Thryve Wealth Management

Thryve Wealth Management LLC Form ADV Part 2A – Disclosure Brochure Effective: March 23, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Thryve Wealth Management LLC (“Thryve” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at 805-451-2909. Thryve is a registered investment advisor with U.S. Securities and Exchange Commission. The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Thryve to assist you in determining whether to retain the Advisor. information about Thryve and its Advisory Persons is available on the SEC’s website at Additional www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335920. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2909 * Fax: 805-600-5128 https://www.thryvewealthmanagement.com/  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Thryve. Thryve believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Thryve encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. The following material changes have been made to this Disclosure Brochure since the last filing and distribution to Clients: • Effective February 27, 2026, Laura Brady has resigned as Chief Growth Officer. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335920. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 805-451-2909. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents .................................................................................................................................... 3 Item 4 – Advisory Services ................................................................................................................................... 4 A. Firm Information ............................................................................................................................................................. 4 B. Advisory Services Offered .............................................................................................................................................. 4 C. Client Account Management .......................................................................................................................................... 5 D. Wrap Fee Programs ....................................................................................................................................................... 6 E. Assets Under Management ............................................................................................................................................ 6 Item 5 – Fees and Compensation ......................................................................................................................... 6 A. Fees for Advisory Services ............................................................................................................................................. 6 B. Fee Billing ....................................................................................................................................................................... 7 C. Other Fees and Expenses ............................................................................................................................................. 7 D. Advance Payment of Fees and Termination .................................................................................................................. 7 E. Compensation for Sales of Securities ............................................................................................................................ 8 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 8 Item 7 – Types of Clients ....................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 8 A. Methods of Analysis ....................................................................................................................................................... 8 B. Risk of Loss .................................................................................................................................................................... 9 Item 9 – Disciplinary Information ....................................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 11 A. Code of Ethics .............................................................................................................................................................. 11 B. Personal Trading with Material Interest ........................................................................................................................ 11 C. Personal Trading in Same Securities as Clients .......................................................................................................... 11 D. Personal Trading at Same Time as Client ................................................................................................................... 12 Item 12 – Brokerage Practices ............................................................................................................................ 12 A. Recommendation of Custodian[s] ................................................................................................................................ 12 B. Aggregating and Allocating Trades .............................................................................................................................. 13 Item 13 – Review of Accounts ............................................................................................................................ 13 A. Frequency of Reviews .................................................................................................................................................. 13 B. Causes for Reviews ..................................................................................................................................................... 13 C. Review Reports ............................................................................................................................................................ 13 Item 14 – Client Referrals and Other Compensation ........................................................................................ 13 A. Compensation Received by Thryve ............................................................................................................................. 13 B. Compensation for Client Referrals ............................................................................................................................... 14 Item 15 – Custody ................................................................................................................................................ 14 Item 16 – Investment Discretion ......................................................................................................................... 14 Item 17 – Voting Client Securities ...................................................................................................................... 15 Item 18 – Financial Information .......................................................................................................................... 15 Privacy Policy ...................................................................................................................................................... 16 Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 3  Item 4 – Advisory Services A. Firm Information Thryve Wealth Management LLC, formerly known as Strive Wealth Management LLC (herein “Thryve”, or the “Advisor”) is a Texas limited liability company that was formed in March 2025 as a subsidiary of Strive Enterprises, Inc. The Advisor was sold to Gary Dorfman in September 2025, and rebranded to Thryve in October 2025. Thryve is a registered investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) and is wholly owned by Gary Dorfman. Thryve is operated by Gary Dorfman (Chief Executive Officer), Randol Curtis (Chief Investment Officer), and Nicole Saragosa (Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Thryve. B. Advisory Services Offered Thryve offers investment advisory services to individuals, high net worth individuals, endowments, foundations, charitable organizations, corporations and other businesses (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Thryve's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Thryve provides comprehensive wealth management services for its Clients. This is achieved through continuous personal Client contact and interaction, and financial planning while providing discretionary investment management and related advisory services. Thryve works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to determine a portfolio strategy Financial Planning Services – Thryve will typically provide a variety of financial planning services to Clients as a component of wealth management services. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan based on the Client’s financial goals and objectives. This planning may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s financial situation. A financial plan developed for 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. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any 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. Investment Management Services – Thryve will construct an investment portfolio, consisting of quity securities, publicly traded real estate investment trusts, corporate, municipal, and government and sovereign debt securities, mutual funds, exchange traded funds (ETFs), exchange-traded products (ETPs), and alternative investment vehicles such as private equity, private credit, real assets, hedge funds, and digital assets to achieve the Client’s investment goals. The Advisor may also utilize direct indexing strategies (see “Direct Indexing” below) to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 4  Thryve’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Thryve will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Thryve evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Thryve may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Thryve may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Thryve may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Thryve accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Direct Indexing – Thryve also offers a direct indexing service to utilize systematic tax-loss harvesting in the Core Equity portion of Client portfolios (“Direct Indexing”). Thryve facilitates this service by contracting with one or more third-party platform providers (“Platform Providers”) to provide an online separately managed account platform (“SMA Platform”). The applicable financial intermediary and/or Platform Provider has discretion with respect to the underlying clients’ portfolios, and the Platform Provider implements all transactions, in accordance with one or more strategies specified by Thryve. Direct Indexing allows the underlying investors to track index performance through ownership in individual stocks, instead of through an ETF or mutual fund, while providing enhanced customization and ownership control. Direct Indexing can also deliver potential tax benefits, including daily scanning for tax loss harvesting opportunities and the opportunity for in-kind transfers from existing equity portfolios. All clients must receive and approve a Tax Transition Analysis of the specific portfolio using the online tool, provided jointly by Thryve and its Platform Provider, before they may elect to invest in the Strategy. Thryve does not execute transactions for any underlying clients in the Direct Indexing program Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. C. Client Account Management Prior to engaging Thryve to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Thryve, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Thryve will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 5  • Portfolio Construction – Thryve will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Thryve will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Thryve does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Thryve. E. Assets Under Management As of December 31, 2025, Thryve manages $303,985,008 in Client assets, $292,020,559 of which are managed on a discretionary basis and $11,964,449 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid quarterly in arrears pursuant to the terms of the wealth management agreement. Wealth management fees are based on the average daily market value of portfolio assets under management during the prior calendar quarter. Wealth management fees range up to 1.50% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. For direct-indexing Clients are subject to an additional fee of up to 0.30%. However, fees may be reduced based on factors including total assets under management with the Advisor. The wealth management fee for new accounts are prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Thryve will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses as described in Item 5.C, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.50% based on the market value of assets under management at the end of the calendar quarter. Retirement plan advisory fees are billed quarterly at the end of each calendar quarter. Fees may be negotiable depending on the size and complexity of the Plan. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 6  B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the end of each calendar quarter. The amount due is calculated by applying the applicable annual fee (annual rate divided by 4) to the average daily market value of securities with Thryve during the prior quarter. Clients will be provided with a 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 advisory fees to be deducted by Thryve to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Thryve, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Thryve are separate and distinct from these custody and execution fees. In addition, all fees paid to Thryve for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Thryve, but would not receive the services provided by Thryve which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Thryve to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services Thryve is compensated for its wealth management services at the end of each quarter after services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services Thryve is compensated for its retirement plan advisory services the end of the quarter after services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. Clients may also terminate the retirement plan advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 7  E. Compensation for Sales of Securities Thryve does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Thryve does not charge performance-based fees for its investment advisory services. The fees charged by Thryve are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Thryve does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Thryve offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans. Thryve generally requires a minimum relationship size of $500,000 to effectively implement its investment process. However, Thryve may waive this minimum at its sole discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Thryve primarily employs fundamental analysis in developing investment strategies for its Clients. Research and analysis from Thryve are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. The Advisor’s investment strategy is built around a Core and Satellite approach, which balances security selection and diversification to optimize returns while managing risk. The Core portion of the Advisor’s portfolio is dedicated to traditional investments, including stocks and bonds, with an emphasis on passive direct indexing, ETFs, and selective active equity strategies. The Advisor has adopted a disciplined investment process that includes systematic rebalancing and tax- efficient management practices. The Advisor generally view placing a portion of the taxable stock in a portfolio into a passive direct indexing service to be in the Client’s best interest due to the opportunities for tax loss harvesting opportunities or the non-taxable stock portion of a portfolio, Thryve advises placing Clients in an ETF (or ETFs) as these are generally more efficient vehicles for broad equity exposure. This structure is designed to provide a stable foundation with diversified exposure across major asset classes, which forms the core of Client portfolios. In addition to the Core, the Satellite segment of the Advisor’s portfolio provides exposure to alternative investments directly and/or through alternative investment vehicles or ETPs, offering unique opportunities for capital growth and income while reducing correlation to public markets. These alternatives can include private equity, private credit, venture capital, real assets and digital assets. By selecting alternative investment managers with specialized expertise in niche markets, Satellite investments are Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 8  designed to complement the Core by adding targeted opportunities for enhanced returns, diversification and inflation protection. Given the Advisor’s belief in the fundamentals of shareholder capitalism in the United States, the Advisor emphasizes U.S. markets relative to non-U.S. developed markets. This positioning reflects Thryve’s confidence in American corporate governance and the ability of US-based companies to drive long-term growth, especially in core equity sectors. Additionally, Thryve de-emphasizes small and micro-cap public equities, where private equity market and regulatory changes have adversely impacted risk adjusted returns and growth prospects. Instead, the Advisor aims to replace this exposure with alternative investments such as private equity, which we believe offers potential for superior returns and access to better small growth- oriented private company investments. Overall, the Advisor’s Core and Satellite framework allows Thryve to tailor a diversified strategy for its Clients, to help benefit from the growth potential and liquidity of traditional investments while also accessing the potential upside of alternatives. This approach is adaptable to varying market conditions, enabling us to respond dynamically to economic shifts and Client needs. The asset classes we anticipate including in our Core and Satellite mandates include, but are not limited to the following: Investment Grade Bonds • Cash & Cash Equivalents • Government Bonds • • Convertible Bonds • High Yield Bonds • U.S. Large Cap Equity • U.S. Mid Cap Equity • Select Global Equity • Preferred Stocks • Altermative Investments • Cryptocurrency (Bitcoin, others) From time to time, at the Advisor’s discretion, asset classes can or will be added or removed from this universe. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Thryve will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 9  Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Real Estate Investment Trusts (“REITs”) Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. For Example, equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self-liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may decline). Digital Assets The investment characteristics of digital assets (“Digital Assets”) which includes, but is not limited to, virtual currencies, crypto-currencies, and digital coins and tokens, generally differ from those of traditional currencies, commodities or securities. Importantly, Digital Assets are not backed by a central bank or a national, supra-national or quasi-national organization, any hard assets, human capital, or other form of credit. Rather, Digital Assets are market-based: a Digital Asset’s value is determined by (and fluctuates often, according to) supply and demand Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 10  factors, the number of merchants that accept it, and/or the value that various market participants place on it through their mutual agreement, barter or transactions. Certain activities that we undertake in connection with holding Digital Assets can lead to significant risks, such as limitations on liquidity or a risk of loss or theft due to malicious actions, network interruptions or a failure by third-party validators to validate transactions. The growth and use of Digital Assets generally is subject to a high degree of uncertainty. The future of the industry likely depends on several factors, including, but not limited to: (a) economic and regulatory conditions relating to Digital Assets, including digital currencies; (b) government regulation of the use of and access to Digital Assets, including digital currencies; (c) government regulation of Digital Asset and digital currency service providers, administrators or exchanges; (d) the domestic and global market demand for—and availability of—other forms of Digital Asset/digital currency or payment methods; and (e) uniquely regarding Bitcoin, the security, integrity and adoption of the Bitcoin network source code protocol. Any slowing or stopping of the development or acceptance of Digital Assets or a Digital Asset network or Bitcoin or the Bitcoin network, may adversely affect a Client’s account. Digital assets exposure may be obtained through investment in ETPs that primarily hold Bitcoin or Bitcoin futures. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Thryve or its management persons. Thryve values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335920. Item 10 – Other Financial Industry Activities and Affiliations The sole business of Thryve is to provide investment advisory services to its Clients. Neither Thryve nor its Advisory Persons are involved in other business endeavors. Thryve does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Thryve has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Thryve (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Thryve and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Thryve’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at 805-451-2909 or via email at nicole.saragosa@thryvewm.com. B. Personal Trading with Material Interest Thryve allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Thryve does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Thryve does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Thryve allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 11  procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Thryve requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Thryve allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Thryve, or any Supervised Person of Thryve, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodians Thryve does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Thryve to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Thryve does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Thryve does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Thryve. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Thryve may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. The Advisor will generally recommend that clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. The Advisor maintains institutional relationships with and Schwab, whereby we receive economic benefit. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Thryve does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Thryve does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Thryve will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Thryve 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. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 12  B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Thryve will execute its transactions through the Custodian as authorized by the Client. Thryve may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Thryve’s Investment Committee. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. Financial planning engagements are reviewed upon completion of the agreed upon deliverable[s], unless the Client requests additional review services. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Thryve if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Thryve Thryve is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Thryve does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Thryve may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Thryve may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform Thryve has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Thryve. As a registered investment advisor participating on the Schwab Advisor Services platform, Thryve receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits can influence the Advisor's recommendation of Schwab over a custodian that does not furnish similar software, systems support, or services. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 13  Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Thryve that may not benefit the Client, including educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Additionally, Schwab has agreed to pay for certain services rendered by third parties for which the Advisor would otherwise have to pay. This amount is covered once the value of Client assets in accounts at Schwab reaches a certain size. Clients do not pay more for assets maintained at Schwab as a result of these arrangements. However, the Advisor does benefit from the arrangement because the cost of these services would otherwise be borne directly by the Advisor. Access to these services and financial support creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Thryve believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Clients should consider these conflicts of interest when selecting a custodian. B. Compensation for Client Referrals Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the Client. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Thryve generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Thryve. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Thryve will be in accordance with each Client's investment objectives and goals. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 14  Item 17 – Voting Client Securities Thryve generally will retain proxy voting authority over Client accounts. Where Thryve has proxy voting authority, Thryve will generally vote in favor of and advocate for board members and proposals that focus companies exclusively on the pursuit of maximizing shareholder value over all other agendas. The Advisor will generally vote against board members and proposals that advance social or political agendas unrelated to driving corporate value. More specifically, the Advisor will vote in favor of board members and proposals that the Advisor believes will lead companies to be mission driven, customer centric, merit-based, and financially disciplined. A copy of the Firm’s proxy voting policies and procedures are available upon request. Item 18 – Financial Information Neither Thryve, nor its management, have any adverse financial situations that would reasonably impair the ability of Thryve to meet all obligations to its Clients. Neither Thryve, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Thryve is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 15  Privacy Policy Effective: March 23, 2026 Our Commitment to You Thryve Wealth Management LLC (“Thryve” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Thryve (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Thryve does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 16  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes Thryve does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Thryve or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Thryve does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations California In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at 805-451-2909 or via email at nicole.saragosa@thryvewm.com. Thryve Wealth Management LLC 523 Chapala St, Ste. 2, Santa Barbara, CA 93101 Phone: 805-451-2902* Fax:805-600-5128 https://www.thryvewealthmanagement.com/ Page 17