TOWER VIEW WEALTH MANAGEMENT LLC

Item 1: Cover Page Tower View Wealth Management LLC 4414 N. Oakland Ave Unit 406 Shorewood, WI 53211 (414) 253-4096 www.tower-view.com Mailing Address: 146 Algoma Blvd Suite E, Oshkosh, WI 54901 Form ADV Part 2A - Brochure March 26, 2025 CRD Number: 108739 this Brochure, please contact Raman This brochure supplement provides information about the qualifications and business practices of Tower View Wealth Management LLC (“Tower View” or the “firm”). If you have any questions about J. Ghei at 1.414.485.5159 or the contents of raman@tower-view.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange (“SEC”) or by any state securities authority. information about Tower View is also available on the SEC’s website at Additional www.adviserinfo.sec.gov . SEC registration does not imply a certain level of skill or training.  Item 2: Material Changes Should a material change in our operations occur, depending on its nature we will promptly communicate this change to clients. Material Changes requiring prompt notification will include changes of Ownership or control; location; disciplinary proceedings; significant changes to our advisory services or advisory affiliates, and any information that is critical to a client’s full understanding of who we are and how we do business. New material changes from our March 25, 2024 annual amendment: ➢ We updated our Personal Trading Policy to allow employees and founder family members to participate in block trades. However, additional restrictions continue to apply to the founder and his immediate family members' accounts. Please refer to Item 11 of this brochure and our full Personal Trading Policy for more details. There may be other non-material changes so we encourage you to read this brochure in its entirety. 2 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business A. Description of the Firm & Shareholders B. Types of Advisory Services C. Investment Management Advisory Services of Client Accounts D. Financial Planning E. Wrap Fees F. Assets Under Management Item 5: Fees and Compensation A. Assets Under Management Fees C. Base Fees D. How Fees are Paid E. Flat Fees for Additional Services or Other Fees F. Refunded Fees G. Custodian Fees H. Foreign Transaction Fees I. Employee Compensation and Additional Payments J. Other Compensation Item 6: Performance-Based Fees and Side-By-Side Management Item 7: Types of Clients A. Tower View Clients B. Brokerage Accounts Custodied at Charles Schwab Institutional C. Outside 401(k)s, Stock Options, Restricted Stock and 529s D. Pledged Asset and/or Margin Accounts: Item 8: Methods of Analysis, Investment Strategies and Risk of Loss A. Types of Analyses & Investments B. Risk of Loss & Investment Risks a. Mutual Fund & ETF Risks: b. Equity Security Risks: i. Stock Market Risks: ii. Foreign Investing Risks: c. Fixed Income Securities: i. Interest Rate Risks: ii. Credit Risks: iii. Call Risks: iv. Liquidity Risks: 1 2 3 5 5 5 6 7 8 8 8 8 9 9 10 10 10 10 10 11 11 11 11 11 11 12 12 12 13 14 14 14 14 14 14 15 15 15 3 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  v. Below Investment Grade Bond Risks: vi. Municipal Bonds Risks: d. Exchange Traded Funds (ETFs) c. Cyber and Identity Theft Risks C. Disaster Recovery D. Key Man Risk Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations Item 11: Code of Ethics, Personal Trading & Conflicts of Interest A. Code of Ethics B. Personal Trading & Conflicts of Interest C. Personal Conduct & Conflicts of Interest A. Company Retirement Savings Plan B. Management of Friend and/or Family Accounts D. Rollover Considerations for Employer-Sponsored Retirement Plans E. Firm Business Brokerage Account F. Employee Compensation G. Independent Contractors H. Founder of Tower View as CCO I. Founder of Tower View serves on the Board of Directors of a Client Item 12: Brokerage Practices A. Brokerage & Custodian Selection B. Advisor Services a. Your Brokerage and Custody Costs b. Products and Services Available to Tower View From Schwab c. Services that Benefit You d. Services That Do Not Directly Benefit You e. Services That Generally Benefit Only Tower View f. Our interest in Schwab’s services C. Research & Soft Dollar Benefits D. Use of Commissions to Gain Clients E. Directing Trades to Brokers of the Client’s Choice F. Trading Practices & Trade Errors Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information 15 15 15 16 16 16 16 16 17 17 18 19 19 20 20 20 20 21 21 21 21 22 22 22 22 23 23 23 23 24 24 24 25 25 25 26 26 27 27 4 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Item 4: Advisory Business A. Description of the Firm & Shareholders Tower View has been in operation since July 1999 as a registered investment adviser. The firm is currently registered with the U.S. Securities and Exchange Commission (SEC). Tower View is majority owned by Raman J Ghei, but also now has six minority stakeholders, none of which have ownership that exceeds 25%. For further details on our shareholders please, contact us directly. B. Types of Advisory Services Tower View offers wealth management services that combine investment management and financial planning to help clients achieve their financial goals. While investment management remains a core service, as it has been the foundation of our business, we also provide financial planning to clients who want additional guidance. In some cases, we may offer financial planning as a standalone service, though it is not a service we currently focus on. Tower View provides investment advisory services for publicly traded securities, including stocks, bonds, exchange-traded funds (ETFs), cash, and mutual funds. We also assist clients with stock options, including advice on expiration dates, exercise strategies, and monitoring positions in restricted stock accounts. Additionally, Tower View may also provide guidance on employer-sponsored retirement plans, including 401(K) accounts as well as 529 education savings plans. ● 401(k) Guidance: Our advisors may offer general asset allocation guidance for 401(k) accounts held with an employer-sponsored plan. However, since these assets are typically held outside our direct management, our role is limited to providing recommendations based on a client’s investment options and financial goals. We do not have discretionary trading authority over 401(k) accounts, nor do we directly manage or monitor them. ● 529 Education Savings Plans: Our involvement in 529 plans varies by client needs. These accounts are typically managed on a non-discretionary basis, where we provide periodic reviews and offer investment recommendations. In a limited number of cases, we may serve in a more active advisory role that includes discretionary trading authority. When this occurs, those 529 accounts are included in our regulatory assets under management (AUM). Additional fees may apply depending on the level of service provided. As part of our services, Tower View may collaborate with clients' attorneys, accountants, and other professionals to help coordinate financial matters. This may include monitoring accounts for tax payments to the IRS, maintaining records of estate planning documents (e.g., wills, trusts, and powers of attorney), and assisting in financial organization. While we do not provide tax or legal advice, we work closely with clients’ attorneys and tax advisors to help integrate financial, estate, and tax planning strategies. However, in no case does Tower View assume custody or control over client assets, nor do we act as a fiduciary trustee, executor, or agent on behalf of any client’s estate or assets. Additionally, we offer guidance on estate and retirement planning, tax-efficient investing, and charitable giving strategies. Our role is to support clients in aligning their financial plans with their 5 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  broader estate and tax planning objectives while ensuring they have the appropriate professionals engaged as needed. C. Investment Management Advisory Services of Client Accounts As part of our investment management process, Tower View provides clients with some form of investment documentation, which may include investment proposal, Investment Policy Statement (IPS), client profile, financial plan or other suitability documentation, depending on the specific circumstances. These documents outline the client’s investment objectives and are based on a review of their financial situation, including but not limited to clients age, investment goals, risk tolerance and time horizon. Because investment needs and preferences are subjective, these plans serve as guiding frameworks and are communicated to clients in writing. Clients are encouraged to review and provide feedback on their investment plans. Tower View monitors client portfolios and assesses asset allocations as part of our ongoing review process. We do not automatically adjust allocations in response to market conditions; however if a client makes a substantial deposit or withdrawal, we will evaluate the portfolio and determine if adjustments are necessary. Additionally, we consider tax implications when making allocation adjustments and generally seek to limit capital gains unless a client specifically directs us to proceed or the client’s circumstances necessitate a change. In addition, we do not as a matter of practice undertake tax-loss harvesting or “tax swaps” unless the client specifically requests this action. We will however, as part of our ongoing review of portfolios, monitor gains/losses in taxable accounts and in certain circumstances not sell an entire position of a stock with a large gain, or defer the sale into the next tax year, or review if a suitable swap candidate exists for a position showing a loss. We manage investment portfolios on both a discretionary and non-discretionary basis. Non-discretionary portfolios are primarily limited to employer-sponsored 401(k) accounts and most 529 education savings plans, where clients have asked us to assist with administration and review, but we do not have discretionary authority or the ability to facilitate trades. In limited cases, we may have discretionary authority over 529 plans, and these accounts are included in our regulatory assets under management (AUM). For our typical discretionary portfolio management service, Tower View has the authority to determine, without first obtaining client consent, which and how many securities are to be purchased or sold in each account. Clients may place reasonable restrictions upon the types of investments to be held in the portfolio, provided that such restrictions are clearly communicated in writing and Tower View maintains authority to accept or reject such restrictions. Client portfolios are generally invested in one or more of several different model portfolios (such as Mutual Funds/ETFs, Stock Yield, Growth/Core, etc), but allocations may vary based on several factors, including account size, available cash, inception date of the relationship, tax considerations, and whether the account is managed individually or as a part of a household. Clients who would like further details about their portfolio structure are encouraged to discuss with Chief Investment Officer, Raman Ghei directly. Portfolios may also hold cash reserves for various reasons, including pending reinvestment after the sale of a security, anticipated withdrawals, or larger ad hoc distributions. Clients should be aware that cash reserves can impact portfolio returns, may generate little or no return, and are included in the calculation of assets under management for fee purposes. 6 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  As a result of the above factors, there has been and will likely continue to be significant variance in portfolio composition and performance between accounts, even if they have similar investment objectives. It is common for clients to be invested in a combination of individual stocks, stock mutual funds/ETFs, bonds and bond mutual funds. Other factors that may influence an account’s investment mix include client preferences, tenure with Tower View, cost basis considerations, liquidity requirements, and overall investment time horizon. Tower View does not engage in market timing or attempt to shift investment allocations in response to short-term economic trends, political developments, or other macroeconomic events. Instead, investment decisions are based on our evaluation of the long-term attractiveness of securities and funds in alignment with each client's objectives. We periodically run weighting and exception reports in an effort to ensure all suitable clients are included in new investment ideas, but not every stock or fund is suitable for every client, and the ultimate determination is at our discretion. We use a best efforts approach to include all clients at targeted weightings, but these weightings will vary based upon account inception date, cash available, tax considerations and cash reserves for clients who regularly withdraw money. Clients should understand there are inherent complexities in the investment of separately managed accounts for a very diverse client base and thus there will always exist wide variances in the composition of client portfolios. D. Financial Planning Tower View offers financial planning services to help clients gain a deeper understanding of their overall financial picture. While investment management remains a core service, we believe that comprehensive financial planning enhances our ability to provide tailored investment strategies that align with a client's broader financial goals. Our financial planning services provide detailed guidance on topics such as retirement planning, budgeting, education funding, social security strategies, outside retirement account reviews, and overall cash flow management. Through this process, we may review and analyze documents such as pay stubs, employer retirement benefits, pension details, and other financial records to help clients make informed financial investment decisions. Each financial plan or discussion is customized based on a client's unique needs and is developed using the information provided to us. It is the clients responsibility to ensure that Tower View has current and accurate financial details, both when initiating a plan and for any future updates. Clients are under no obligation to implement our recommendations and may choose to take action independent or through other providers. Tower View does not provide tax or legal advice, and clients should consult with accountants, tax professionals, and attorneys regarding any legal or tax implications of a specific strategy or recommendation. While we may work closely with these professionals to help coordinate financial decisions, our services should not be interpreted as tax or legal advice. Clients should also be aware that there is an inherent conflict of interest in our financial planning services. For example, in developing a financial plan, we may recommend that a client increase 7 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  investment holdings, which could result in additional assets under our management and an increase in our advisory fees. However, clients are under no obligation to implement our recommendations or utilize Tower View’s investment management services. Our goal is to ensure that clients receive objective financial guidance that supports their overall financial well-being. E. Wrap Fees Tower View does not currently participate in Wrap Fee programs. F. Assets Under Management As of December 31, 2024, Tower View managed approximately $281,900,000 on a discretionary basis, and $0 on a non-discretionary basis. G. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: a. Meet a professional standard of care when making investment recommendations (give prudent advice);a b. Never put our financial interests ahead of yours when making recommendations (give loyal advice); c. Avoid misleading statements about conflicts of interest, fees, and investments; d. Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and e. f. Give you basic information about conflicts of interest. Item 5: Fees and Compensation A. Assets Under Management Fees Tower View charges an annual asset-based management fee that does not exceed 1.50% of a client’s assets under management (AUM). Actual fees may vary based on the specific services provided, and all fees are outlined in each client’s written agreement with Tower View. In some cases, additional financial planning/base/hourly fees may apply, which could result in a client’s total fee rate exceeding 1.50% of AUM. Fees may be adjusted based on factors such as the complexity of a client’s financial situation, the number of household or related accounts, the scope of investment management versus financial planning services, the length of the client relationship, and the client’s preference for a more active or passive advisory relationship. Fee rates are subject to change over time. Any fee increase will be communicated in writing and must be agreed to by the client before taking effect. 8 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Management fees are not dependent upon changes/transactions in each account/portfolio, and fees are still due even when no transactions occur. In addition, at times, client funds may be held in cash or cash equivalents, such as a money market fund, bank deposit, cash, or cash equivalents. This may be for a variety of reasons such as finding an appropriate investment opportunity or to fund pending client withdrawals. Funds in cash are still typically subject to management fees. B. Financial Planning and Consulting Fees Tower View generally seeks to offer wealth management services under an asset-based fee structure, which includes both financial planning and portfolio management. While financial planning and consulting fees may be included in a clients overall-asset based management fee, in certain cases, additional fees may apply if the scope of the planning services goes beyond what is reasonable under the clients AUM-based fee or if planning is provided as a standalone service. For clients receiving comprehensive financial planning services, Tower View may charge a quarterly base fee, hourly rates, project-based fees when planning services extend beyond what is included in a standard wealth management engagement. Financial planning services may include areas such as retirement planning, tax strategies in coordination with tax professionals, estate planning guidance in collaboration with attorneys, budgeting and cash flow analysis, and general financial planning advice. Any fees for financial planning or consulting services will be fully disclosed in advance, including payment terms. While Tower View has the discretion to waive or adjust financial planning fees in certain cases, clients will always be notified and given the option to accept or decline additional services. C. Base Fees Clients may pay Tower View a quarterly base fee; these fees are paid in advance for next three months of service, and should the client terminate the agreement the client would receive a pro-rata refund (by day) of any base fees. These fees can either be paid alongside the client's assets under management quarterly invoice fees, or they may have the option to make payments with a secure and compliant invoice system allowing the client to pay with credit card, ACH or Venmo. These fees cover the ongoing financial planning or consulting services provided by Tower View. D. How Fees are Paid Clients may pay their management fees through direct deduction from their investment account(s) or by check. Fees are billed on a quarterly basis, in advance unless stated otherwise. If a client wishes to pay via an alternative method, such as credit card, ACH, or Venmo, we may consider a secure and compliant system like AdvicePay on a case-by-case basis. For new accounts, fees will be prorated based on the number of days the account was funded during the initial quarter. If a client terminates their advisory relationship with Tower View, any prepaid, unearned fees will be refunded. However, fees are not prorated or refunded for accounts that are simply closed or depleted during a billing period. . 9 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Additionally, clients can, for any reason, cancel their management agreement within the first five (5) business days of execution, without incurring any advisory fees, including, but not limited to, our failure to provide our firm’s ADV disclosure brochure at least 48 hours prior to signing the investment advisory contract. E. Flat Fees for Additional Services or Other Fees In addition to our standard asset-base fees, Tower View Wealth Management may charge flat fees for clients requiring additional services beyond traditional wealth management. These additional fees apply in situations involving complex estate settlements, divorce financial planning, business transitions, or other extraordinary planning needs. The fee amount is determined based on the complexity, administrative workload, increased client support, and coordination time requirement to manage the engagement. In certain circumstances clients may be subject to additional fees such as administrative fees, hourly consulting rates, or project-based fees. These fees may be one-time, recurring, or periodic in nature. All additional fees will always be disclosed upfront to a client including the fee amount, frequency, payment terms, and include a description of the fee's purpose or scope of service. Our maximum hourly rate is $500 per hour and flat or project based fees may start at $100 but will not exceed $50,000. Some of our historical agreements may discuss per brokerage account administrative fees, but at the moment we do not currently charge those types of fees, but could do so if a an agreement includes that language. F. Refunded Fees Quarterly fees will not be prorated or refunded if a client withdraws assets from an Account, but if Client closes an Account or removes Tower View as the advisor on an account during a calendar quarter then a prorated refund will apply. G. Custodian Fees Tower View’s management fees do not include brokerage commissions, transaction fees, and other related costs and expenses which could be incurred by the client. Clients could incur certain charges imposed by custodians and brokers, such as transfer fees, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts, ADR holdings and securities transactions. H. Foreign Transaction Fees Tower View uses Charles Schwab as its primary custodian. Previously, Schwab offered reduced foreign stock transactions fees, but as of early 2023, this benefit has been discontinued. Clients are now typically subject to a $50 foreign transaction fee per trade executed in a foreign market. Since Tower View executes only a limited number of foreign trades annually, we will review all foreign trade transactions and, at our discretion, may refund a portion of a foreign transaction fees that exceed approximately 3% of the trade value by providing a credit to the client’s brokerage account. I. Employee Compensation and Additional Payments Tower View employees receive a base salary and may be eligible for cash bonuses and/or profit-sharing contributions. Bonuses are based on overall firm profitability and individual job performance. Compensation is not tied to recommended investments, referrals or new accounts. 10 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  In limited cases Tower View charges a separate flat fee for additional services due to complex client situations, such as estate or divorce matters requiring extensive administrative work, coordinating with attorneys, accountants or other professionals. An employee who takes on significant additional work beyond their typical responsibilities may receive a portion of the revenue collected as compensation for the extra hours the employee needed to work to complete the requested tasks in the time frame requested by the client. This arrangement is designed solely to compensate for work that requires substantial extra time and effort beyond standard wealth management services. Profit-sharing contributions made to employee retirement accounts are governed by Tower View’s 401(k) plan document and are not discretionary based on individual based performance. All such contributions follow the plan's stated allocation formula and are provided on non-discriminatory basis in accordance with ERISA rules. We use a third-party plan administrator, BlueChip who oversees our employee plan. J. Other Compensation Tower View does not accept any sales charges or compensation for the sale of any securities or investment products. Item 6: Performance-Based Fees and Side-By-Side Management Tower View does not charge performance fees or engage in side-by-side management. Item 7: Types of Clients A. Tower View Clients Tower View provides investment advisory and wealth management services to individuals, businesses, pension plans, and at times for other investment professionals. The firm does not impose a minimum relationship size and serves clients with assets under management ranging from below $100,000 to over $10 million. B. Brokerage Accounts Custodied at Charles Schwab Institutional Tower View manages client investment accounts held at Charles Schwab Institutional, using Schwab’s platform to execute trades, monitor portfolios, and assist with other administrative matters. C. Outside 401(k)s, Stock Options, Restricted Stock and 529s Tower view may provide advisory guidance on client-held accounts that are not held with Charles Schwab, such as 401(k)s, Stock Options, Restricted Stock and 529 education savings plans., Tower View helps with reviews of client’s accounts of these types, if asked by the client. These accounts are not linked to Tower View’s institutional relationship with Charles Schwab. Tower View may offer advice on how to allocate 401(k) and 529 investments, based upon trying to limit investment 11 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  management costs to the client and to tailor the investment objectives and risk tolerances of the client to these outside accounts. D. Pledged Asset and/or Margin Accounts: Clients who pledge assets in their advisory accounts as collateral for loans or margin accounts should be aware of the associated risks. A lender whether Schwab or another institution may exercise control over the pledged assets, including liquidating positions, which could be contrary to the clients interest and investment strategy. In the event of a margin call or collateral requirement, assets in the advisory account may be liquidated without prior notice, potentially at unfavorable prices or in an inefficient tax manner. Neither the client nor Tower View may have discretion over which assets are sold. Clients considering a pledged asset strategy should carefully evaluate these risks and consult with Tower View before proceeding. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss A. Types of Analyses & Investments While not every investment is ultimately held for a long period of time, our goal is to be a long-term investor and we do not initiate trading or market timing trades in accounts. We seek to invest in companies (and funds which hold such companies) which we believe have balance sheets which do not pose risks to the company as a going concern, growth prospects which can support the current valuation and market positions which have competitive strengths. All of those characteristics, however, are subjective in nature and do not guarantee positive returns. We will sell or trim securities when they reach what we believe to be full or overvalued levels or we have concerns about their growth prospects, balance sheet or competitive positions. The final determination for these factors is based upon the opinion of Tower View and is very subjective and we do not adhere to any strict valuation criteria or quantitatively driven models or methodologies, and our opinions will vary over time. Our type of investment strategy is often referred to as “bottoms up” as it is stock or fund specific and not driven by economic forecasts or other “top down” macro-economic factors. We consider ourselves to be active investment managers, in that we are not seeking to simply replicate the holdings of a particular stock or bond market index (such as the Russell 1000), although we often hold more passively managed ETFs and/or mutual funds in client portfolios. for clients and which are not. We do not It is solely at the discretion of the Chief Investment Officer to determine/decide which investments he believes are suitable follow strict growth/value/momentum or other strategies and methodologies, and therefore there is a wide variance in the types of investments we will make. Suitability is a highly subjective issue and the selection criteria the Chief Investment Officer uses to determine which securities to purchase for clients is solely at his discretion. In portfolios holding individual stocks, we typically invest in a mix of three different types of stocks: those we consider larger and more mature, those we consider more growth oriented and those which we consider higher risk/emerging. We also can invest internationally in both developed and emerging markets via both ADRs and direct ordinary shares. We also can invest in companies with 12 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  small market capitalizations of under $100 million and large companies with market capitalizations over $500 billion. We may invest in companies which are not profitable. In portfolios holding ETFs (exchange traded funds) and or mutual funds, we typically seek to invest in more “passive” funds in order to limit fund expenses, but there may be exceptions. Due to the inherent nature of mutual funds and ETFs, not all the individual holdings in those ETFs/Funds would normally meet all our selection criteria and in fact they can include securities we would typically not hold in portfolios. We believe however, that the overall diversification provided by these funds/ETFs outweigh this potential negative factor. The ETFs and mutual funds held in portfolios are selected with the goal of being diversified by company size, market sector, and geography and focus on the areas one finds most attractive. Our investment processes inherently contain risks of significant loss, but also incorporate other risks such as foreign currencies and liquidity. Tower View’s method of security analysis relies heavily on personal opinions, publicly available financial publications and company provided materials. We do not use technical analysis, create earnings models, visit companies or typically communicate with analysts or investment relations departments. While the mutual funds and ETFs we invest in would generally be considered “passive” investments, Tower View uses an active management style which involves looking at various stock markets around the world to identify the stocks, bonds and mutual funds which we believe represent good long-term investments. Individual bond purchases are selected using the same methods as equities, with a reliance on generally available ratings of credit quality. A significant portion of bond investments are made via bond mutual funds, including taxable, government, municipal and high yield (below investment grade) bonds. Before purchasing individual bonds in a portfolio, we will review the bond’s credit rating - either investment grade or below investment grade - and also the composition of a client’s portfolio. The bond portfolio, like the stock portfolio, is diversified by type of issuer and maturity schedule, and therefore maximization of yield is rarely the determining factor in a bond purchase. Individual bonds are purchased through Charles Schwab’s trading department, and thus we rely on their offerings. All investments in financial assets carry risks including but not limited to: market risk, transaction costs, poor investment choices and unexpected changes in one’s personal circumstances, requiring portfolio shifts at inopportune times. Investing in securities involves risk of loss that clients should be prepared to bear. B. Risk of Loss & Investment Risks Investments with Tower View carry significant risk of volatility and thus are subject to potential, short-term and/or permanent loss of value and income. Tower View invests in foreign stocks and below investment grade bonds which carry additional currency, credit and liquidity risks. Climate change represents an emerging risk factor for investors in financial assets, such as stocks, mutual funds and bonds. At this time it is difficult to determine what the ultimate impact might be, but could include, among other things, reduced company profits and dividends due to rising costs associated with limiting chemical and other emissions, changing consumer buying patterns due to environmental concerns and new laws and regulations, slower global GDP growth and more restrictive trade policies as countries seek to penalize countries that they believe are heavier polluters. These factors could reduce future returns for investors and create higher levels of credit risk and market volatility. 13 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  In addition, clients are subject to the following set of risks, which is not meant to be a complete list of all the risks an investor can face when investing in any of these types of securities. a. Mutual Fund & ETF Risks: Mutual funds are subject to investment advisory, transaction, marketing, operating and other expenses. Each mutual fund is also subject to specific risks related to the nature of its investments. The value of the fund’s underlying investments and the NAV of the fund will fluctuate along with changes in market prices and conditions. For more information, we encourage shareholders to review the fund prospectus. In addition, different funds held by the Client can purchase the same security, increasing the risk to the Client if that security were to fall in value. There is also a risk that a manager of the fund can deviate from the stated mandate or strategy of that fund, which could make the holding(s) less appropriate for the client’s portfolio. b. Equity Security Risks: Clients with all or a part of their accounts invested in equity-focused mutual funds and individual equity securities are subject to the following risks, among others: i. Stock Market Risks: Investments in stocks are subject to fluctuations in the stock market, which can rise or fall sharply in value over short periods of time. Stocks are historically more volatile than bonds. We also invest in smaller companies (determined by either sales, market value or both), and generally a company with smaller market value has fewer shares traded daily, making the stock less liquid and its price potentially more volatile, and this can negatively impact the price paid or received when trading in it. Companies with smaller market values also tend to have shorter track records, a limited product or service base and a limited access to capital. These factors can increase the risk that these companies could suffer poor results or fail. ii. Foreign Investing Risks: Investments in foreign companies, via either ADRs or purchase of ordinary shares, and ETFs or mutual funds which hold foreign stocks carry a number of economic, financial and political risks above and beyond those of U.S. companies and markets, which could unfavorably affect account performance. The potential risks are greater price volatility, weak supervision and regulation of securities exchanges, brokers and issuers, higher brokerage costs, fluctuation in foreign currency exchange rates and related conversion costs, adverse tax consequences, and settlement delays, among others. Moreover, dividend payments from the company are subject to currency risks, if the dividend is paid in a currency that is declining in value against the dollar, the dividend would be worth less to a U.S. resident. Additionally, if a country's currency falls in value, this decline will result in a decrease in the value of your ADR or direct foreign stock holding, even if the stock in local currency terms were to remain stable. c. Fixed Income Securities: Client accounts with all or a portion of the assets and/or mutual funds whose underlying assets are invested in fixed income are subject to the following risks: i. Interest Rate Risks: Prices of fixed income securities rise and fall in response to changes in the interest rate paid by similar securities. Generally, when interest rates rise, the prices of fixed income securities fall. 14 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Fixed income securities with longer maturities are generally more affected by interest rate changes, as they carry what is known as a longer duration. ii. Credit Risks: Credit risk is the possibility that an issuer will default on a security by failing to pay interest or Founder when it is due. If an issuer defaults, a fund holding securities of that issuer can lose money, and investors with direct holdings in that bond will also likely lose money. Fixed income securities with higher credit risk typically have lower credit ratings, and at a certain rating level are considered speculative. iii. Call Risks: Fixed income securities with a call date (callable bonds” can be redeemed (or called) by the issuer before maturity. A fund that invests in callable bonds that are called, could have to reinvest the proceeds in securities that pay a lower interest rate, which can decrease the portfolio’s overall yield. This is more likely to happen when interest rates are falling. iv. Liquidity Risks: Liquidity risk refers to the possibility that a fund or investor would not be able to sell or buy a bond at a favorable price or time. Consequently, the fund could have to accept a lower price to sell a security, sell other securities to raise cash or give up an investment opportunity, any of which could have a negative effect on the investor’s performance. v. Below Investment Grade Bond Risks: Low rated/high yield securities (sometimes called Junk Bonds) are rated below investment grade, and thus tend to be more sensitive to economic conditions than higher-rated securities and generally involve more credit risk than bonds in the higher-rated categories. The risk of loss due to default by an issuer of below investment grade bonds is significantly greater than investment grade bonds because such securities are generally unsecured and are often subordinated to other creditors. Below investment grade bonds can also have liquidity risk. A fund can have difficulty disposing of certain below investment grade bonds because there can be a thin trading market for such securities due to there being fewer potential buyers. This would be especially true during periods of economic and/or market stress. vi. Municipal Bonds Risks: Municipal bonds are subject to risks, including economic and regulatory developments, changes or proposed changes in the federal and state tax structure, deregulation, court rulings and other factors. The value of municipal bonds can also be affected by liquidity risk, credit risk and market interest rate risk. Repayment of municipal bonds depends on the ability of the issuer or project backing such securities to generate taxes or revenues. There is a risk that the interest on an otherwise tax-exempt municipal security can be subject to federal income tax. d. Exchange Traded Funds (ETFs) ETFs are investment funds that can track an index, commodity, currency, or sector and are traded like common stock on a stock exchange. They experience price changes throughout the day as they are bought and sold. ETFs try to replicate the performance of their corresponding index, but there is no guarantee that the prices paid or realized for an ETF will match the underlying value of the holdings in the fund, particularly during times of market stress or reduced liquidity. In addition, as we do not control the underlying investments in a fund or ETF, and managers of different funds held by the client can 15 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager of the fund or ETF can deviate from the stated strategy of that fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. c. Cyber and Identity Theft Risks Although Tower View makes every attempt to monitor client accounts, we cannot guarantee that if an account becomes compromised at the Schwab website by an authorized or unauthorized person, that the firm would discover such an event. While Schwab maintains protections against unauthorized access, it does not cover anyone you have provided your credentials, including authorized family members, etc. To help mitigate risks, Tower View may periodically provide recommendations for enhancing account security and offer guidance on cybersecurity best practices. Likewise, if a client chooses to custody their assets elsewhere, Tower View would be unable to monitor the account. Tower View also currently holds a cyber security insurance policy which, within the terms and limitations of the policy, could assist clients in the event a cyber breach occurred at Tower View. As a matter of policy Tower View does not reimburse clients for cyber security and or identity theft losses, and clients should recognize that despite our best efforts in this area, there can be no assurances that a cyber breach can be avoided. Clients are strongly encouraged to immediately contact us in the event they believe any of their personal information has been compromised at Schwab or any other financial institution or their email has been hacked. Charles Schwab maintains a 24 hours, 7 days a week Fraud hotline that clients should immediately call with any concerns. That number is 1.877.862.6352. C. Disaster Recovery Tower View maintains disaster recovery plans and procedures. Clients may request a copy of this at any time. Force Majeure Events Risk: This is the risk that there may be an act of God, terrorist act, global health pandemic, failure of utilities or other similar circumstances not within the reasonable control of Tower View that may have an unknown and potentially catastrophic effect on the global markets. D. Key Man Risk As a small firm, Tower View also carries key-person risk, as the Founder and CIO plays a critical role in investment decisions. In the event of incapacity or departure, clients may experience some level of disruption. However, since clients assets are held at Charles Schwab, access to accounts and funds would not be affected. Item 9: Disciplinary Information Tower View and our investment adviser representatives have not been involved in any events that require disclosure. Nor have they ever been subject to any financial industry disciplinary actions, or events material to a client's or prospective client's evaluation of the supervised person. Item 10: Other Financial Industry Activities and Affiliations 16 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Tower View does not have any affiliations with broker-dealers, investment firms, insurance companies, banks or other financial institutions. We do not maintain any formal partnerships, ownership interests, or fee-sharing arrangements with external financial firms, nor do any of our employees act as broker-dealers, insurance agents or commodity traders. Tower View does not have any formal referral agreements with outside professionals, such as accountants, attorneys, or financial planners. However, upon client request, we may provide referrals to outside professionals as a courtesy. These referrals are based on our general knowledge and experience but do not constitute an endorsement or recommendation. Tower View does not receive compensation or benefits for referring outside professionals. Clients are encouraged to conduct their own due diligence before engaging any referred professionals. No one at Tower View has a relationship with any of the following entities which we believe would create a potential conflict of interest. 1. Broker dealer, municipal securities dealer, or government securities dealer or broker 2. Investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company, or an offshore fund) 3. Other investment adviser or financial planner 4. Futures commission merchants, commodity pool operator, or commodity trading advisor 5. Banking or thrift institution 6. Accountant or accounting firm 7. Lawyer or law firm 8. Insurance company or agency 9. Pension consultant 10. Real estate broker or dealer 11. Sponsor or syndicator of limited partnerships Tower View does not formally recommend or select outside advisers for clients, except in cases where such relationships are included as part of the firm’s business continuity planning. Item 11: Code of Ethics, Personal Trading & Conflicts of Interest A. Code of Ethics Tower View’s Code of Ethics contains policies and procedures designed to identify and mitigate potential conflicts of interest. While we do not believe that there are any present conflicts that pose material risks to the firm’s interests, there are some potential conflicts that are inherent in the firm’s 17 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  structure and activities. We utilize procedures in place to mitigate their effects and uphold our fiduciary duty to clients. Tower View uses an internal Code of Ethics (the “Code”) which, in general terms, forbids any practices which are either illegal or against the best interests of our clients. The Code generally sets the standard of ethical and professional business conduct that we require of our Supervised Persons, requires Supervised Persons to comply with applicable federal securities laws and regulations, and sets forth provisions regarding personal securities transactions by certain Supervised Persons deemed access persons under applicable regulations. Additionally, the Code sets forth Tower View’s policies and procedures with respect to material nonpublic information and other confidential information, and the fiduciary obligations that we and each of our Supervised Persons owes to every advisory client. We will provide a copy of the Code to any existing or prospective client upon request. To request a copy, please reach out to us using the contact information on the Cover Page of this brochure. B. Personal Trading & Conflicts of Interest Tower View employees, including the Founder and his family may purchase or sell the same securities we purchase for our clients, within the confines of the firm’s personal trading restrictions and procedures. Tower View’s employees and the Founder routinely invest in the same securities as clients, which ensures employees and clients share a vested interest in the security’s performance. Employees must provide Tower View with oversight over the account’s trading activity, although exceptions can be made. The Founder’s portfolio typically holds the same individual stocks that we use in our client portfolios, but it is not a requirement that he adheres to this. Employees and the Tower View Savings Plan accounts (including the Founder’s 401k & Roth 401k) may participate in client block trades or trade simultaneously with other trades if the Founder determines that doing so will not disadvantage clients. The Founder and his family/acquaintance accounts may also be included in block trades and simultaneous trades alongside clients. All employee trades are subject to compliance oversight to ensure adherence to trading policies. From time to time, the Founder may hold a position in a security which subsequently becomes a model portfolio holding. It is solely at the discretion of the Founder to determine/decide which investments he believes are suitable for clients and which are not. The Founder may purchase securities for himself and his family which are not purchased for clients. Suitability is a highly subjective issue and the selection criteria the Founder uses to determine which securities to purchase for himself and his immediate family and for clients is solely at his discretion. Tower View maintains a Code of Ethics and Personal Trading Policy (The Code) which governs personal trading by Tower View employees and the Founder. The Code, among other items, requires employees and the Founder to adhere to ethical standards established by the firm and requires all employees, the Founder and their immediate families to periodically provide the Founder/Chief Compliance Officer and the Chief Operating Officer with reports of any and all personal security holdings and transactions. Employee accounts, the Founder’s accounts, and the accounts of the Founder’s immediate family, along with a few close acquaintances of the Founder, are held in a private master account at Schwab institutional. Employee accounts and the Tower View Savings Plan assets are discretionary AUM 18 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  assets. All other accounts in the private master account are not part of Tower View’s advisory services and are managed separately by the Founder at his own discretion. However, all accounts in this private master may be included in block trades or trade simultaneously with client trades, provided they adhere to the firm's trading rules. Tower View is aware that personal trading can potentially create conflicts of interest and thus has put the following procedures in place: 1. Day trading will not be initiated for individual stocks or ETFs. 2. Employee accounts and employee savings plan accounts, including the Founder’s savings plan accounts, may participate in block trades or execute trades simultaneously with client trades without restrictions on trade timing. 3. The Founder’s personal accounts, his family account, and the other non-advisory account(s) in the private master account may be included in block trades with clients. If they are not included in a block trade, any trades in model securities within these accounts must only occur after the client block trade has been completed and never before. 4. Any exceptions to trading rules will be documented. 5. All accounts in the private master account, including employee accounts, employee Tower View Savings Plan accounts, and accounts belonging to the Founder, his family and a few close acquaintances are maintained separately at Schwab Institutional to ensure clear separation from managed client accounts. 6. Employee and Founder-related trades are reviewed for adherence to compliance rules. 7. Tower View reviews employee, Founder-related, and client block trades to ensure compliance with the firm’s personal trading policies. This includes monitoring trades within the Founder’s, immediate family’s, and acquaintances’ accounts for adherence to compliance rules. Any discrepancies are documented and addressed as necessary. One of the Founder’s children, Natalie Cumming, is now an employee of Tower View (as of 1/1/2024). The trading rules surrounding her investment accounts will default to the rules for employees, not family members, and her accounts will be managed accordingly. Clients should recognize that due to these various trading rules, employees and the Founder of Tower View (and his family and related accounts) may receive better or worse prices than clients. C. Personal Conduct & Conflicts of Interest A. Company Retirement Savings Plan Tower View maintains a company sponsored retirement savings plan for its employees, allowing employees to establish traditional and Roth 401k accounts. These accounts are invested using ETFs, model portfolio holdings and mutual funds. These accounts are generally invested along the same lines as other 401(k) and small mutual fund accounts maintained by clients. While a potential conflict of interest could arise in managing employee retirement plan accounts, Tower View has internal compliance measures in place to ensure that these accounts are not given preferential treatment. Trading activity is reviewed for adherence to firm policies and regulatory requirements, helping to minimize any potential conflicts. 19 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  B. Management of Friend and/or Family Accounts Tower View manages some investment accounts for individuals deemed friends or family members (other than the Founder’s immediate family/acquaintances, which are covered by separate trading rules, as noted above in Part B), all of which are standard investment relationships. While this could create some conflicts of interest, we believe that since these accounts are managed on an arm’s length basis - using the same trading rules, management agreements, investment objectives and model portfolios as our other clients - the conflicts of interest are managed in a way that does not negatively impact our other clients, nor positively affect the friend or family member. Accounts managed for the Founder’s immediate family are not managed under the supervision of Tower View, except for monitoring activity to make sure they meet our compliance trading rules. One of the Founder’s daughters is employed by a leading accounting firm that maintains a restricted list of companies for which it provides audit services. As a result, she is prohibited from owning stocks on that restricted list. Therefore, that work requirement will supersede the Tower View trading and holdings guidelines and rules. In the event a Tower View stock ends up on her work related restricted list, we will have to sell it from her account, even though it will be a model stock held in client accounts and in the Founder’s personal accounts. D. Rollover Considerations for Employer-Sponsored Retirement Plans Tower View may discuss rollover options for clients with assets in employer-sponsored retirement plans, such as 401(k), 403(b), or pension plans. Clients may have multiple options, including: ● Leaving assets in their current plan (if permitted by the plan sponsor) ● Rolling over assets into a new employer’s plan (if applicable) ● Rolling over assets into an individual retirement account (IRA) ● Taking a lump-sum distribution (which may have tax implications Because Tower View charges an asset-based management fee, rolling assets into an IRA managed by Tower View may result in higher fees compared to leaving assets in an employer-sponsored plan. This creates a potential conflict of interest. To ensure transparency, clients considering a rollover are provided with a rollover disclosure form, outline plan details, investment options, and associated fees. Clients are encouraged to review all available options. E. Firm Business Brokerage Account Tower View Wealth Management maintains firm-owned, non-advisory accounts, that hold firm capital and are managed at the Founder’s discretion. These accounts are maintained at Charles Schwab in a private master account and are used for operational purposes, including business expenses, payroll, and tax obligations. They are separate from the firm’s client advisory services and are not included in the firm’s regulatory assets under management. The Founders management of these accounts does not impact or influence the investment decision made on behalf of clients. F. Employee Compensation Tower View employees receive a base salary and may be eligible for cash bonuses and/or profit-sharing contributions. Bonuses are based on overall firm profitability and individual job 20 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  performance. Compensation is not tied to the time spent on any one client, specific investment recommendations, referrals, or new accounts. For details on additional compensation related to specific client services, please refer to Item 5 – Fees and Compensation. Tower View maintains a fiduciary duty to ensure that all employees act in the best interest of clients, regardless of compensation structure. G. Independent Contractors Tower View currently and has traditionally utilized a small number of independent contractors. In some cases, these independent contractors have also been clients or have become clients. We mitigate conflicts of interest by following the same set of trading rules and standard client procedures regardless of their affiliation or previous affiliation as a contractor for the firm. H. Founder of Tower View as CCO This dual role includes supervision of employee actions, monitoring of trading and other client issues and enforcement of Tower View’s compliance policies. The circumstance creates a conflict of interest based upon “self-enforcement.” Tower View thus monitors the Founder’s personal trading and company block trading for compliance with our stated rules. We also utilize the outside services of a compliance consulting firm to evaluate our practices and procedures, and review periodically our trade records. I. Founder of Tower View serves on the Board of Directors of a Client Raman J Ghei, the Founder and CCO of Tower View, now serves on the Board of Directors of a company for which we also perform advisory services. While this creates a conflict of interest, we believe that since these accounts are managed on an arm’s length basis - using the same trading rules, management agreements, investment objectives and model portfolios as our other clients - the conflicts of interest are managed in a way that does not negatively impact our other clients, nor positively affect the business and other board members. Mr. Ghei, as an individual, receives a stipend (under $1000) per quarter for this board service. In addition, Mr. Ghei will abstain from any type of voting on the Board related to the task of hiring or evaluating their investment advisory services. Trades involving accounts related to the company may be periodically reviewed to ensure no preferential trading treatment. Item 12: Brokerage Practices Tower View periodically reviews available brokerage and custodial services to evaluate whether Charles Schwab’s offerings, pricing and execution quality remain competitive with comparable alternatives. As part of our Best Execution Policy, we review factors such as commission rates, pricing, customer service, educational resources, research offerings and other factors. Currently, Tower View utilizes Charles Schwab as our sole custodian and broker-dealer for client accounts. While we recommend Schwab, clients decide whether to use Schwab and must enter into a separate account agreement directly with them. Tower View is independently owned and operated and has no affiliation with Schwab. For more details on Schwab’s services and associated conflicts of interest, refer to Item 14, Client Referrals and Other compensation. 21 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  A. Brokerage & Custodian Selection We currently only use Schwab, a custodian/broker, to hold your assets and execute transactions. When considering whether the terms that Schwab provides are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: ● Combination of transaction execution services and asset custody services (generally without a separate fee for custody) ● Capability to execute, clear, and settle trades (buy and sell securities for your account) ● Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) ● Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.) ● Availability of investment research and tools that assist us in making investment decisions ● Quality of services ● Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices ● Reputation, financial strength, security and stability ● Prior service to us and our clients ● Services delivered or paid for by Schwab ● Availability of other products and services that benefit us, as discussed below (see “Products and services available to us from Schwab”) ● General client familiarity with and comfort with Schwab, as well as our clients feedback on their experiences with Schwab. B. Advisor Services a. Your Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). By using another broker or dealer you may pay lower transaction costs. b. Products and Services Available to Tower View From Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an 22 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: c. Services that Benefit You Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. d. Services That Do Not Directly Benefit You Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: ● Provide access to client account data (such as duplicate trade confirmations and account statements) ● Facilitate trade execution and allocate aggregated trade orders for multiple client accounts ● Provide pricing and other market data ● Facilitate payment of our fees from our clients’ accounts ● Assist with back-office functions, recordkeeping, and client reporting e. Services That Generally Benefit Only Tower View Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: ● Educational conferences and events ● Consulting on technology and business needs ● Consulting on legal and related compliance needs ● Publications and conferences on practice management and business succession ● Access to employee benefits providers, human capital consultants, and insurance providers ● Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab, we would be required to pay for these services from our own resources. While these services are of benefit to us, we believe that our use of the services that only benefit us are modest in scope, and could be replaced by other providers at a reasonable cost to us, in that we already pay for outside compliance and legal help. In addition, these services are generally offered by other institutional brokers and thus the conflicts of interest in our use of Schwab are limited. f. Our interest in Schwab’s services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to request the use 23 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and not Schwab’s services that benefit only us. C. Research & Soft Dollar Benefits Soft Dollars are the receipt of goods and/or services from a custodian in connection with providing advice to clients is seen by regulators as “soft dollars.” The additional services that we and other independent advisors may receive from Schwab, as disclosed in the section entitled “Advisor Services” above, would fall under this description of soft dollars. Tower View does not maintain nor intend to start any other soft-dollar arrangements, whereby we would receive specific services that would normally be purchased in “hard dollars,” in exchange for directing client brokerage commissions to brokers other than Schwab. Tower View recommends that clients establish brokerage accounts with the Schwab Institutional Division of Charles Schwab & Co., Inc. (Schwab) to maintain custody of clients’ assets and to settle trades for their accounts. Although Tower View commonly recommends its clients establish accounts at Schwab, it is ultimately the client’s decision to custody assets with them. Tower View is independently owned and operated and thus not affiliated with Schwab. Schwab provides Tower View with access to its institutional trading and custody services which typically are not available to Schwab retail investors. These services are not contingent upon Tower View committing any specific amount of business with Schwab (i.e. assets in custody or trading commissions) other than Schwab’s internally determined minimum sizes for an institutional relationship. Schwab’s brokerage services include the execution of security transactions, custody, research, and may include access to mutual funds and other investments that are otherwise typically only available to institutional investors with a higher minimum initial investment. Tower View does benefit from these services, some of which might otherwise incur a cost to the firm if we did not custody with Schwab. For Tower View client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees, such as on cash deposits, for securities trades that are initially executed through Schwab or that settle into Schwab accounts. D. Use of Commissions to Gain Clients Tower View does not direct any brokerage commissions in exchange for client referrals. E. Directing Trades to Brokers of the Client’s Choice Clients are permitted to select a custodian other than Schwab to execute their trades and custody their investments. In making such an instruction, the client may lose any savings on execution costs that Tower View could obtain for other clients, such as cost savings from negotiated commission discounts. Clients who use different brokers may also receive higher or lower transaction prices or commission rates. Tower View does not allow clients who are custodied at Schwab to direct trades to a specific outside broker. 24 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  F. Trading Practices & Trade Errors If you have questions about our trading practices and handling of trade errors you may contact us for further information. Item 13: Review of Accounts Investment Management Tower View regularly monitors client investment accounts as part of our ongoing portfolio management process. The Chief Investment Officer (CIO) reviews accounts daily considering factors such as company conditions, capital markets and recent economic and market developments. Additionally, the CIO periodically reviews each client’s account to monitor cash levels, asset allocation and position sizes. Clients receive both brokerage statements from their custodian and Quarterly Statements from Tower View. Tower View statements always include the client’s billing statement(s) and typically include a letter discussing strategy or other issues deemed of interest or relevancy. Clients may also elect to have the statements from their custodian sent to them electronically via email. Clients are encouraged to review all correspondence for errors and omissions and contact Tower View if any are found. Financial Planning For clients who engage Tower View for financial planning services, financial plans may be developed early in the client relationship, particularly for newer clients, with adjustments made as needed. Financial planning discussions are conducted periodically and are often included as part of a client’s annual review meeting. These discussions may include a review progress toward retirement and other financial goals, potential adjustments to financial objectives, and updates related to cash flow, budgeting, tax strategy, estate planning or risk management considerations. Financial planning reviews are tailored to each client’s circumstance and may occur alongside investment management discussions or as separate planning sessions. Item 14: Client Referrals and Other Compensation Tower View does not currently pay any compensation to outside sources for client referrals, nor do we currently have any active solicitation agreements in place. However, we may enter into such agreements in the future, and if we do, we will provide appropriate disclosures in accordance with applicable regulations. Tower View does not receive direct compensation from Schwab or any other custodian for referring clients, nor does Schwab refer clients to Tower View. However, Schwab provides platforms such as Find Your Independent Advisor and other resources where advisory firms, including Tower View, may list their services for potential clients to find and evaluate. Participation in these platforms does not require us to meet specific asset or revenue thresholds, nor does it obligate us to refer clients to Schwab in return. 25 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  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. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the referral arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12—Brokerage Practices). Schwab does not refer clients to us. Tower View may occasionally provide informal referrals to accountants, attorneys or other professionals at a client’s request. However, we do not receive compensation for these referrals, nor do we have formal referral agreements with any outside professional at this time. Item 15: Custody Tower View Wealth Management does not maintain custody of client assets under SEC rules. While we have discretionary authority to transfer funds between a client’s own accounts at the same custodian (e.g., Schwab brokerage to Schwab IRA), this does not constitute custody, as these accounts remain under client ownership and control. Schwab (or your other custodian) maintains actual custody of your assets. You will receive account statements directly from your custodian at least quarterly, sent to the email or postal mailing address you provided. We encourage you to review these statements carefully and compare them with any portfolio reports you receive from us. Tower View does not have the authority to move client funds to third parties. All third-party money movements require direct client approval, and we do not have the ability to edit or update third-party transfer instructions. Item 16: Investment Discretion Tower View primarily manages investment portfolios on a discretionary basis. Therefore, Tower View has discretionary authority to determine, without obtaining specific client consent, both which and how many securities are to be purchased or sold in each account deemed discretionary. Tower View also is able to assist with accounts on a non-discretionary basis, on a case by case basis, depending upon the relationship desired by the client. Clients are able to impose reasonable investment restrictions such as the retaining specific securities or excluding certain investments. However, all restrictions must be communicated in writing, and Tower View reserves the right to accept or decline such limitations based on their impact on portfolio management. . As part of our discretionary authority, clients sign a Limited Power of Attorney with Schwab granting Tower View trading and fee paying authorization. Additionally, all clients must sign a Tower View Management Agreement, which outlines the scope of our investment discretion and responsibilities. 26 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Item 17: Voting Client Securities Tower View does not vote proxies on behalf of its clients. Clients are solely responsible for receiving and voting all proxies and other shareholder communications related to securities held in their accounts. All proxy materials will be sent directly to clients by their custodian or issuing company. Tower View does not provide guidance on how to vote proxies, nor do we accept authority to vote on behalf of clients. Clients may request a copy of Tower View’s Proxy Voting Policy and Procedure from our Compliance Manual by contacting us using the information on the Cover Page of this brochure. Item 18: Financial Information Tower View does not require payment or accept prepayment more than three months in advance. Tower view has no financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Tower View has never filed for bankruptcy or been involved in any bankruptcy proceedings. 27 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A