations, and businesses. TPWM generally does not impose a minimum account size for establishing a relationship. Please see Item 7 – Types of Clients in the Disclosure Brochure for additional information. Item 6 – Portfolio Manager Selection and Evaluation Portfolio Manager Selection TPWM serves as sponsor and as portfolio manager for the services under this Wrap Fee Program. Related Persons TPWM personnel serve as portfolio managers for this Wrap Fee Program. TPWM does not serve as a portfolio manager for any third-party Wrap Fee Programs. Performance-Based Fees TPWM does not charge performance-based fees for its wealth management services. The fees charged by TPWM are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. TPWM does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Supervised Persons TPWM Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure Brochure. Methods of Analysis Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the research and analysis methods employed by the Advisor. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. TPWM will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 20  lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. There is also a risk that Authorized Participants are unable to fulfill their responsibilities. Authorized Participants are one of the major parties involved with ETF creation/redemption mechanism in the markets. The Authorized Participants play a critical role in the liquidity of ETFs and essentially have the exclusive right to change the supply of ETF shares in the market. If the Authorized Participants does not fulfill this expected role, there could be an adverse impact on liquidity and the valuation of an ETF. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 21  call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on investment risks. Proxy Voting TPWM does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. If the Client directs proxies to the Advisor, this action does not authorize or empower the Advisor to vote proxies on the Client’s behalf. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 7 – Client Information Provided to Portfolio Managers TPWM is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also see the TPWM Privacy Policy (included after this Wrap Fee Program Brochure). Item 8 – Client Contact with Portfolio Managers TPWM is a full-service investment management advisory firm. Clients always have direct access to the Portfolio Managers at TPWM. Item 9 – Additional Information A. Disciplinary Information and Other Financial Industry Activities and Affiliations There are no legal, regulatory or disciplinary events involving TPWM or its management persons. TPWM values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 326353. Please see Item 9 of the TPWM Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the background of the Advisor and its Advisory Persons. Other Financial Activities and Affiliations Please see Item 10 – Other Financial Activities and Affiliation and Item 14 – Client Referrals and Other Compensation of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure). B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information TPWM has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This Code of Ethics applies to all persons subject to TPWM’ compliance program (our “Supervised Persons”). Complete details on the TPWM Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure). Investments in Review of Accounts Client accounts are monitored on a regular and continuous basis by Advisory Persons of TPWM under the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided in The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 22  Item 13 of the Form ADV Part 2A – Disclosure Brochure. Other Compensation Participation in Institutional Advisor Platform TPWM may recommend the Custodian based on criteria such as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. As certain Advisory Persons are also Registered Representatives of PKS (Please see Item 10), PKS must approve the use of any outside broker-dealer/custodian. TPWM will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. TPWM maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. TPWM has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like TPWM. As a registered investment advisor participating on the Schwab Advisor Services platform, TPWM receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Please see Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to TPWM that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. TPWM believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on additional compensation that may be received by TPWM or its Advisory Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program Brochure) provides details on any outside business activities and the associated compensation. Client Referrals from Solicitors The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Financial Information Neither TPWM, nor its management, have any adverse financial situations that would reasonably impair the ability of TPWM to meet all obligations to its Clients. Neither TPWM, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. TPWM is not required to deliver a balance sheet along with this Disclosure The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 23  Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 24  Form ADV Part 2B – Brochure Supplement for Howell (Evans) Neville, CFP® Founder, Principal and Wealth Manager Effective: August 14, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Howell (Evans) Neville, CFP® (CRD# 2404560) in addition to the information contained in the The Pines Wealth Management, LLC (“TPWM” or the “Advisor”, CRD# 326353) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the TPWM Disclosure Brochure or this Brochure Supplement, please contact us at (910) 475-8312 or via email at info@thepineswealth.com. Additional information about Mr. Neville is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2404560. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 25  Item 2 – Educational Background and Business Experience Howell (Evans) Neville, CFP®, born in 1971, is dedicated to advising Clients of TPWM as a Founder, Principal and Wealth Manager. Mr. Neville earned his Bachelor’s Degree from The University of North Carolina in 1993.. Additional information regarding Mr. Neville’s employment history is included below. Employment History: 03/2024 to Present 09/1994 to 03/2024 Founder, Principal and Wealth Manager, The Pines Wealth Management, LLC Resident Director - Wealth Management Advisor, Merrill Lynch, Pierce, Fenner & Smith Inc. CERTIFIED FINANCIAL PLANNER™ (“CFP®”) The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by CERTIFIED FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 87,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: ● Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; ● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real-world circumstances; ● Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and ● Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: ● Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and ● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 26  Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Neville. Mr. Neville has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Neville. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Neville. However, we do encourage you to independently view the background of Mr. Neville on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2404560. Item 4 – Other Business Activities Broker-Dealer Affiliation Mr. Neville is also a Registered Representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is a registered broker-dealer (CRD# 35747), member FINRA, SIPC. In Mr. Neville’s separate capacity as a Registered Representative, Mr. Neville will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr. Neville. Neither the Advisor nor Mr. Neville will earn ongoing investment advisory fees in connection with any products or services implemented in Mr. Neville’s separate capacity as a Registered Representative. Mr. Neville spends less than 10% of his time per month in her role as a Registered Representative of PKS. Insurance Agency Affiliations Mr. Neville is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Neville’s role with TPWM. As an insurance professional, Mr. Neville will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Neville is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Neville or the Advisor. Mr. Neville spends less than 10% of his time per month in this capacity. Item 5 – Additional Compensation Mr. Neville has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Neville serves as a Founder, Principal and Wealth Manager of TPWM and is supervised by Michelle Robinson, the Chief Compliance Officer. Ms.Robinson can be reached at (910) 500-0132. TPWM has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of TPWM. Further, TPWM is subject to regulatory oversight by various agencies. These agencies require registration by TPWM and its Supervised Persons. As a registered entity, TPWM is subject to examinations by regulators, which may be announced or unannounced. TPWM is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 27  Form ADV Part 2B – Brochure Supplement for Michelle (Shelly) C. Robinson, CFP® Founder, Chief Compliance Officer, and Principal and Wealth Manager Effective: August 14, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Michelle C. Robinson (CRD# 6434226) in addition to the information contained in the The Pines Wealth Management, LLC (“TPWM” or the “Advisor”, CRD# 326353) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the TPWM Disclosure Brochure or this Brochure Supplement, please contact us at (910) 475-8312 or via email at info@thepineswealth.com. Additional information about Ms. Robinson is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6434226. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 28  Item 2 – Educational Background and Business Experience Michelle C. Robinson, born in 1986, is dedicated to advising Clients of TPWM as a Founder, Chief Compliance Officer, Principal and Wealth Manager. Ms. Robinson earned a Bachelor’s Degree from Appalachian State University in 2010. Additional information regarding Ms. Robinson’s employment history is included below. Employment History: 03/2024 to Present Founder, Chief Compliance Officer, Principal and Wealth Manager, The Pines Wealth Management, LLC VP, Wealth Management Advisor, Merrill Lynch, Pierce, Fenner & Smith Inc. 10/2015 to 03/2024 CERTIFIED FINANCIAL PLANNER™ (“CFP®”) The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by CERTIFIED FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 87,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: ● Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; ● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real-world circumstances; ● Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and ● Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: ● Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and ● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®. Item 3 – Disciplinary Information The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 29  There are no legal, civil or disciplinary events to disclose regarding Ms. Robinson. Ms. Robinson has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Ms. Robinson. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Ms. Robinson. However, we do encourage you to independently view the background of Ms. Robinson on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6434226. Item 4 – Other Business Activities Broker-Dealer Affiliation Ms. Robinson is also a Registered Representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is a registered broker-dealer (CRD# 35747), member FINRA, SIPC. In Ms. Robinson’s separate capacity as a Registered Representative, Ms. Robinson will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by Ms. Robinson. Neither the Advisor nor Ms. Robinson will earn ongoing investment advisory fees in connection with any products or services implemented in Ms. Robinson’s separate capacity as a Registered Representative. Ms. Robinson spends less than 10% of her time per month in her role as a Registered Representative of PKS. Insurance Agency Affiliations Ms. Robinson is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Ms. Robinson’s role with TPWM. As an insurance professional, Ms. Robinson will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Ms. Robinson is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Ms. Robinson or the Advisor. Ms. Robinson spends less than 10% of her time per month in this capacity. Item 5 – Additional Compensation Ms. Robinson has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Ms. Robinson serves as a Founder, Chief Compliance Officer, Principal and Wealth Manager of TPWM. Ms. Robinson can be reached at (910) 500-0132. TPWM has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of TPWM. Further, TPWM is subject to regulatory oversight by various agencies. These agencies require registration by TPWM and its Supervised Persons. As a registered entity, TPWM is subject to examinations by regulators, which may be announced or unannounced. TPWM is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 30  Privacy Policy Effective: August 14, 2025 Our Commitment to You The Pines Wealth Management, LLC (“TPWM” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. TPWM (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. TPWM does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 31  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. TPWM shares Client information with Purshe Kaplan Sterling Investments, Inc. (“PKS”). This sharing is due to the oversight PKS has over certain Supervised Persons of the Advisor. You may also contact us at any time for a copy of the PKS Privacy Policy. No Not Shared Marketing Purposes TPWM does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where TPWM or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients TPWM does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (910) 475-8312 or via email at info@thepineswealth.com. The Pines Wealth Management, LLC 104 Bradford Village Court, Southern Pines, NC 28387 Phone: (910) 475-8312 * Fax: (910) 401-1539 | Website: https://thepineswealth.com Page 32