TLW WEALTH MANAGEMENT, LLC

Item 1 Cover Page Part 2A of Form ADV Firm Brochure TLW Wealth Management, LLC 535 Harbor Dr N Indian Rocks Beach, FL 33785 Phone: (402) 599-9568 Date: January 31, 2026 www.tlw.money This brochure provides information about the qualifications and business practices of TLW Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at (402) 599-9568 or via email at David@tlw.money. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about TLW Wealth Management, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Please note that registration as an investment advisory firm does not imply a certain level of skill or training. 1  Material Changes Item 2 Since our last annual amendment of February 24, we have made no material changes. 2  Table of Contents Item 3 Item 1 Cover Page .................................................................................................................................... 1 Item 2 Material Changes .......................................................................................................................... 2 Item 3 Table of Contents .......................................................................................................................... 3 Item 4 Advisory Business .......................................................................................................................... 4 Item 5 Fees and Compensation ................................................................................................................ 4 Item 6 Performance-Based Fees and Side-by-Side Management ............................................................ 5 Item 7 Types of Clients ............................................................................................................................. 5 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 6 Item 9 Disciplinary Information ................................................................................................................ 6 Item 10 Other Financial Industry Activities and Affiliations ................................................................... 6 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............ 7 Item 12 Brokerage Practices .................................................................................................................. 7 Item 13 Review of Accounts ................................................................................................................... 8 Item 14 Client Referrals and Other Compensation ................................................................................ 9 Item 15 Custody ..................................................................................................................................... 9 Item 16 Investment Discretion ............................................................................................................... 9 Item 17 Voting Client Securities ............................................................................................................. 9 Item 18 Financial Information .............................................................................................................. 10 Brochure Supplement ................................................................................................................................. 11 Item 1 Cover Page ................................................................................................................................. 11 Item 2 Educational Background and Business Experience ..................................................................... 11 Item 3 Disciplinary Information .............................................................................................................. 13 Item 4 Other Business Activities ............................................................................................................. 13 Item 5 Additional Compensation ........................................................................................................... 13 Item 6 Supervision .................................................................................................................................. 13 3  Advisory Business Item 4 TLW Wealth Management, LLC (“TLW”, the “Firm”, “Us” or “We”) is an investment adviser offering investment advisory services to our clients. The Firm began offering investment advisory services in 2016 and is owned by David VerVelde, Jesse VerVelde, Molly Arnall and Maureen McAnarney. We offer value driven investment management services on a discretionary basis. We trade in individual equity securities with the goal of meeting our client’s financial needs and objectives. Our services are designed for investors with a long term (10 or more years) time horizon who can tolerate the ups and downs of the financial markets. At the onset of the relationship, we will meet with you to determine your investment objectives and needs. We are always available upon client request to review your individual financial situation. If our investment philosophy is suitable for your needs and objectives, we will then recommend a course of action. It is important to note that our services are not for everyone. If our investment philosophy does not match your investment objectives and needs, you should seek advice from a different advisor. Clients may impose investment restrictions and we structure our portfolios to meet ongoing monthly cash withdrawal needs. Our services are not offered as a wrap fee program. As of December 31, 2025, our firm has $175,165,291 of discretionary assets under management and $0 of non-discretionary assets under management. Fees and Compensation Item 5 The Firm offers managed accounts with similar management styles for a percentage of assets under management that is exclusive of transaction and custodial charges. You may be charged by the custodian of your assets for transactions in your accounts, margin fees, custodial fees, or other charges as detailed separately for you on your custodial account application. Fee Structures for Managed Accounts We charge an annual fee of 1.00% on the average account value for the quarter. To calculate the average daily balance, the system we use to calculate fees takes the ending balance of each day in the billing period and averages this by the number of days in the period. Our fees are charged quarterly, in advance and are typically deducted from client accounts. In any partial calendar quarter, the management fee will be pro-rated based on the number of days that the Account was open during the quarter. Client understands that Account assets invested in shares of mutual funds or other investment companies (“funds”) will be included for the purpose of calculating the value of the Account for purposes of computing our fee and that the same assets will also be subject to other fees as set forth in the prospectus of those funds which will be paid by the funds but ultimately borne by the investor. 4  The total cost of each of the services provided through these programs, if purchased separately, could be more or less than the costs of each respective program. Cost factors may include your ability to obtain the services provided within the programs separately with respect to the selection of investments, invest and rebalance the selected investments without the payment of a sales charge, and obtain performance reporting comparable to those provided within each program. When making cost comparisons, you should be aware that the combination of multiple mutual fund investments, advisory services, custodial and brokerage services available through each program may not be available separately or may require multiple accounts, documentation and fees. If an account is actively traded or if you otherwise may not qualify for reduced sales charges for fund purchases, the fees may be less expensive than separately paying the sales charges and advisory fees. If an account is not actively traded or if you otherwise would qualify for reduced sales charges, the fees in these programs may be more expensive than if utilized separately. You may also incur charges for other account services provided by the custodian not directly related to the execution and clearing of transactions. These fees may include IRA custodial fees, safekeeping fees, interest charges on margin loans, and fees for legal or transfers of securities. Transaction costs will be paid by active clients in the instance of an unsolicited liquidation of more than three account positions within a month of each other. In any unsolicited liquidation of one or more positions by a client who is in the process of closing out their account with the Firm, client pays transaction charges. Termination The Investment Advisory Agreement may be terminated by either of us at any time upon providing written notice pursuant to the provisions of the Investment Advisory Agreement. There is no penalty for terminating your account. Upon termination, you will receive a refund of the portion of the prepaid asset- based fee which is not utilized. We will not accept instructions to terminate the Agreement unless you provide these instructions in writing. We believe the charges and fees offered within each fee-based program are competitive with alternative programs available through other firms and/or investment sources. We make no guarantee that the aggregate cost of a particular program is lower than that which may be available elsewhere. We will occasionally negotiate fees with clients due to personal family relationships or the percentage of cash that the client requests to retain in their account. Performance-Based Fees and Side-by-Side Management Item 6 We do not charge performance-based fees. Types of Clients Item 7 We provide investment advice to Individuals, High Net Worth people, Companies, Trusts, and Estates. The Firm has a minimum account value of $100,000 for TLW Portfolios. We may waive this based on prior relationships, anticipated other assets, or at our discretion. 5  Methods of Analysis, Investment Strategies and Risk of Loss Item 8 Investing involves risk that you should be prepared to bear. Our investment style has developed over 30 years. Three investors have served to guide our process: Sir John Templeton, Peter Lynch, and Warren Buffett, thus the name TLW Wealth Management, LLC. Although these well-known investors are not our clients, nor recommending us, their methodology and mindset has influenced how TLW manages money. John Templeton believed in buying at the point of maximum pessimism and selling at the point of maximum optimism. He was the founder of Templeton Funds. Peter Lynch believed in knowing what you own and stressed the importance of diversification. He has written many books on investing and successfully managed the Fidelity Magellan Fund. Warren Buffett believes in buying value and holding long term. Warren is considered one of the world’s greatest investors and is the founder of Berkshire Hathaway. TLW’s services are best suited for patient, value investors. We typically are buying when a stock is declining, and it is not unusual to average down 2 or 3 times. When initiating a position, we may start with a quarter or half position. On the sell side, positions are pruned as they become overvalued. In our TLW portfolios, we believe individual stock positions should not be more than 12% of the portfolio. There will be exceptions to the 12% rule…some stocks may appreciate greatly but still be undervalued. Also, for smaller accounts (under $100,000) the total number of securities held may be less. These guidelines are just guidelines and individual accounts and holdings will vary. The risks of this methodology include capital loss due to incomplete research, unexpected problems at a company in which stock is held, problems in the general economy and potential trade execution problems. There are risks associated with the investments we select, including that returns are not guaranteed. There is no guarantee you will make money on a stock at any given point at time. Stock prices change often and for many reasons. Disciplinary Information Item 9 Neither the Firm nor any of our management persons have been involved in any events that are material to a client’s or prospective client’s evaluation of the Firm or the integrity of its management. In this Item, these would include specific criminal or civil actions, certain administrative actions by the SEC or a regulatory authority, or certain proceedings by self-regulatory authorities. Item 10 Other Financial Industry Activities and Affiliations Neither we nor any of our management persons are a broker/dealer, nor are we affiliated as registered representatives of a broker/dealer. 6  Neither we nor our management persons are registered nor have an application pending to register as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. We do not recommend or select other investment advisers for our clients. Code of Ethics, Participation or Interest in Client Item 11 Transactions and Personal Trading Associated persons may buy or sell for their own accounts the same securities recommended to you. Associated persons seek to ensure that they do not personally benefit from the short-term market effects of their recommendations to you and we monitor their personal trading. Associated persons are aware of the rules regarding material non-public information and insider trading. Associated persons may also buy or sell a specific security for their own account based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. We have adopted a Code of Ethics to instruct our personnel in their ethical obligations and to provide rules for their personal securities transactions. The Firm and our personnel owe a duty of loyalty, fairness and good faith to their clients, and the obligation 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 including general ethical principles, reporting personal securities trading, exceptions to reporting securities trading, reportable securities, initial public offerings and private placements, reporting ethical violations, distribution of the Code, review and enforcement processes, amendments to Form ADV and supervisory procedures. We will provide a copy of the Code to any client or prospective Client upon request. Brokerage Practices Item 12 We recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker/dealer, member SIPC, as a qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to do so. While we recommend that you use Schwab as a custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below. For certain clients with retirement plan assets, we may recommend clients custody assets through John Hancock Life Insurance Company. We do not trade securities at John Hancock Life Insurance Company, nor do we receive any additional products and service from their firm. We maintain a relationship with one broker/dealer. While you are free to choose any broker/dealer or other service provider, we recommend that you establish an account with a brokerage firm with which we have an existing relationship. Such relationship may include benefits provided to our firm, including 7  but not limited to, research, market information, and administrative services that help our firm manage your account(s). We believe that recommended broker/dealers provide quality execution services for our clients at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by recommended broker- dealers, including the value of research provided, the firm's reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In recognition of the value of research services and additional brokerage products and services recommended broker/dealers provide, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Clients may select another custodian. Not all advisers would require or suggest that you use a particular custodian. If you choose a different custodian, we may not be able to achieve the most favorable execution of transactions. It may cost you more or less money. In particular, you may pay higher brokerage commissions or receive less favorable prices. We combine our orders into block trades if more than one account is participating in the trade. This blocking or bunching technique must be equitable and potentially advantageous for each such account. We engage in block trading when it is consistent with the duty to seek best execution and is consistent with the terms of our investment advisory agreements. Equity trades are blocked based upon fairness to client, both in the participation of their account, and in the allocation of orders for the accounts of more than one client. Allocations of all orders are performed in a timely and efficient manner. All managed accounts participating in a block execution receive the same execution price (average share price) for the securities purchased or sold in a trading day. In certain cases, we may use a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Review of Accounts Item 13 We continuously review the securities in every client's account. Account suitability and holdings are reviewed quarterly. David VerVelde typically reviews every account weekly. On a quarterly basis, we provide a written report designed to summarize your investment account holdings, show deposits and withdrawals, and your investment performance. This is a supplement to 8  the statements provided to you by your custodian and does not replace your custodial statement which you should review carefully. Client Referrals and Other Compensation Item 14 We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. We benefit from the products and services provided because the cost of these services would otherwise be borne directly by us, and this creates a conflict. You should consider these conflicts of interest when selecting a custodian. These products, how they benefit us, and the related conflicts of interest are described above (see Item 12- Brokerage Practices). Custody Item 15 We only have custody of client assets to the extent which allows us to withdraw quarterly fees. We request your written consent for this ability to withdraw fees from your accounts at the time you engage us as your investment adviser. We have in place the following safeguards in line with the custody of your assets:  Your assets will be physically held by Charles Schwab & Co., Inc., a registered broker/dealer and qualified custodian.  We will send you an invoice for our advisory fees before we debit your account for the fees.  You will receive quarterly statements or more frequent statements depending on transactions in your account, from your custodian. Those statements will show, among other things, the deduction of our advisory fee and all other disbursements from your account. You should carefully review those statements. Investment Discretion Item 16 We request discretionary authority to manage your account. Our services work best when we have this discretionary authority and may not be suited for persons wishing to work on a non-discretionary basis. You may place reasonable limitations (such as on the types of securities you do or do not wish to purchase, for example) by notifying us of these limitations, in writing, at the time you become a client or at any point thereafter. In order for us to assume investment discretion you must authorize us to do so, in writing, by signing our Investment Advisory Agreement. Voting Client Securities Item 17 We do not accept authority to vote client securities. Our clients retain that right. You will receive your proxies or other solicitations directly from your custodian. We will provide advice, upon request, to 9  assist with any corporate actions or proxies but the ultimate decision of how to vote or act rests upon you as the security owner. Financial Information Item 18 We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. We do not have any financial situation that would be likely to impair our ability to meet contractual commitments to clients. We have not been the subject of a bankruptcy petition at any time during the past ten years. 10  Brochure Supplement Item 1 Cover Page Part 2B of Form ADV David VerVelde Jesse VerVelde Molly Arnall Dylan Arnall TLW Wealth Management, LLC 535 Harbor Dr N Indian Rocks Beach, FL 33785 Phone: (402) 599-9568 Date: January 31, 2026 This brochure supplement provides information about David VerVelde, Jesse VerVelde, Molly Arnall and Dylan Arnall that supplements our disclosure brochure. Please contact us at (402) 599-9568 if you did not receive TLW Wealth Management, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about our advisors is available on the SEC’s website at www.adviserinfo.sec.gov. Educational Background and Business Experience Item 2 David VerVelde, born in 1953, is an Investment Advisor Representative and a Member and Chief Compliance officer of TLW Wealth Management, LLC and has been so since July 2016. Mr. VerVelde holds Bachelor’s degree from Calvin College and a Masters in Industrial Psychology from the University of Nebraska. Prior to this he was an Investment Advisor Representative of VSR Advisory Services from 2012 – 2016 and a Registered Representative of VSR Financial Services. Prior to that affiliation, Mr. VerVelde was a Registered Representative and Investment Advisor Representative of Robert W. Baird & Co., Incorporated beginning in August 1993 through September 2012. Jesse VerVelde, born in 1990, is an Investment Advisor Representative and a Member and Vice President of TLW Wealth Management, LLC and has been so since July 2016. Mr. VerVelde holds Bachelor’s degree from Doane College in Business Administration and a Minor in History. Prior to this he was a trader, asset movement specialist, and cashier at VSR Advisory Services from 2013 – 2016. 11  Molly Arnall CFP® was born in 1993. She is an Investment Adviser Representative and Client Services Manager for TLW Wealth Management LLC. She graduated in May of 2016 from the University of Kansas with a degree in Strategic Communications from the Journalism School. Molly relocated to Florida in 2018 and began working for Berkshire Hathaway Real Estate. She joined TLW Wealth Management, LLC in September 2019 and became licensed in January 2020. She earned her Certified Financial Planning Certification in April 2025. Dylan Arnall CFP® was born in Little Rock, Arkansas, in 1993. He graduated with a degree in Marketing and Management from Baker University and an MBA from the University of Arkansas at Little Rock in 2018. Before joining the TLW team, he worked for Paychex, Inc. for 6 years, specializing in retirement planning. He joined TLW Wealth Management in November 2024 as a Financial Services Director and earned his Certified Financial Planning certification in December 2024. The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP®(with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is voluntary; no federal or state law or regulation requires financial planners to hold the CFP® certification. It is recognized in the United States and several other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 92,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:  Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and reach a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning.  Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered in 10 hours over two days, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real-world circumstances.  Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year).  Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: 12   Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field.  Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. Disciplinary Information Item 3 None of our supervised people is subject to any material legal or disciplinary event. Other Business Activities Item 4 We have no outside business activities that relate to the services we provide outside of that which is disclosed in item 10 of our brochure (attached). Additional Compensation Item 5 There are no such issues to be disclosed. Supervision Item 6 David VerVelde supervises all associates of TLW Wealth Management, LLC. You may reach him at any time with questions or concerns by calling him at (402) 599-9568. 13