Thepartners Wealth Management

ThePARTNERS Wealth Management SEC File Number: 801-122637 ADV Part 2A - Disclosure Brochure Effective: March 23, 2026 This Form ADV 2A (Disclosure Brochure) provides information about the qualifications and business practices of ThePARTNERS Wealth Management, LLC (ThePARTNERS or the Advisor). If you have any questions about the contents of this Disclosure Brochure, please contact us at 800-324-3010. ThePARTNERS is an investment advisor registered with the U.S. Securities and Exchange Commission (the SEC). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration with the SEC does not imply a certain level of skill or training. This Disclosure Brochure provides information about ThePARTNERS to assist you in determining whether to retain it. Additional information about ThePARTNERS and its investment advisory representatives (IARs) is available on the SEC's website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 314816.  ThePARTNERS Wealth Management NW CORNER OCEAN AVENUE AND MISSION STREET, SECOND LEVEL, CARMEL BY THE SEA, CA 93921 Phone: (800) 324-3010 Item 2 Summary of Material Changes Form ADV 2 requires registered investment advisors to amend their disclosure brochure when information becomes materially inaccurate. If there are any material changes to an advisor’s disclosure brochure, the advisor is required to notify you and provide you with a description of the material changes. Since the last update made on October 24, 2025, the following updates were made: - Item 5 – Fees and Compensation: Clarified disclosure regarding platform fees, including applicability to both wrap and non-wrap accounts, and updated fee descriptions associated with third-party investment managers and platform services. In addition, the Firm does not issue refunds on new client agreement. - Item 9 – Disciplinary Information: Added disclosure regarding a regulatory matter involving a member of Firm management that occurred at a prior unaffiliated firm. - Other Updates: Certain non-material clarifications, enhancements, and formatting updates were made throughout the Brochure to improve readability and transparency.  Item 3 Table of Contents Item 2 Summary of Material Changes ........................................................................................... 2 Item 3 Table of Contents ............................................................................................................... 3 Item 4 Advisory Business .............................................................................................................. 4 Item 5 Fees and Compensation .................................................................................................. 10 Item 6 Performance-Based Fees and Side-By-Side Management................................................ 14 Item 7 Types of Clients ................................................................................................................ 14 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 12 Item 9 Disciplinary Information .................................................................................................... 15 Item 10 Other Financial Industry Activities and Affiliations ............................................................ 15 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....... 18 Item 12 Brokerage Practices ....................................................................................................... 19 Item 13 Review of Accounts ........................................................................................................ 20 Item 14 Client Referrals and Other Compensation ....................................................................... 21 Item 15 Custody .......................................................................................................................... 23 Item 16 Investment Discretion ..................................................................................................... 23 Item 17 Voting Client Securities ................................................................................................... 24 Item 18 Financial Information ...................................................................................................... 24  Item 4 Advisory Business Firm Information ThePARTNERS Wealth Management, LLC does business under the name ThePARTNERS Wealth Management (ThePARTNERS or the Advisor), and is an investment advisor registered with the U.S. Securities and Exchange Commission (the SEC). It is organized as a limited liability company under the laws of the State of Delaware. ThePARTNERS was founded in March 2021 and is primarily owned by Gregory Rutherford through various entities and trust vehicles. These entities are owned in whole or part by individuals who are affiliated with ThePARTNERS, and certain of these entities also own ELITE TAMP, LLC (ELITE TAMP) and Adaptive Investments (Adaptive), which are affiliates of ThePARTNERS. This Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services provided by ThePARTNERS. For information regarding this Disclosure Brochure, please contact Jeffrey Smith, Chief Compliance Officer at compliance@thepartnerswm.com. Amplify Platform ThePARTNERS investment adviser representatives utilize the Amplify Platform, the Amplify Platform provides back-office operational support services such as administrative, trading, and reporting services and/or gain access to and select from independent third-party managers available through the Amplify Platform. Upon executing the Platform Agreement, the investment adviser firm or investment professional shall be considered a Platform Member. Platform Members may choose to receive certain back-office services, such as administrative, trading and reporting services and/or to select independent third-party managers to manage underlying client assets on a sub-advisory basis. Platform Members may choose to allocate all or a portion of their underlying client’s assets among the different independent third-party investment managers (“TPIMs”) available through the Amplify Platform on a discretionary basis. Platform Members shall have a direct contractual relationship with each of their underlying clients and obtain, through such agreements, the authority to engage Amplify Platform for services rendered through the Platform. ThePARTNERS engages unaffiliated investment advisers to service Platform Members as unaffiliated “TPIMs” available through the Amplify Platform will perform discretionary investment management services and shall manage, invest and reinvest the Platform Member’s underlying client assets designated by the Platform Member. As such, a selected manager(s) shall be authorized, without prior consultation with the Platform Member or the underlying client, to buy, sell trade or allocate the underlying client’s assets in accordance with the underlying client’s investment objectives and to deliver instructions in furtherance this responsibility to the underlying client’s broker-dealer and or custodian. Platform Members retain responsibility for the underlying client relationship, including the initial and ongoing suitability determination. Platform Members shall also retain the responsibility for implementing client investment recommendations in accordance with the Platform Member’s fiduciary duty to the underlying client. Platform Members are responsible for obtaining and furnishing information pertaining to sub-advisor selection and underlying client account guidelines along with any reasonable account restrictions.  Please note: ThePARTNERS’ investment adviser representatives are required to utilize the various services available through the Amplify Platform. Therefore, ThePARTNERS clients will incur platform fees in addition to advisory fees in connection with services provided through the Amplify Platform, as described in Item 5. Advisory Services Offered ThePARTNERS offers investment advisory services to individuals, families, trusts, estates, businesses, investment and retirement plans (each, a Client). ThePARTNERS provides comprehensive management, planning, and consulting services designed to meet the individual needs of each Client. ThePARTNERS investment advisory services may be customized or based on model portfolios (Models) firms (Model Providers). developed by ThePARTNERS, an IAR, or third-party management ThePARTNERS also sponsors an optional Wrap Fee Program as described below and in the Wrap Fee Program Brochure available separately. Investment Advisory Services ThePARTNERS provides investment advisory solutions for its Clients either on a tailored, customized basis, via the use of Models, or via engagement of outside investment management firms (Third Party Investment Managers or TPIMs (described below)). ThePARTNERS endeavors to maintain personal Client contact while providing discretionary investment management and related advisory services. ThePARTNERS works with Clients to identify their investment goals and objectives as well as analyze their risk tolerance and financial situation to identify an appropriate investment strategy. ThePARTNERS will then construct a customized portfolio strategy, manage the Client’s accounts based on internally developed Models, or on third-party Models, or direct Client assets to TPIMs for their discretionary management. TPIM are available via the Amplify Platform, direct with the Manager or via the approved Custodians. Internal Investment Management - ThePARTNERS may customize investment management services for its Client’s or it may manage Client accounts using Models. In each case, Client portfolios are primarily constructed using mutual funds, exchange-traded funds (ETFs), individual stocks, and fixed-income securities. The Advisor may also utilize other types of investments, as appropriate, to seek to meet the needs of each particular Client. The Advisor may retain legacy securities (i.e., securities held in a Client’s account prior to becoming subject to the Adviser’s management services) due to portfolio fit and other considerations. ThePARTNERS' investment strategy is primarily long-term focused, but it may buy, sell, or re-allocate positions that have been held less than one year to seek to meet the objectives of the Client, due to market conditions, or as ThePARTNERS’ deems prudent under the circumstance. In some cases, including when managing accounts using TPIMs, the Advisor may manage a Client’s account using an investment strategy that utilizes frequent trading in securities, as outlined in Item 8 below. 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. Clients grant full discretion to ThePARTNERS to purchase, hold, and sell securities in their portfolio, and to use one or more Models, to change Models, and to hire, replace, and fire Model Providers. ThePARTNERS recommendations for a custom-managed account will be made in a manner consistent with the account’s investment objective, strategy, and restrictions, if any. Accounts managed in accordance Models will generally align with the overall changes to the Models, subject to any reasonable Client-imposed restrictions. ThePARTNERS will not accept nor maintain direct custody of a Client's funds or securities; provided that, through its authorized deduction of fees, it will be deemed to have custody (indirectly) of Client funds. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms  of the investment advisory agreement. Additional Third-party Model Providers may provide Models to ThePARTNERS via its affiliate, ELITE TAMP or through other third-party TAMP (turnkey asset management provider) platforms including the Amplify Platform. The TAMPs will generally trade and rebalance Client accounts. Model Providers will not receive any information about your investment or financial goals and will not provide you individualized investment advice. Use of TPIM - ThePARTNERS may recommend to Clients that all or a portion of their investment portfolio be managed by one or more Third-Party Investment Manager. TPIMs may be accessed through Amplify, or direct with a custodian (Schwab or Fidelity) or may directly engaged by ThePARTNERS. The Client may be required to enter into a separate agreement with each TPIM. Please see Item 10 for additional information. Generally, with TPIM, ThePARTNERS serves as the Client's primary advisor and relationship manager. However, each TPIM will assume discretionary authority for the day-to-day investment management of those assets placed in their control. ThePARTNERS will assist and advise the Client in establishing investment objectives for their account, the selection of the TPIM, and defining any restrictions on the management of the account. ThePARTNERS will provide oversight of the Client's account[s] and monitor the activities of each TPIM. Each TPIM will manage assets allocated to them based on the selected investment strategy(ies). The Client may be able to impose reasonable investment restrictions on the TPIM’s management of these accounts, subject to the acceptance of the restrictions by the TPIM. ThePARTNERS compensation from these TPIM, if any, is limited to ThePARTNERS’ advisory agreement set forth in the Client’s investment management agreement (see Item 5). If the requisite Investment Advisory Agreement TPIM has been completed, ThePARTNERS has the authority to hire, replace, and fire TPIMs to manage Client accounts using different investment strategies. Financial Planning and Consulting Services ThePARTNERS may provide financial planning and consulting services to Clients. Financial planning and consulting services are provided via an agreement separate from the investment management agreement. Generally, such financial planning services will involve preparing a financial plan or rendering a 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, estate planning, personal savings, education savings 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. ThePARTNERS may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of 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 months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a potential conflict between the interests of the Advisor and the interests of the Client. Clients are not obligated to implement any 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. Ultimately the Client has the discretion to decide whether  to implement the plan or recommendations and takes responsibility for this decision. Retirement Plan Advisory Services When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. ThePARTNERS may serve as an ERISA 3(21) Fiduciary to retirement plans (each, a Plan) in support of the Plan Sponsor. ThePARTNERS may provide the following Plan Fiduciary Services pursuant to the terms of the Advisor's advisory agreement with each Plan Sponsor: • Vendor Analysis • Employee Enrollment and Education Tracking Investment Policy Statement • • Investment Monitoring • Performance Reports • Ongoing Investment Recommendation and Assistance • ERISA 404(c) Assistance • Benchmarking Services The specific services will be outlined in a separate retirement plan advisory agreement entered into between ThePARTNERS and the Plan Sponsor. This agreement is separate from ThePARTNERS’ investment management agreement with its advisory Clients. ThePARTNERS does not provide 3(38) discretionary investment advisory services on behalf of Plans or Plan Sponsors but may offer such services through its affiliate, Adaptive.  IRA Rollover Considerations As an investment advisor, we are and have acted as a fiduciary in our relationships with our clients. We follow the fiduciary standard required by the provisions of the Investment Advisor’s Act of 1940. A recommendation to take a distribution from a plan or to transfer (or withdraw from) an IRA are fiduciary acts. As such, the recommendation must be prudent and in the best interest of the participant or IRA owner. Providing education regarding distribution options is an important consideration for selecting among those options. The following is a discussion of those options and considerations. As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because persons providing investment advice on our behalf have the incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of: An employee will typically have four options: Leaving the funds in your employer's (former employer's) plan. Moving the funds to a new employer’s retirement plan. Cashing out and taking a taxable distribution from the plan. Rolling the funds into an IRA rollover account. 1. 2. 3. 4. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so: 1. 2. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs of those products and services.  3. 4. 5. 6. 7. 8. 9. 10. Our strategy may have higher risk than the option(s) provided to you in your plan. Your current plan may also offer financial advice. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required minimum distribution beyond age 73. Your 401k may offer more liability protection than a rollover IRA; each state may vary. a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. You may be able to take out a loan on your 401k, but not from an IRA. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this Disclosure Brochure. Client Agreements Prior to engaging ThePARTNERS to provide investment advisory services, each Client is required to enter into one or more advisory agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. Clients should review these agreements in detail prior to executing them. The services provided under investment management agreements may include: • Establishing an Investment Strategy - ThePARTNERS, in connection with the Client, will develop or select an investment strategy designed to enable the Client to seek to achieve the Client's investment goals and objectives. • Asset Allocation - ThePARTNERS may be engaged to develop a strategic asset allocation plan that is designed to meet the Client’s investment objectives, time horizon, financial situation and tolerance for risk. • Portfolio Construction - ThePARTNERS will develop or utilize a portfolio for the Client that is • designed to meet the stated goals and objectives of the Client. Investment Management and Supervision - ThePARTNERS will provide investment management and ongoing oversight of the Client's portfolio. • Financial Planning and Consulting – Please see the description above. • Retirement Plan Advisory Services – Please see the description above. Non-Wrap Fee or Wrap Fee Programs ThePARTNERS offers investment advisory services through either a wrap fee program or a non-wrap (transaction-based) program. The non-wrap program has additional costs for transactions The wrap fee program is generally used when the transaction costs may be substantial due to the types of products used or a significant amount of trading being performed. Clients pay the costs for securities transactions in the non-wrap program. The wrap fee program includes securities transaction fees together with its investment advisory fees. The Advisor sponsors ThePARTNERS Wrap fee Program through a separate brochure regarding the combination of fees. Investment advisory fees will be calculated by the Advisor or its delegate and deducted from the Client’s account(s) at the custodian. ThePARTNERS sends an invoice to the custodian providing the amount of the fees to be deducted from the Client’s account(s) for the applicable billing period. The amount due is calculated by applying the applicable rate (annual rate divided by the number of calendar days in the  applicable billing period divided by number of days in the applicable year) to the total assets, including any borrowed money via margin, under management with ThePARTNERS at the end of the prior billing period. • Important Disclosure Regarding Wrap Fee Program Accounts When making the determination of whether one of the advisory programs available through ThePARTNERS is appropriate for your needs, you should know that wrap accounts, when compared with non-wrap accounts, often result in lower costs during periods when trading activity is heavier or transactions costs are significant on certain products used in an account. However, during periods when trading activity is lower, or when products don’t incur transaction costs, the wrap fee-based account arrangement could result in a higher cost for transactions. Thus, depending on a number of factors, the total cost for transactions under a wrap-account versus a non-wrap account can vary significantly. In a wrap fee program, you generally pay a single asset-based fee that includes advisory services and certain transaction-related costs, whereas in a non-wrap arrangement you generally pay advisory fees and transaction charges separately; depending on trading activity and other factors, one structure may be more or less costly than the other. Factors which affect the total cost include the account size, amount of turnover, type and quantities of securities purchased or sold, transaction rates, and your tax situation. Additionally, you should know that fee-based accounts include the active management of your assets on an ongoing basis. You should know that lower fees for comparable service may be available from other sources when you don’t believe you need ongoing management of your assets. You should discuss the advantages and disadvantages of fee-based versus commission-based accounts with your IAR. Please note that any commission-based brokerage services are offered through the broker-dealer in your IAR’s separate capacity and are not provided by ThePARTNERS as an investment adviser. Assets Under Management As of January 31, 2026, ThePARTNERS has $1,181,424,638 discretionary assets under management and $2,575,131non-discretionary assets under management. Item 5 Fees and Compensation Fees for Advisory Services Investment Advisory Services One of ThePARTNERS’ Investment Adviser Representatives (IAR) will discuss the investment advisory fees when your account is established, and these fees will be outlined in the advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior billing period and are billed at an annual rate of up to 2.99%, depending on the level of assets being managed, the complexity of the services to be provided and/or the overall relationship with the Client. In addition to the investment advisory fee, the Client may also pay a platform fee of up to 0.25% annually. The platform fee is a separate fee for technology and administrative services used to manage Client accounts, including trading, rebalancing, performance reporting, billing, document maintenance, and asset aggregation, and generally applies to both wrap fee program and non-wrap advisory accounts, as applicable. The Client may also pay additional fees for a third-party Model Provider, TPIMs, or for the build-out of a client's unique custom portfolio model. These fees could be as high as 1% annually. In most cases, this type of investment management effort is provided through a Turnkey Asset Management Platform (TAMP), including through third-party turnkey asset management platform (“TAMP”) providers, such as our affiliate Elite TAMP, or other unaffiliated firms. ThePARTNERS’ fees are paid quarterly, in advance of each calendar quarter (the billing period), pursuant to the terms of the investment advisory agreement. Fees for the first partial billing period of service are  prorated from the inception date of the account[s] to the end of the first billing period. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may have a fixed annual fee or fixed rate fee or a fee schedule that differs from the above. The Client's fees will take into consideration the aggregate assets under management with Advisor. All securities held in accounts managed by ThePARTNERS will be independently valued by the Custodian. ThePARTNERS will not have the authority or responsibility to value portfolio securities. Clients should review their advisory agreement for additional information relative to fees and fee billing. ThePARTNERS’ fees cover only the advisory services provided by ThePARTNERS and IARs. Additional fees may be payable to Model Providers and TPIMs, as described in the investment management agreement. Model Provider and TPIM fees are subject to change depending on the Model, third-party Model Provider, TPIM, and TPIM investment strategy used to manage your assets. Please see below for more information about TPIM fees. The Client may make additions or withdrawals from the account[s] at any time, subject to ThePARTNERS' right to terminate an account or the overall relationship. Additions may be in cash or securities provided that the Advisor reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client's account[s]. Clients may withdraw account assets on notice to ThePARTNERS, subject to the usual and customary securities settlement procedures. However, ThePARTNERS typically designs its investment portfolios as long-term investments and the withdrawal of assets may impair the achievement of a Client's investment objectives. ThePARTNERS may consult the Client about the implications of such transactions. Clients are advised that when such securities are liquidated, they may be subject to securities transaction fees, short-term redemption fees, and/or may have tax ramifications. If assets in excess of $25,000 are deposited into or withdrawn from the Client's account[s], an adjustment will be made in the next billing period to reflect the fee difference. ThePARTNERS may negotiate a fee that differs from the schedule above for certain account[s] or holdings. ThePARTNERS charges a Platform fee in addition to its Advisory Fee and applies to advisory accounts as described in this Item 5. The Platform Fee is collected for the technology platform to help us manage, trade, rebalance, report performance, bill fees, maintain important documents and aggregate your assets. We bill accounts at of rate of 0.09% per year (0,0225% per quarter) for accounts solely managed by the Adviser Representative. Accounts that include any TPIMs, utilizing a Unified Managed Account (UMA) will be billed at a rate of 0.12% per year (0.03% per quarter). Third-Party Investment Manager (TPIM) Fees For a Client account where a TPIM is utilized, the TPIM fees will be billed independently from ThePARTNERS’ advisory and platform fee as described below. Financial Planning and Consulting Services Financial planning and consulting services are provided on either a one-time basis, or as an ongoing service engagement. For one-time engagements, fees will be charged at hourly rate of up to $400 per hour or as a fixed engagement. Fees are based on the experience of the person performing the services, the complexity and duration the services to be provided. An estimate for total hours and costs will be determined prior to engaging for these services. The Advisor's fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by the Client. Clients should review their financial planning and consulting services agreement for specific pricing, billing terms, and additional conditions governing these services. For ongoing financial planning services, fees are negotiated on a case-by-case basis. Retirement Plan Advisory Services Retirement plan advisory fees are paid quarterly, in advance of each calendar quarter (the billing period), pursuant to the terms of the retirement plan advisory agreement. Fees are generally based on the market value of assets in the Plan at the end of the prior billing period and charged at an annual rate of up to 1%. Fees may also be billed at a fixed annual rate. Clients should review their retirement plan advisory  agreement for additional terms and conditions for these services. Fee Billing Investment Advisory Services Investment advisory fees will be calculated by the Advisor, its delegate, or by TPIMs, and deducted from the Client's account[s] at the Custodian. The Advisor sends an invoice to the Custodian providing the amount of the fees to be deducted from the Client's account[s] for the applicable billing period. The amount due is calculated by applying the applicable rate (annual rate divided by the number of calendar days in the applicable billing period divided by the number of days in the applicable year) to the total assets under management with ThePARTNERS at the end of the prior billing period. Clients will be provided with statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian's brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting ThePARTNERS to be paid directly from their accounts held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Third-Party Investment Managers (TPIMs) on Amplify Platform Client accounts utilizing a TPIM(s) will be billed separately from ThePARTNERS advisory and platform fee. Fees for TPIM are billed in the second month of each quarter and will only be an estimate for that period. Upon the next billing cycle a “True Up” on the estimate will be calculated to compensate if the actual assets are higher or lower than the estimated amount. Specific fees for TPIMs available through the Amplify Platform are available to view at https://app.amplifyplatform.com/_f/pnyhceqa/programmanagers Use of TPIMs through custodians When using an TPIM available through the custodians, Fidelity and/or Schwab, these fees will be posted by the custodians and listed in the agreement signed by the client. ThePARTNERS does not share in these fees but continues to collect its Advisory and Platform fee on these accounts. Financial Planning and Consulting Services Please see the Financial Planning and Consulting Services fee disclosure above for a description of applicable hourly and flat-fee arrangements. Fees can be billed upon the execution of the financial planning and consulting agreement subject to the schedule defined in the agreement. Retirement Plan Advisory Services 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. Other Fees and Expenses Clients will incur securities transaction costs and may incur a platform fee separate from investment advisory fees charged by ThePARTNERS. Clients will also likely incur certain non-transactional fees or charges imposed by custodians or third parties in connection with accounts that are established and investments held in the Client's accounts. These fees and expenses include account maintenance fees, wire transfer fees, and other fees that are outlined in the Client’s account agreement with the custodian or third party. In addition, all fees paid to ThePARTNERS for investment advisory services are separate and distinct from the fees and expenses incurred or charged by mutual funds or ETFs, if applicable. These fees and expenses are described in each mutual fund's and ETF’s prospectus. These fees and expenses will  generally be an affiliate of ThePARTNERS. These fees may include but are not limited to, management fees, fund expenses and account administration fees. For more on the potential conflicts of interest, please see Conflicts of Interest in Item 9: Additional Information. Advance Payment of Fees and Termination Investment Advisory Services ThePARTNERS can be compensated for its investment advisory services in advance of the billing period in which services are rendered, pursuant to the terms of the investment advisory agreement. Either party may request to terminate the investment advisory agreement with ThePARTNERS at any time by providing advance written notice to the other party. The Client shall be responsible for investment advisory fees up to and including the effective date of termination. Advisory fees paid in advance are non-refundable, as provided in the applicable investment advisory agreement. . Use of TPIMs In the event that a Client should wish to terminate their relationship with an TPIM held through Amplify the terms for the termination will be set forth in the Investment Advisory Agreement. Any engagements with TPIMs not done through the Amplify Platform, termination will be done through the respective agreements between the Client and those TPIMs. Financial Planning and Consulting Services The Advisor is compensated for its financial planning and consulting services upon execution of the engagement agreement. Either party may terminate a planning agreement, at any time, by providing written notice to the other party. Upon termination, the Client shall be responsible for fees based on the hours worked by the Advisor or the percentage of the engagement completed. Upon termination, any unearned prepaid fees will not be refunded to the Client. Retirement Plan Advisory Services ThePARTNERS are compensated for their retirement plan advisory services in advance or arrears of the billing period in which services are rendered. Either party may request to terminate the retirement plan advisory agreement with ThePARTNERS, at any time, by providing advance written notice to the other party. The Client shall be responsible for advisory fees up to and including the effective date of termination. Upon termination, the Advisor will refund any unearned, prepaid fees to the Client within a reasonable time period. Compensation for Sales of Securities Investment Advisory Representatives (IARs) of ThePARTNERS may also be affiliated as Registered Representatives (“RRs”) of a broker-dealer that is independent of ThePARTNERS (the or a “BD”). When these individuals are acting as RRs, ThePARTNERS does not receive any compensation for securities transactions in any client brokerage accounts. ThePARTNERS and the BDsare not affiliated entities. The services provided by the BDs are separate and distinct from the services provided by ThePARTNERS. A RRs who is also an IAR with ThePARTNERS may implement securities transactions on a commission basis through its affiliation with the BD. In such instances, the IAR is acting as an RR of the BD and is solely under the supervision of the BD. The RR 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, through its affiliation with the BD. Compensation earned by an IAR in his or her capacity as a RR is separate and in addition to ThePARTNERS' advisory fees. This practice presents a conflict of interest if an IAR can earn more compensation from effecting securities transactions as compared to what can be earned from investment advisory services. To mitigate this conflict, ThePARTNERS discloses the different options the Clients have, supervises the opening of accounts, and assures Clients are under no obligation, contractually or otherwise, to purchase securities products through one of our IARs when acting as an RR. Further, ThePARTNERS will not charge an ongoing investment advisory fee on any assets implemented in the separate capacity of one of our IARs when  acting as an RR. Please see Item 10. IARs may also be licensed as independent insurance agents. IARs may earn commission-based compensation for selling insurance products, including insurance products they sell to clients. Insurance commissions earned by an IAR when acting as an insurance agent are separate and in addition to ThePARTNERS' advisory fees. Compensation earned by the IAR in his or her capacity as an insurance agent is separate and in addition to ThePARTNERS' advisory fees. This practice presents a conflict of interest if an IAR can earn more compensation from selling insurance as compared to what can be earned from investment advisory services. To mitigate this conflict, ThePARTNERS discloses the different options the Clients have, supervises the opening of accounts, and assures Clients are under no obligation, contractually or otherwise, to purchase insurance products through one of our IARs. Item 6 Performance-Based Fees and Side-By-Side Management ThePARTNERS does not charge performance-based fees for its investment advisory services. The fees charged by ThePARTNERS are as described in "Item 5 - Fees and Compensation" above. ThePARTNERS 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. However, depending upon client suitability and investment profile, an investment may be made mutual funds or ETFs managed by its affiliate, Adaptive. Please see Conflicts of Interest in Item 9: Additional information for more details. Item 7 Types of Clients ThePARTNERS offers investment advisory services to individuals, families, trusts, estates, and businesses. Once the Adviser updates its Form ADV, the relative percentage of each type of Client will be available on ThePARTNERS' Form ADV Part 1. These percentages will change over time. ThePARTNERS does not impose a size for establishing a relationship. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis & Investment Strategies ThePARTNERS' methods of analysis may include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis, and Technical analysis, as described in more detail below. • Charting analysis involves the use of patterns in performance charts. ThePARTNERS uses this technique to search for patterns used to help predict favorable conditions for buying or selling a security. • Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying or selling a security. • Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. • Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. factors as distinguished • Quantitative analysis deals with measurable from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and other factors. • Technical analysis involves the analysis of past market data; primarily price and volume.  Risk of Loss Investing in securities involves certain investment risks. Securities will fluctuate in value and may lose value. Clients should be prepared to bear the risk of loss, which will vary based upon market conditions and length of investment. ThePARTNERS and their IARs s assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee about any investment strategy’s performance, or that a Client will meet their investment goals. 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 or identify 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. 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. 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 Disciplinary Information In 2025, a member of the Firm’s management was involved in a regulatory matter with the U.S. Securities and Exchange Commission relating to activities at a prior unaffiliated firm. The matter was resolved through a settled administrative order. The matter did not involve client losses and has since been resolved. Public records regarding this matter are available through the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching our firm name or our CRD #314816. Item 10 Other Financial Industry Activities and Affiliations Conflicts of Interest ThePARTNERS’ goal is to provide non-conflicted advisory services to our Clients. However, certain aspects of our business do provide conflicts of interest due to the broader nature of the services we strive to provide to clients. We want to assure that we identify these conflicts so that our Clients can fully and fairly discuss them with their IARs, and make informed decisions. The material conflicts outlined below generally are presented based upon three broad categories - (i) affiliated transactions including commission-based insurance transactions; (ii) commission-based brokerage transactions through the BD; (iii) our efforts to recruit other IARs; and (iv) investments invested into Adaptive’s mutual funds or ETFs. These conflicts are outlined below and we encourage our Clients to discuss them with their IARs. Affiliate Conflicts Elite TAMP, LLC (Elite TAMP), is an affiliated investment advisor. ThePARTNERS and Elite TAMP have common control persons and ownership structures. Elite TAMP creates model portfolios (Models) and makes available Models created by third-party management firms. Elite TAMP also provides services, which may be used by IARs to develop their own Models. IARs may have an ownership interest in both ThePARTNERS and Elite TAMP, and to the extent that they do have ownership have an economic incentive to recommend the use of ThePARTNERS to open an account and Elite TAMP to provide Models. Clients should also be aware that certain conflicts of interest may exist should any IARs of ThePARTNERS (regardless of ownership) recommend that all or a portion of a Client's account be allocated to Models provided by Elite TAMP. A conflict of interest exists as those allocations will result in revenue being generated indirectly to individuals and entities that also have an interest in  ThePARTNERS. The investment management services provided by Elite TAMP may cost more or less than obtaining the same or similar services through an unaffiliated investment manager. No Client or IAR is under any obligation to utilize the services of Elite TAMP. The client may, at any time, impose reasonable restrictions, in writing, on ThePARTNERS’ investment recommendations or services, including Models made available by Elite TAMP. It is important to note that although Elite TAMP makes available Models, an IAR may take into consideration these Models to a limited extent or not at all. Clients should discuss with the IAR the investment strategy being deployed and fully understand the strategy or strategies being employed. The client may instruct their IAR to utilize a strategy that does not contain allocations to Elite TAMP Models or any other manager or investment. Adaptive Investments, LLC (Adaptive), is an affiliated registered investment advisor. ThePARTNERS and Adaptive have common control persons and ownership structure. Adaptive manages mutual funds and ETFs, and provides Models and other services that may be used by IARs to develop portfolios. These IARs may have an ownership interest in both ThePARTNERS and Adaptive, and to the extent that they do have ownership have an economic incentive to recommend the use of ThePARTNERS to open an account and Adaptive to provide Models or to allocate a portion of the Client’s assets to Adaptive ETFs. Clients should also be aware that certain conflicts of interest may exist should any IARs of ThePARTNERS (regardless of ownership) recommend that all or a portion of a Client's account be allocated to model portfolios or ETFs managed by Adaptive. A conflict of interest exists as those allocations will result in revenue being generated indirectly to individuals and entities that also have an interest in ThePARTNERS. The investment management services provided by Adaptive may cost more or less than obtaining the same or similar services through an unaffiliated investment manager. In addition, if all or a portion of a Client's account be allocated Adaptive-managed ETFs, the Client will bear the underlying costs of the ETFs. No Client or IAR is under any obligation to utilize the services of Adaptive [or invest in any Adaptive-managed ETF]. The Client may, at any time, impose reasonable restrictions, in writing, on ThePARTNERS' investment recommendations or services, including models provided by Adaptive or the use of mutual funds or ETFs managed by Adaptive. It is important to note that although Adaptive makes available its recommended investment models and strategies, mutual funds, and ETFs, an Advisor may take into consideration these models and products to a limited extent or not at all. Clients should discuss with the Advisor managing their account the investment strategy being deployed and fully understand the strategy or strategies being employed. The client may instruct their IAR to utilize a strategy that does not contain allocations to Adaptive model portfolios, Adaptive mutual funds, ETFs, or any other manager or model provider. Commission Based Securities Transactions As outlined above, ThePARTNERS' IARs may also act RR to conduct commission-based securities transactions through a BD. ThePARTNERS and your IAR act as fiduciaries with respect to your advisory account. Brokerage services are non-discretionary transactions such as securities trades and are paid for by commissions. With brokerage services your RR affiliated with the BD, and your representative owe you a duty to assure that any recommendations are suitable. Therefore, there is a different legal standard in addition to a different compensation structure between an investment advisory account and a brokerage account. through brokercheck.finra.org), the IAR can provide advisory services To the extent that an IAR is also registered as an RR with the BD (your IAR can tell you or the information is available through ThePARTNERS or brokerage services as an RR through the BD. This poses a conflict of interest to the extent that an IAR will earn more or less depending upon the nature of your account and the investments that are held in the account. Investments like mutual funds, ETFs, stocks and bonds that are bought and held for longer periods of time in a brokerage account, like an account available at the BD, will have a lower overall cost for this longer hold due to the lack of active management and additional management fees charged by the investment advisor managing the account. However, the actual cost will depend on the type of investment and how active a brokerage account is trading securities positions. Additionally, as noted above, there are different legal standards between advisory and brokerage accounts. The  difference in this legal standard will impact the disclosure of conflicts, the nature of investment recommendations, the obligation for ongoing monitoring of the account, and other legal obligations. Which type of account is best for you depends upon your individual circumstances and preferences. Our goal is to assure that Clients understand the options available and the difference in the types of accounts and investments that they may make. Advisor Transition Assistance ThePARTNERS may provide various benefits and payments (or loans) to IARs that are newly associated with ThePARTNERS to assist the IAR with costs associated with transitioning his or her business to ThePARTNERS (collectively referred to as Transition Assistance). The proceeds of Transition Assistance payments are intended to be used for a variety of purposes, including but not necessarily limited to, providing working capital to assist in funding the IAR's business, satisfying any outstanding debt to the IAR's prior firm, offsetting account transfer/termination fees as a result of the IAR's clients transitioning to one of custodial platforms with which ThePARTNERS has connectivity, technology setup fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space expenses, and staffing support. ThePARTNERS does not verify that any Transition Assistance funds made are actually used for such transition costs, and therefore, they may provide direct revenue to newly recruited IAR. Transition Assistance may be provided in the form of a cash advance to the IAR, by ThePARTNERS foregoing revenues during account transactions, through loans, or through other incentives to the IAR. Transition Assistance may also be provided subject to certain contractual obligations by the IAR, such as repayment of all or a portion of the payments if the IAR elects to leave ThePARTNERS or does not meet certain other obligations. The amount of Transition Assistance payments are often significant in relation to the overall revenue earned or compensation received by the IAR at his or her prior firm. Such payments are generally based on the size of the IAR's business established at his or her prior firm, for example, a percentage of the revenue earned or assets serviced by the IAR at the prior firm. These payments are generally in the form of payments or loans to the IAR with favorable interest rate terms as compared to other lenders, which are paid by ThePARTNERS or forgiven by ThePARTNERS based on years of service with ThePARTNERS (e.g., if the IAR remains with ThePARTNERS for 5 years) and/or the scope of business engaged in with ThePARTNERS. ThePARTNERS also makes payments to IARs in connection with the transition of certain advisory business to ThePARTNERS from his or her prior firm that is not approved on ThePARTNERS' platform. These payments are tied to the amount of client assets that are transitioned from an unapproved platform at the prior firm to ThePARTNERS' advisory program. The receipt of Transition Assistance creates a conflict of interest in that an IAR has a financial incentive to recommend that a client open and maintain an account with the IAR and ThePARTNERS for advisory services and to recommend changing investment products or services where a potential Client's current investment options are not available through ThePARTNERS, in order to receive the Transition Assistance benefit or payment. ThePARTNERS and its IARs attempt to mitigate these conflicts of interest by evaluating and recommending that clients use ThePARTNERS' services based on the benefits that such services provide to Clients, rather than the Transition Assistance earned by any particular IAR. However, we want to assure that potential Clients are aware of this conflict and take it into consideration in making a decision whether to establish or maintain a relationship with ThePARTNERS. As with all items in this Brochure, we also encourage Clients to discuss this item with their IAR. Item 10 Other Financial Industry Activities and Affiliations Neither the Advisor nor its associated persons (Supervised Persons) has any registrations or affiliations with a futures commission merchant, commodity pool operator, or commodity-trading advisor. IAR Broker-Dealer Affiliations As noted in Items 5.E. and 9, some IARs of ThePARTNERS may also be RR of a BD. In an IAR's separate capacity as a RR of the BD, an IAR will typically receive commissions for the implementation  of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an IAR. To the extent that an IAR earns commissions as a RR of a BD or supervises such transactions this business is solely through the BD, and ThePARTNERS does not participate in those transactions and receives no financial payments. Other Registered Investment Advisors Certain Managing Members and IARs of ThePARTNERS also own and/or provide advisory services through other independent registered investment advisory firms. The details of these relationships are included with the Form ADV 2B (Brochure Supplements) of the respective IARs. A Client may be offered financial planning, consulting or related advisory services from these firms. In such instances, the Client shall also receive the Form ADV 2A - Disclosure Brochure for the respective firm. To the extent that these services are being provided by a separate investment adviser, the services are being provided solely by that investment adviser which takes sole responsibility for the services. In those instances, ThePARTNERS does not participate in the provision of investment advice and does not approve or supervise the activities of other investment advisory firms. Third-Party Estate Planning Software Platform ThePARTNERS may make available to clients access to Estately, an independent third-party software platform that provides self-directed estate planning technology, templates, forms, and related tools for the preparation of wills, trusts, and similar documents. Estately is not affiliated with, owned by, or under common control with ThePARTNERS. ThePARTNERS does not supervise or control Estately’s services and does not assume responsibility for the accuracy, completeness, or quality of any documents, software, or content provided by Estately. ThePARTNERS does not provide legal or tax advice and does not prepare or review legal documents. Clients are solely responsible for determining whether any estate planning tools or documents are appropriate for their individual circumstances and should consult their own attorney or tax professional. ThePARTNERS and its representatives do not receive any compensation, referral fees, or economic benefit for introducing clients to Estately. Use of the platform is entirely optional and separate from the ThePARTNERS’ investment advisory services. Pontera ThePARTNERS utilizes a third-party vendor, Pontera Solutions, Inc. (“Pontera”), to facilitate asset management for assets held away from the firm’s primary custodians, such as defined contribution plans. ThePARTNERS does not have custody of these assets but does have discretionary authority to manage the asset allocation. Through this service, the client provides authorization to link their defined contribution plan to the Pontera platform, enabling ThePARTNERS’ Investment Adviser Representatives (“IARs”) to manage the asset allocation for a fee. The advisory fee applicable to these services is determined in an addendum to the Investment Advisory Agreement executed by the client. ThePARTNERS does not maintain client login credentials. All trading activity associated with these accounts is executed through the Pontera platform. ThePARTNERS does not receive any additional compensation for the use of Pontera. The only fee collected in connection with these services is the advisory fee described in the addendum to the Investment Advisory Agreement. IARs are responsible for meeting with clients on a regular basis to review asset allocation, performance, risk tolerance, investment objectives, and any new investments added to the plan. Based on these factors, IARs may implement changes to the asset allocation as deemed appropriate.  Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics ThePARTNERS has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of Ethics applies to all Supervised Persons. The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. ThePARTNERS and its personnel owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of ThePARTNERS 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 of Ethics covers a range of topics that address employee ethics and conflicts of interest. To request a copy of our Code of Ethics, please contact us at 800-324-3010. Personal Trading with Material Interest ThePARTNERS does not act as principal in any securities transactions. In addition, the Advisor does not act as the adviser to any mutual funds or ETFs. However, as noted above, affiliates of ThePARTNERS do act as the adviser to mutual funds and ETFs. ThePARTNERS does not have a direct material interest in any securities traded in Client accounts. The mitigation of the conflict with respect to affiliates that act as the advisor to mutual funds and ETFs is disclosed in Item 9 above. Personal Trading in Same Securities as Clients ThePARTNERS allows the purchase, holding, and sale of the same that may be purchased on behalf of Clients. Owning the same securities we purchase, hold or sell for your account, presents a potential conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted a Code of Ethics, which addresses insider trading (material non-public information controls) and personal securities reporting procedures. When trading for personal accounts, Supervised Persons of ThePARTNERS have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can potentially be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This conflict is managed by ThePARTNERS requiring Supervised Persons to report of personal securities trades for review by the Chief Compliance Officer ("CCO"). We have also adopted written policies and procedures to detect the misuse of material, non-public information. Personal Trading at Same Time as Client ThePARTNERS’ IARs may purchase or sale of the same securities for their own accounts at the same time as they are purchased or sold for your accounts. In that case, those trades are typically aggregated with Client orders or traded afterwards. This may provide an opportunity for IARs of ThePARTNERS to buy or sell securities before or after effect securities trades for client accounts resulting in representatives potentially profiting off the recommendations they provide to clients. Such transactions create a conflict of interest. However, to manage this conflict ThePARTNERS has procedures to avoid trading that operates to the Client's disadvantage if IARs buy or sell securities at or around the same time as clients. Item 12 Brokerage Practices Custodian[s] To the extent that you provide discretionary authority to ThePARTNERS, it is limited to executing securities transactions in your account as outlined in your investment advisory agreement. This "limited discretion" does not allow ThePARTNERS authority to open your broker-dealer/custodian account for custody and execution services. As such, you will need to agree to open an account with a broker-  dealer/custodian with which ThePARTNERS has an established relationship (herein the "Custodian") to safeguard your assets. Your account management agreement will authorize ThePARTNERS to direct trades to this Custodian as agreed in the investment advisory agreement. Your custodial agreement will set forth the terms of your relationship with the Custodian, including the costs of effecting transactions and for maintaining the account. While ThePARTNERS does not exercise discretion over the opening of an account with the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor. ThePARTNERS currently maintains institutional relationships with Fidelity Clearing & Custody Solutions, a related entity of Fidelity Investments, Inc. (collectively Fidelity), Charles Schwab & Co, Inc. (Schwab) and Axos Clearing, where the Advisor maintains institutional relationships. ThePARTNERS receives certain economic benefits from Fidelity, Schwab and/or Axos as detailed in Item 9 above and Item 14 below. Brokerage Referrals - ThePARTNERS does not receive any compensation from any third party in connection with the recommendation for establishing an account. Directed Brokerage The investment advisory agreements indicate that ThePARTNERS will generally place trades for Client accounts through the Client-selected broker (the Custodian). However, if ThePARTNERS reasonably believes in good faith that another broker or dealer will provide better execution considering all factors including the net price, then it may execute elsewhere. That is, the investment advisory agreement contemplates that trades will be made on a "directed brokerage basis,” where ThePARTNERS will generally place trades within the established accounts at a Custodian designated by the Client, unless instructed otherwise by the Client. 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]). In selecting the broker to effect transactions, ThePARTNERS 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. 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 order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. So, if ThePARTNERS reasonably believes in good faith that another broker or dealer (other than the Custodian) will provide better execution considering all factors including the net price, then it may execute elsewhere. ThePARTNERS may aggregate orders in a block trade or trades when securities are purchased or sold through the same Custodian for multiple (discretionary) accounts. 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 particular Client accounts. Item 13 Review of Accounts Frequency of Reviews As a matter of policy and practice, investments in client accounts are monitored on a regular and continuous basis by IARs of ThePARTNERS and periodically by The PARTNERS’ chief compliance officer (CCO). We provide account reviews as part of our Investment Advisory Services. Our IARs will seek to meet with clients either by phone or in person at least annually to review their accounts and update any changes in their financial profile. Reviews can be conducted more frequently when requested by the client or at our discretion.  Causes for Reviews Accounts may also be reviewed as a result of major changes in (i) economic conditions such as material market, economic or political events or (ii) known changes in the Client's financial situation, such as significant life events and/or large deposits or withdrawals in the Client's account. The Client is encouraged to notify ThePARTNERS if changes occur in the Client's personal financial situation that might adversely affect the Client's investment plan. Review Reports The Client will receive a brokerage statement from the Custodian no less than quarterly. 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. The Advisor and its IARs may also provide Clients with periodic reports regarding their holdings, allocations, and performance. However, the Custodian statements are the official reports of the Client's account. Please review these accounts as received to assure they appear accurate for both the positions and transaction effectuated in the account. Item 14 Client Referrals and Other Compensation Compensation Received by ThePARTNERS Participation in Institutional Advisor Platform Fidelity ThePARTNERS has established institutional relationship with Fidelity to be a preferred Custodian for Client accounts. This relationship assists us in managing Client accounts through aggregation of the accounts and use of a single operating system. Based upon this relationship, we have received access to software and related support. The software and related systems support provide direct benefit the Advisor, and may provide indirect benefits to the Clients through increased efficiencies. 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 the Custodian over one that does not furnish similar software, systems support, or services. Additionally, ThePARTNERS has received financial and other support from Fidelity to assist the Advisor in the launch and maintain its advisory firm. These benefits from Fidelity include reimbursement to Clients for costs charged by a previous custodian for transfer of the assets or account to Fidelity, financing services, receipt of duplicate Client confirmations and bundled duplicate statements at no cost, access to a trading desk that exclusively services its institutional participants, access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts, and access to an electronic communication network for Client order entry and account information. Schwab ThePARTNERS may recommend that clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at the discretion of the Advisor’s clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. ThePARTNERS is independently owned and operated and not affiliated with Schwab. Schwab provides ThePARTNERS with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent  investment advisors on an unsolicited basis, at no charge to advisors. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. to ThePARTNERS other products and services to ThePARTNERS other services intended Schwab also makes available that benefit ThePARTNERS but may not benefit its clients’ accounts. These benefits may include national, regional or ThePARTNERS specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of ThePARTNERS by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist ThePARTNERS in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of ThePARTNERS’ fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of ThePARTNERS accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to help ThePARTNERS manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to ThePARTNERS by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to ThePARTNERS. The availability of the foregoing products and services from Schwab creates a conflict of interest because ThePARTNERS has an incentive to recommend that clients maintain their assets in accounts at Schwab to receive these benefits. Clients should be aware that such recommendations may be influenced by the benefits received by ThePARTNERS and not solely by the nature, cost, or quality of Schwab’s custody and brokerage services. ThePARTNERS seeks to manage this conflict by disclosing it and acting in accordance with its fiduciary obligations. Schwab has eliminated commissions for online trades of equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab's pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter a wrap fee arrangement, your total cost to invest will likely exceed the cost of paying for brokerage and advisory fees separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab's most recent pricing schedules available at schwab.com/aspricingguide. PenChecks Certain Investment Adviser Representatives (“IARs”) of the Advisor may refer clients to PenChecks Trust, Inc. (“PenChecks”), an independent trust company that provides retirement plan distribution, rollover, and related services. Under this arrangement, PenChecks may compensate the referring IAR for client referrals. Neither ThePARTNERS nor its affiliates receive any direct compensation or benefit from PenChecks other than the referral arrangement described herein, and clients do not pay additional fees as a result of these referrals. This relationship creates a potential conflict of interest, as the referring IAR has a financial incentive to recommend PenChecks’ services. To mitigate this conflict, the Advisor requires that the relationship and compensation be fully disclosed to the client in writing prior to or at the time of the referral, that the client be informed that similar or comparable services may be available elsewhere at different costs, and that  no additional fees or charges be imposed on the client due to the referral. PenChecks provides services that assist retirement plan participants and fiduciaries in processing plan distributions, rollovers, and locating or recovering plan assets. The Advisor has reviewed this relationship and determined that it complies with applicable regulatory requirements. Expense Reimbursements We will occasionally receive expense reimbursements for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are typically the result of informal expense sharing arrangements in which product sponsors underwrite the costs incurred for marketing, such as, client appreciation events, advertising, publishing, and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are typically made by those sponsors for which sales have been made or for which it is anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of our clients. We attempt to control for this conflict by always basing investment recommendations and decisions on the individual needs of our clients. Item 15 Custody There are specialized rules pertaining to a registered investment advisor accepting or maintaining "custody" of Clients' assets. ThePARTNERS does not accept or maintain custody of any Client accounts or assets. Under government regulations, we are deemed to have custody of your assets in certain situations as described below. One situation occurs when you authorize the custodian to deduct our advisory fees directly from your account, even though the custodian maintains actual custody of your assets. A second situation occurs if you authorize us to direct checks or money transfers from your accounts to third parties, all dependent upon the authorization given to the custodian. A third situation may occur if a client inadvertently sends a check to ThePARTNERS that is not made payable to the qualified custodian. In such instances, ThePARTNERS does not accept or deposit the check and will promptly return or void it, and the client must reissue the check made payable directly to the qualified custodian. ThePARTNERS. In all cases, all clients are provided, at least quarterly, with written transaction confirmation notices and/or regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts. ThePARTNERS may also provide a written periodic report summarizing account activity and performance. Please Note: To the extent that ThePARTNERS provides clients with periodic account statements or reports, the client is urged to compare any statement or report provided by ThePARTNERS with the account statements received from the account custodian. Please Also Note: The account custodian does not verify the accuracy of ThePARTNERS’ advisory fee calculation. Item 16 Investment Discretion ThePARTNERS generally has full investment discretion over the selection of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. This discretion includes selecting the security, the quantity of a transaction, and the timing of transaction. It also extends to the hiring, firing, or change of TPIM. However, these purchases, sales, hirings, etc. may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by ThePARTNERS. The discretionary authority will be authorized only upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by ThePARTNERS will be in accordance with each Client's investment objectives and goals. Please note that this discretion is deemed to be "limited" to investment discretion, and ThePARTNERS does not have the authority to open an account, switch Custodians, or deposit or withdraw funds from an existing account (with the exception of  authorized withdrawals for payment of investment advisory fees). Item 17 Voting Client Securities ThePARTNERS does not vote proxies for any Client. Clients will receive proxy statements directly from the Custodian. If the Client directs proxy materials to the Advisor's attention, this does not result in the Advisor assuming responsibility for the voting of proxies. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 Financial Information Neither ThePARTNERS, nor its management, have any adverse financial situations that would reasonably impair the ability of ThePARTNERS to meet all obligations to its Clients. Neither ThePARTNERS, nor any of its IARs, has been subject to a bankruptcy or financial compromise. ThePARTNERS is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance, and therefore is not required to include a balance sheet with this brochure. A. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither ThePARTNERS nor its management has any financial condition that is likely to reasonably impair ThePARTNERS' ability to meet contractual commitments to clients. B. Bankruptcy Petitions in Previous Ten Years ThePARTNERS has not been the subject of a bankruptcy petition in the last ten years. 

ThePARTNERS Wealth Management SEC File Number: 801-122637 Wrap Fee Program Brochure Effective: March 23, 2026 This Wrap Fee Program Brochure provides information about the business practices and fees for ThePARTNERS Wealth Management (ThePARTNERS) when client (hereinafter referred to as “you”, “your” or the “Client”) transaction costs are included with investment advisory fees as a single bundled fee (a "Wrap Fee Program"). ThePARTNERS sponsors this Wrap Fee Program and provides this Wrap Fee Program Brochure as a supplement to the ThePARTNERS ADV Part 2A Disclosure Brochure, which provides complete details on the business practices of ThePARTNERS. If you did not receive the complete ThePARTNERS’ ADV Part 2A Disclosure Brochure or you have any questions about the contents of this Wrap Fee Program Brochure or the ThePARTNERS Disclosure Brochure, please contact Jeffrey Smith at compliance@thepartnerswm.com or by phone at (800) 324-3010. ThePARTNERS is an investment adviser registered with the U.S. Securities and Exchange Commission (the 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 adviser does not imply any specific level of skill or training. This Wrap Fee Program Brochure provides information about ThePARTNERS to assist you in determining whether to engage it as your investment adviser. information about ThePARTNERS and its advisory persons Additional (Investment Adviser Representatives) is available on the SEC's website at www.adviserinfo.sec.gov by searching for our firm name or by using our CRD# 314816. ThePARTNERS Wealth Management NW CORNER OCEAN AVENUE AND MISSION STREET, SECOND LEVEL, CARMEL BY THE SEA, CA 93921 Phone: (800) 324-3010 1  Item 2 Summary of Material Changes Form ADV Part 2A provides information about a variety of topics relating to ThePARTNERS’ business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the fee billing practices of the firm as a supplement to the Form ADV Part 2A Disclosure Brochure. Material Changes There are no material changes to report. Future Changes From time to time, we may amend this Wrap Fee Program Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Wrap Fee Program Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of ThePARTNERS. At any time, you may request a current copy of the Wrap Fee Program Brochure by contacting our Chief Compliance Officer, Jeffrey Smith at compliance@thepartnerswm.com or by phone at (800) 324-3010. 2  Item 3 Table of Contents Item 1 Cover Page Item 2 Summary of 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 Page 1 Page 2 Page 3 Page 4 Page 6 Page 6 Page 8 Page 8 Page 8 3  Item 4 Services, Fees, and Compensation Services ThePARTNERS Wealth Management ("ThePARTNERS" or the “firm”) provides customized investment management and related advisory services for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the ThePARTNERS 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 ThePARTNERS as your investment adviser. As part of the investment advisory fee noted in Item 5 of the Part 2A Disclosure Brochure, ThePARTNERS includes normal securities transaction fees and a platform 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 disclosures relating to the combination of securities transaction fees and a platform fee into the single "bundled" investment advisory fee. Please see Item 4 – Advisory Services of the Part 2A Disclosure Brochure for details on ThePARTNERS' investment philosophy and related services. For information regarding this ADV Part 2A Disclosure Brochure, please contact Jeffrey Smith, Chief Compliance Officer at compliance@thepartnerswm.com. Program Costs Advisory services provided by ThePARTNERS may be offered as a Wrap Fee Program whereby normal securities transaction costs are included in the overall investment advisory fee paid to ThePARTNERS. As the level of trading in a Client's account may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the transaction costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on the services to be provided to each Client, however, the Client is not charged more if there is higher trading activity in the Client's account. This wrap fee structure has a potential conflict of interest as we may have an incentive to limit the number of trades placed in Clients’ accounts to reduce our costs (a practice known as “reverse churning”). To address this conflict, we have adopted policies and procedures to ensure the wrap fee arrangement remains in your best interest. Our Investment Adviser Representatives (IARs) and our Chief Compliance Officer periodically review wrap fee accounts to assess trading activity. Specifically, accounts with minimal or no trading activity over an extended period (typically a calendar year) are flagged for a formal suitability review. This review is designed to determine if the level of portfolio management and trading activity justifies the wrap fee. If we determine the program may no longer be suitable, we will discuss with you whether a non-wrap advisory account or other arrangement would be more appropriate and cost- effective. Please note that for accounts with low trading activity, a wrap fee may cost more than paying for advisory services and transaction costs separately. Certain broker-dealers have lower transaction fees than other broker-dealers and as a result overall separate fees may be lower now than in the past in relation to these particular broker-dealers and custodians. Please see Item 5 - Fees and Compensation of the Part 2A Disclosure Brochure for complete details on fees. Additionally, the practice of billing fees on the total market value, including assets purchased with margin, creates a conflict of interest. ThePARTNERS and its IARs have a financial incentive to recommend the 4  use of margin, as borrowing to invest increases the total assets on which the advisory fee is based, thereby increasing the firm's compensation. To address this conflict, margin will only be recommended after a thorough suitability review with you to ensure it aligns with your stated investment objectives, financial situation, and risk tolerance. Our IARs will also clearly explain the risks associated with margin, including the potential for amplified losses, before it is used in your account. You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund's prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, margin interest, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included in the wrap-fee you are charged by our firm. Fees Investment Advisory Services Your designated IAR will discuss the investment advisory fees when your account is established, and these fees will be outlined in the advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior billing period and are billed at an annual rate of up to 2.99%, depending on factors such as the level of assets being managed, the complexity of the services to be provided and/or the overall relationship with the Client. For purposes of calculating the advisory fee, the "market value of assets under management" includes the total value of assets in the account, including any assets purchased with margin (i.e., borrowed funds). Further, as a component of the bundled wrap fee, a platform fee may be charged for securities transaction fees, reporting and related services, structured as follows: • ThePARTNERS as Portfolio Manager – If we directly manage and trade your portfolio, the platform fee is 0.09% per year, billed quarterly (0.0225% per quarter). • Unified Managed Account (UMA) – If we engage or use third party managers to manage some or all of your portfolio, the platform fee is 0.12% per year, billed quarterly (0.03% per quarter). Fees are paid quarterly, in advance of each calendar quarter (the billing period), pursuant to the terms of the investment advisory agreement. Fees for the first partial billing period of service are prorated from the inception date of the account[s] to the end of the first billing period. Fees may be negotiable at the sole discretion of the Adviser. Certain Clients may have a fixed annual fee or fixed rate fee or a fee schedule that differs from above. The Client's fees will take into consideration the aggregate assets under management with Adviser. All securities held in accounts managed by ThePARTNERS will be independently valued by the custodian. ThePARTNERS will not have the authority or responsibility to value portfolio securities. Clients should review their advisory agreement for additional information relative to fees and fee billing. The Client may make additions or withdrawals from the account[s] at any time, subject to the ThePARTNERS' right to terminate an account or the overall relationship. Additions may be in cash or securities provided that the ThePARTNERS reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client's account[s]. Clients may withdraw account assets on notice to ThePARTNERS, subject to the usual and customary securities settlement procedures. However, ThePARTNERS typically designs its investment portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client's investment objectives. ThePARTNERS may consult the Client about the implications of such transactions. Clients are advised that when such securities are liquidated, they may be subject to securities transaction fees, short-term redemption fees, and/or tax ramifications. If assets in excess of $25,000 are deposited into or withdrawn from the Client's account[s], an adjustment will be made in the next billing period to reflect the fee difference. ThePARTNERS may 5  negotiate a fee that differs from the schedule above for certain account[s] or holdings. As noted above, the Wrap Fee Program includes normal securities trading costs incurred in connection with the discretionary investment management services provided by ThePARTNERS. Securities transaction fees for Client-directed trades may be charged separately to the Client. Compensation ThePARTNERS receives an investment advisory fee paid by Clients for investment advisory services covered under this Wrap Fee Program. The investment advisory fees as described in detail in Item 5 – Fees and Compensation of the Part 2A of Disclosure Brochure. Fees and Costs Not Included Our wrap fee covers our advisory services and the brokerage services provided by Schwab, including custody of assets, equity trades, ETFs, and agency transactions in fixed income securities. As a result, we have an incentive to execute transactions for your account at Schwab. Our wrap fee does not cover all fees and costs. The fees not included in the wrap fee include charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund's prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions, and commissions or transaction fees for trades executed away from Schwab. In limited circumstances, our firm may direct a trade to a broker-dealer other than Schwab. This is done only when we believe in good faith that another broker or dealer will provide better "best execution" (for example, a more favorable net price, considering all factors) than is available through Schwab. In such instances, you will be responsible for paying the commission or markup charged by the other broker- dealer. This cost is separate from and in addition to your wrap fee. You will see this separate transaction cost itemized on the official trade confirmation sent by the executing broker-dealer and reflected on your custodial account statement. Clients are likewise responsible for paying all margin interest, which is a separate finance charge imposed by the custodian for any funds borrowed on margin. The wrap fee does not cover this margin interest. ThePARTNERS does not receive any portion of the margin interest revenue paid to the custodian. This would be similar if assets were held at other custodians. Item 5 Account Requirements and Types of Clients ThePARTNERS offers investment advisory services to individuals, families, trusts, estates, and businesses, with a focus on those Clients with a high net worth. The relative percentage of each type of Client is available on ThePARTNERS' Form ADV Part 1. These percentages will change over time. ThePARTNERS do not impose a size for establishing a relationship, but as noted does tailor its services to high-net-worth Clients. Item 6 Portfolio Manager Selection and Evaluation This item describes how ThePARTNERS, as the sole sponsor and portfolio manager for this Wrap Fee Program, manages your account. Our firm, ThePARTNERS, acts as the portfolio manager for this program, with services provided directly by our supervised persons, particularly our IARs acting on behalf of the firm, through our "Internal Investment Management" services. As required, we are providing the following 6  information from our Part 2A Disclosure Brochure: A) Advisory Business ThePARTNERS is an investment adviser registered with the SEC. It is organized as a limited liability company under the laws of the State of Delaware. ThePARTNERS was founded in March 2021 and is primarily owned by Gregory Rutherford through various entities and trust vehicles. These entities are owned in whole or part by individuals who are affiliated with ThePARTNERS, and certain of these entities also own ELITE TAMP and Adaptive which are affiliates of ThePARTNERS. Please refer to Item 4 – Advisory Business of the Part 2A Disclosure Brochure for details on the advisory services provided by ThePARTNERS, and to the Brochure Supplement for the background of the IARs of ThePARTNERS. B) Performance-Based Fees As a general rule, ThePARTNERS charges advisory fees based on a percentage of assets under management, as described in Item 5 – Fees and Compensation of the Part 2A of Disclosure Brochure. However, in limited circumstances for certain qualified client accounts, we may negotiate a performance-based fee (e.g., a fee based on a share of capital gains). All such fee arrangements are exceptional and require the prior review and approval of our Chief Compliance Officer. ThePARTNERS does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund). However, as described above and in Item 10 of the Part 2A Disclosure Brochure, our affiliate, Adaptive, manages proprietary mutual funds and ETFs. This creates a financial incentive for our firm and IARs to recommend these products to Clients. Depending upon client suitability and investment profile, an investment may be made in mutual funds or ETFs managed by Adaptive. C) Methods of Analysis Please see Item 8 of the Part 2A Disclosure Brochure for details on the research and analysis methods employed by ThePARTNERS. D) Risk of Loss Investing in securities involves certain investment risks. Securities will fluctuate in value and may lose value. Clients should be prepared to bear the risk of loss, which will vary based upon market conditions and length of investment. ThePARTNERS and its IARs assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that Clients will meet their investment goals. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally 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 firm in evaluating potential investments, it does not guarantee that the investments will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis will fluctuate in value and may lose value and may have negative investment performance. ThePARTNERS monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. Please refer to Item 13 – Review of Accounts of the Part 2A Disclosure Brochure for more details on the review process. 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 7  account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account. The IAR 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 ThePARTNERS 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 IAR will work with each Client to determine their tolerance for risk as part of the portfolio construction process. 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 IAR. Please see Item 8.B. – Risk of Loss of the Part 2A Disclosure Brochure for details on investment risks. E) Voting Client Securities ThePARTNERS does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the custodian. The IAR 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 As ThePARTNERS is the sponsor and primary portfolio manager for this Wrap Fee Program, we generally manage client accounts directly. However, in certain cases, we can utilize third-party or affiliated portfolio managers, including manager strategists available through the Amplify platform or independent managers not affiliated with the Amplify platform. In such cases, client information will be shared as necessary to provide advisory services. Your IAR, acting on behalf of ThePARTNERS, serves as your portfolio manager. Your IAR gathers information directly from you regarding your financial situation, investment objectives, risk tolerance, and any reasonable restrictions you wish to place on your account. We use this information to construct and manage your portfolio. We update this information during our regular Client reviews or as needed when you inform us of any material changes to your financial situation or goals. Item 8 Client Contact with Portfolio Managers There are no restrictions on your ability to contact and consult with your portfolio manager. As ThePARTNERS is the sole portfolio manager for this program, you will have direct access to your IAR, who is responsible for managing your account. Item 9 Additional Information Disciplinary Information and Other Financial Industry Activities and Affiliations Disciplinary Information ThePARTNERS values the trust you place in us. As part of our commitment to transparency, we encourage all Clients to conduct their own due diligence when selecting an investment adviser or related service provider. Information regarding the background of ThePARTNERS and our IARs is publicly 8  available on the Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov by searching our firm name or CRD# 3184816. For additional information regarding disciplinary history, please refer to Item 9 – Disciplinary Information of the Part 2A Disclosure Brochure and Item 3 – Disciplinary Information of the Brochure Supplement of each IAR documents describe how to review the regulatory background of both the Firm and its representatives. Other Financial Activities and Affiliations Additional information regarding ThePARTNERS’ affiliations, business activities, and potential conflicts of interest can be found in Items 10 and 14 of the Part 2A Disclosure Brochure, and in Items 4 and 5 of each IAR’s Brochure Supplement. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information ThePARTNERS maintains a comprehensive Code of Ethics designed to uphold our fiduciary obligations and to promote the highest standards of professional conduct. This Code of Ethics applies to all individuals subject to ThePARTNERS' compliance program (collectively, our "Supervised Persons"). Complete details regarding the ThePARTNERS’ Code of Ethics are provided under Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading of the Part 2A Disclosure Brochure. Review of Accounts Client accounts are reviewed on a regular basis by the Client’s designated IAR and periodically by our Chief Compliance Officer. For additional information, please refer to Item 13 – Review of Accounts of the Part 2A Disclosure Brochure. Other Compensation Participation in Institutional Adviser Platform As part of our institutional relationships with custodians such as Fidelity and Schwab, we receive an array of products, services, and support that benefit our firm and, in some cases, our Clients. These benefits are not considered "soft dollars" under the safe harbor of Section 28(e) of the Investment Advisers Act of 1940, as they are not received in exchange for directing client brokerage transactions and are not used exclusively for brokerage and research services. Instead, these benefits are received as part of an overall institutional platform offering. We disclose them here as a potential conflict of interest. The availability of these services and benefits creates an incentive for us to recommend custodians that provide them over those that do not. Where ThePARTNERS does not exercise discretion over the selection of the custodian, we may recommend the custodian[s] to Clients for custody and execution services. Nonetheless, Clients are not obligated to use the custodian recommended by ThePARTNERS. As earlier stated, we recommend that Clients establish their account[s] with Fidelity Clearing & Custody Solutions, a related entity of Fidelity Investments, Inc. (collectively "Fidelity"), or with Charles Schwab & Co, Inc. ("Schwab") where the firm maintains institutional relationships. We periodically monitor and review the services, costs, and benefits provided by our recommended custodians to ensure our recommendation continues to be in the best interest of our Clients. 9  Fidelity ThePARTNERS has established an institutional relationship with Fidelity to be the preferred custodian for Client accounts. This relationship assists us in managing Client accounts through aggregation of the accounts and use of a single operating system. Based upon this relationship, we have received access to software and related support. The software and related systems support provide direct benefit to the ThePARTNERS and may provide indirect benefits to the Clients through increased efficiencies. In fulfilling our duties to our Clients, we endeavor at all times to put the interests of our Clients first. To reiterate, Clients should be aware, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the firm’s recommendation of the custodian over one that does not furnish similar software, systems support, or services. Additionally, ThePARTNERS has received financial and other support from Fidelity to assist in the launch and maintain its advisory firm. These benefits from Fidelity include reimbursement to Clients for costs charged by a previous custodian for transfer of the assets or account to Fidelity, financing services, receipt of duplicate Client confirmations and bundled duplicate statements at no cost, access to a trading desk that exclusively services its institutional participants, access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts, and access to an electronic communication network for Client order entry and account information. Schwab ThePARTNERS may likewise recommend that Clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc., to maintain custody of Client’s assets and to effect trades for their accounts. Schwab provides us and our Clients with access to its institutional trading and services, which are not typically available to Schwab retail customers. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. These services generally benefit our Clients. Services that May Not Directly Benefit Clients Schwab also makes available to ThePARTNERS other products and services that benefit us but may not directly benefit our Clients or their account(s). These products and services assist us in managing and administering our Clients' accounts. They include investment research, both Schwab's own and that of third party which we may use to service all or some substantial number of our Clients' accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: o provides access to Client account data (such as duplicate trade confirmations and account statements); o facilitates trade execution and allocate aggregated trade orders for multiple Client accounts; o provides pricing and other market data; o facilitates payment of our fees from our Clients' accounts; and o assists with back-office functions, recordkeeping and Client reporting. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: o educational conferences and events o technology, compliance, legal, and business consulting; o publications and conferences on practice management and business succession; and 10  o access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party's fees. Irrespective of direct or indirect benefits to our Client through Schwab, we strive to enhance the Client's experience, help reach their goals and put their interests before that of our firm or its associated persons. Schwab has eliminated commissions for online trades of equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab's pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab's most recent pricing schedules available at schwab.com/as pricing guide. Please see Item 14 – Other Compensation of the Part 2A Disclosure Brochure for details on additional compensation that may be received by ThePARTNERS. The Brochure Supplements for each IAR also provide details on their outside business activities and associated compensation. Financial Information Neither ThePARTNERS, nor its management has any adverse financial situations that would reasonably impair our ability of to meet all our obligations to our Clients. Neither ThePARTNERS, nor any of our IARs, has been subject to a bankruptcy or financial compromise. ThePARTNERS is not required to deliver a balance sheet along with its Disclosure Brochure, as the firm does not collect advance fees of $1,200 or more for services to be performed six months or more in advance. 11