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 30, 2026 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. The following material change has been made since our last annual updating amendment filed March 27, 2025: ➢ Custody: Tower View Wealth Management is deemed to have custody of client assets in limited circumstances where our Chief Investment Officer, Raman Ghei, CFA, serves in a personal capacity as trustee for certain clients. These appointments are made personally by the client and are not services offered by the firm. ➢ Advisory Minimum Fee: A minimum quarterly fee provision was added to the firm's advisory agreement in December 2025. The firm has since elected not to implement this provision and has removed it from its standard agreement. No clients will be subjected to a minimum fee at this time. ➢ Discretionary Authority and AUM Reporting: The firm has updated its treatment of certain accounts owned by Raman Ghei, related family members, and firm employees to reflect that these accounts are managed on a discretionary basis and are now treated as client relationships of the firm. As a result, these accounts are included in the firm’s regulatory assets under management (AUM), aligning reporting with the level of authority exercised over such accounts. 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 B. Types of Advisory Services Investment Management Services Financial Planning Services: Employer-Sponsored Retirement Plan Guidance: 529 Education Savings Plans: Education Content: Other Activities: C. Investment Management Advisory Services of Client Accounts D. Wrap Fees E. Assets Under Management Item 5: Fees and Compensation A. Fees and Compensation Asset-Based Management Fees Financial Planning and Consulting Fees Additional Fees for Complex Services Fee Waivers and Discounts B. How Fees Are Paid C. Other Fees and Expenses D. Prepayment and Refunds E. Other Compensation Item 6: Performance-Based Fees and Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis and Investment Strategies B. Material Risks of Investment Strategies Pledged Asset and Margin Risk General Market and Economic Risks C. Risks Associated with Specific Types of Securities Mutual Funds and ETFs Equity Securities Foreign Investing Risks Fixed Income Securities 1 2 3 5 5 5 5 6 6 6 6 6 6 8 8 8 8 8 9 9 9 10 10 10 11 11 11 11 12 13 13 13 14 14 14 14 14 3 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Interest Rate Risk: Credit Risk: Call Risk: Liquidity Risk: Below Investment Grade (High Yield) Risk: Municipal Bond Risk: Cybersecurity and Operational Risks Key Person Risk Force Majeure / Disaster Risk Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations A. Broker-Dealer Registration: B. Commodity-Related Registration: C. Other Financial Industry Relationships: Item 11: Code of Ethics, Personal Trading & Conflicts of Interest A. Code of Ethics B. Participation or Interest in Client Transactions C. Personal Trading & Investment in the Same Securities as Clients D. Trading the Same Securities at or About the Same Time as Clients E. Additional Conflicts of Interest and Business Practices Employee Trading Authority in Client Accounts Company Retirement Savings Plan Management of Friend and/or Family Client Accounts Personal and Related Accounts of Firm Personnel Firm Business Accounts Employee Compensation Independent Contractors Founder as Chief Compliance Officer Founder Serving on Board of a Client Company Item 12: Brokerage Practices A. Brokerage Practices Brokerage Accounts Custodied at Charles Schwab Institutional: Brokerage & Custodian Selection Your Brokerage and Custody Costs 1. Research and Other Soft Dollar Benefits a. Products and Services Available to Tower View From Schwab i. Services that Benefit You ii. Services That Do Not Directly Benefit You iii. Services That Generally Benefit Only Tower View Our interest in Schwab’s services Research & Soft Dollar Benefits 14 15 15 15 15 15 15 16 16 16 17 17 17 17 18 18 19 19 19 20 20 20 20 21 21 21 21 21 22 22 22 22 22 23 23 23 23 23 24 24 25 4 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  2. Brokerage for Client Referrals Use of Commissions to Gain Clients 3. Directed Brokerage Directing Trades to Brokers of the Client’s Choice Trading Practices & Trade Errors B. Aggregation of Orders 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 25 25 25 25 26 26 26 27 27 28 28 29 Item 4: Advisory Business A. Description of the Firm 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. Investment management is the core of our business, and we also provide financial planning services based on clients’ needs. In certain cases, financial planning may be offered as a standalone service. Investment Management Services Investment management is the primary service offered by Tower View. We provide ongoing portfolio management services tailored to each client’s investment objectives, risk tolerance, and financial circumstances. This includes the construction and management of client portfolios using a combination of individual securities, mutual funds, and exchange-traded funds (ETFs), as well as ongoing monitoring and adjustments as appropriate. Additional details regarding our investment management process are described in Item 4.C below. These services are often provided in conjunction with our financial planning services, allowing us to align investment strategies with each client’s broader financial goals. Tower View primarily provides investment advisory services related to publicly traded securities, including stocks, bonds, exchange-traded funds (ETFs), cash, and mutual funds. We may also provide guidance on stock options, including exercise strategies, expiration considerations, and monitoring of restricted stock positions. 5 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  In addition to assets directly managed by the firm, Tower View may provide advice on held-away assets, such as employer-sponsored retirement plans (e.g., 401(k) accounts) and 529 education savings plans. Financial Planning Services: Tower View offers financial planning services designed to help clients understand and manage their overall financial situation. These services may include guidance on retirement planning, cash flow and budgeting, education funding, Social Security strategies, stock option planning, and the review of employer-sponsored retirement benefits and other held-away assets. Financial planning recommendations are based on information provided by the client and are tailored to each client’s specific circumstances, goals, and objectives. Clients are responsible for providing accurate and updated information so that recommendations remain appropriate over time. Clients are under no obligation to implement any recommendations and may choose to do so independently or through other professionals. Employer-Sponsored Retirement Plan Guidance: Our advisors may offer general asset allocation guidance for accounts held within an employer-sponsored retirement plan such as 401(k)s, 403(b) etc. Because these accounts are typically held directly with the plan provider and outside of 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 employer-sponsored retirement plan accounts and do not execute trades, directly manage, or monitor these accounts. 529 Education Savings Plans: Tower View may provide recommendations and periodic reviews for 529 plans, generally on a non-discretionary basis. In limited cases, we may have discretionary authority over certain 529 accounts, in which case those assets are included in regulatory assets under management (AUM). Additional fees may apply depending on the level of service provided. Education Content: Tower View may provide general educational content, including newsletters, website articles, and other communications related to financial planning and investing. This content is for informational purposes only, is not personalized investment advice, and is subject to internal compliance review. Other Activities: As part of our services, Tower View may coordinate with clients’ attorneys, accountants, and other professionals to support the implementation of financial, estate, and tax planning strategies. While we do not provide legal or tax advice, we assist clients in aligning their financial plans with their broader planning objectives. Raman may serve in a personal capacity as a trustee or executor for certain clients. These roles are undertaken at the request of the client and are not services offered by Tower View. Where such roles involve assets managed by the firm, appropriate disclosures are made and applicable custody-related requirements are followed. C. Investment Management Advisory Services of Client Accounts As part of our investment management process, Tower View provides clients with investment-related documentation, which may include an 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 6 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  a review of their financial situation, including but not limited to client’s 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 generally do not make frequent allocation changes in response to short-term market conditions; however, portfolios may be adjusted in connection with significant deposits, withdrawals, or changes in a client’s financial circumstances. 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. The firm may consider tax-efficient strategies, including the timing of gains and losses, as part of its portfolio management process. Tower View does not implement tax-loss harvesting as a systematic strategy; however, such strategies may be considered in certain circumstances or upon client request based on the client’s specific situation and overall investment objectives. investment portfolios on both a discretionary and non-discretionary basis. We manage 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 typically constructed using model portfolios or investment strategies, which may include a combination of individual securities, mutual funds, and exchange-traded funds (ETFs). Portfolio allocations may vary based on factors such as account size, available cash, tax considerations, cost basis sensitivity, investment restrictions, liquidity needs, client preferences, investment time horizon, and the timing of account funding or withdrawals. In addition, accounts may be managed differently based on client tenure, including legacy positions or strategies that are maintained to accommodate tax considerations or client-specific circumstances. Tower View does not engage in market timing or attempt to shift investment allocations based on short-term economic or market 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. 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. 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. 7 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Tower View seeks to implement investment decisions consistently across client accounts where appropriate; however, not all investment opportunities are suitable for every client. Portfolio allocations and investment selections may vary based on individual client circumstances, including tax considerations, account characteristics, and cash needs. All final investment decisions are made at the firm’s discretion. Due to differences in client circumstances, including investment objectives, tax considerations, cash flows, and account timing, there may be significant variation in portfolio composition and performance among clients, even where investment objectives are similar. D. Wrap Fees Tower View does not currently participate in Wrap Fee programs. E. Assets Under Management As of December 31, 2025, Tower View managed approximately $318,214,061.59 on a discretionary basis, and $0 on a non-discretionary basis. F. 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. When we recommend that you roll over assets from an employer-sponsored retirement plan into an individual retirement account managed by Tower View, we may receive additional compensation as a result of managing those assets. This creates a conflict of interest, as we have a financial incentive to recommend the rollover. You are not obligated to roll over your assets and may have other options available, including leaving assets in your current plan, rolling them into a new employer’s plan, or taking a distribution. We encourage you to consider all available options before making a decision. Item 5: Fees and Compensation A. Fees and Compensation Asset-Based 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). 8 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Actual fees may vary based on the specific services provided, and all fees are outlined in each client’s written agreement with Tower View. Fees are negotiable. Fees may be adjusted based on factors such as the complexity of a client’s financial situation, the number of related accounts, the scope of investment management versus financial planning services, the length of the client relationship, and the level of service provided. Any fee increase will be communicated in writing and must be agreed to by the client before taking effect. Management fees are not dependent on transactions within an account and are charged regardless of trading activity. Client accounts may hold cash or cash equivalents for various reasons, including pending investment or withdrawals, and such assets are generally included in AUM for fee calculation purposes. Financial Planning and Consulting Fees Tower View generally provides financial planning services as part of its asset-based fee structure. However, in certain cases, additional fees may apply if planning services extend beyond what is included in a standard advisory relationship or are provided on a standalone basis. Financial planning or consulting services may be billed as quarterly base fees, hourly fees, or project-based/flat fees. These fees vary based on the scope and complexity of services provided and are disclosed and agreed to in advance. Tower View’s maximum hourly rate is $1,000 per hour. Project-based or flat fees typically do not exceed $50,000; however, actual fees may vary based on the nature and complexity of the engagement. Tower View has the discretion to waive or adjust fees in certain cases. Additional Fees for Complex Services In limited cases, Tower View may charge additional fees for services involving complex client situations, such as estate settlements, divorce planning, business transitions, or other specialized engagements requiring significant time and coordination. These services may be billed as hourly, project-based, base-fees, or flat fees depending on the nature of the engagement. The scope of services and applicable fees may be discussed and agreed upon with the client either in advance or after the extent of services becomes more clearly defined. All such fees are disclosed to and agreed upon by the client prior to billing. Certain legacy client agreements may reference additional administrative or account-level fees. Tower View does not currently assess these fees; however, we reserve the right to do so in accordance with the terms outlined in the applicable client agreement. Fee Waivers and Discounts Tower View may waive or reduce advisory fees for certain clients, including employees of the firm and related persons of firm personnel. These fee arrangements are determined at the firm’s discretion. 9 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  This creates a potential conflict of interest, as similarly situated clients may pay different fees for comparable services. In addition, the firm provides advisory services to certain accounts without receiving compensation. Tower View Seeks to mitigate this conflict by managing all client accounts, including those with reduced or waived fees, in a consistent manager, applying the same investment process, trading procedure and level of service across all accounts. B. How Fees Are Paid Clients may pay advisory fees through direct deduction from their investment account(s) or by direct payment. Direct payment methods may include check or other approved electronic payment methods processed through a secure and compliant invoicing system (such as AdvicePay). Asset-based management fees are generally billed quarterly in advance, based on the value of client assets as of the last business day of the prior quarter. Base fees and financial planning or consulting fees may also be billed quarterly in advance and may be invoiced separately or alongside asset-based management fees, depending on the nature of the engagement and the client’s agreement. For new accounts, new client relationships, or changes in service level or fee arrangements, fees may be prorated from the effective date of the agreement or funding date through the end of the billing period. Such prorated fees may be billed at the time of the change or, at Tower View’s discretion, collected in arrears and included in the next billing cycle. In certain cases, Tower View may waive or defer prorated fees when deemed de minimis. Tower View does not collect new or prorated fees until at least five (5) business days after the applicable agreement or amendment is signed. C. Other Fees and Expenses Clients will incur additional fees and expenses separate from Tower View’s advisory fees. These may include, but are not limited to, brokerage commissions and transaction costs, custodian fees such as account maintenance, wire fees, and transfer fees, mutual fund and exchange-traded fund (ETF) internal expenses, and taxes on transactions or holdings. Tower View uses Charles Schwab & Co., Inc. as its primary custodian. Clients may also incur additional costs when investing in foreign securities, including foreign transaction fees charged by the custodian or executing broker. These fees vary by market and security. In limited cases, Tower View may review such charges and, at its discretion, provide a credit to the client’s account where fees are deemed excessive. Additional information regarding brokerage practices is provided in Item 12. D. Prepayment and Refunds Fees are generally billed in advance. If a client terminates their advisory relationship, any prepaid, unearned fees will be refunded on a pro-rata basis, calculated daily, from the effective date of termination. 10 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  For new accounts or mid-quarter changes, prorated fees may be billed or collected as described above. Any applicable refunds will reflect the unused portion of services. Clients may terminate their agreement within five (5) business days of execution without incurring advisory fees. Fees are not typically prorated for partial asset withdrawals during a billing period unless the account is fully closed or the advisory relationship is terminated. E. Other Compensation firm performance and Tower View employees receive a base salary and may be eligible for bonuses and profit-sharing based on overall individual contributions. Compensation is not tied to specific investment recommendations, product sales, or client referrals. In certain cases, employees who perform substantial additional work outside of their typical responsibilities, such as financial planning, consulting, or complex client engagements, may receive additional compensation. This compensation is generally based on the time, effort, and level of involvement required to complete the services and may be tied in part to the revenue generated from such services. These types of additional services are provided based on client needs and circumstances, and not as a result of employee-driven incentives. All such services and associated fees are discussed with and agreed upon by the client prior to billing. Tower View maintains policies and supervisory procedures designed to ensure that all recommendations and services are in the best interest of the client and are not influenced by employee compensation arrangements. Item 6: Performance-Based Fees and Side-By-Side Management Tower View does not charge performance-based fees (fees based on a share of capital gains or capital appreciation) and does not engage in side-by-side management. Item 7: Types of 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. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 11 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  A. Methods of Analysis and Investment Strategies While not every investment is ultimately held for a long period of time, our goal is to be long-term investors 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 that 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 when we have concerns about their growth prospects, balance sheet, or competitive position. The final determination for these factors is based upon the opinion of Tower View and is inherently subjective. We do not adhere to strict valuation criteria or quantitatively driven models or methodologies, and our opinions may vary over time. Our type of investment strategy is often referred to as “bottom-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 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. Investment selection is primarily driven by the Chief Investment Officer, and suitability is a highly subjective determination based on client circumstances, market conditions, and professional judgment. We do not follow strict growth, value, or momentum strategies or methodologies, and therefore there can be wide variance in the types of investments selected over time. 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 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 and/or mutual funds, we generally seek to invest in more passive funds in order to limit expenses, although there may be exceptions. Due to the nature of these investments, not all underlying holdings will meet all of our selection criteria, and in some cases may include securities we would not otherwise purchase directly. We believe the diversification benefits provided by these funds generally outweigh these considerations. Tower View’s method of security analysis relies heavily on personal judgment, publicly available financial publications, and company-provided materials. We do not typically use technical analysis, create earnings models, visit companies, or regularly communicate with analysts or investor relations departments. Individual bond purchases are selected using similar methods as equities, with a reliance on generally available credit ratings to assess credit quality. A significant portion of bond 12 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  exposure is obtained through mutual funds, including taxable, government, municipal, and high yield (below investment grade) securities. When purchasing individual bonds, Tower View considers both the bond’s credit rating (investment grade or below investment grade) and the overall composition of the client’s portfolio. Bond portfolios are diversified by issuer type and maturity, and maximizing yield is not the sole determining factor in a bond purchase. Individual bonds are typically purchased through Charles Schwab’s trading platform, and as such, available offerings may be influenced by the custodian. All investments in financial assets involve risk, including but not limited to market risk, transaction costs, poor investment decisions, and changes in a client’s personal circumstances that may require portfolio adjustments at inopportune times. Investing in securities involves the risk of loss that clients should be prepared to bear. B. Material Risks of Investment Strategies Tower View’s investment approach is based on subjective analysis and professional judgment, which may result in investment decisions that differ from market consensus or other advisers. Because we do not follow rigid models or predefined methodologies, there may be significant variation in portfolio composition and performance between accounts. We may invest in securities that carry elevated risk, including smaller companies, foreign securities, and below investment grade bonds. In addition, portfolios may include mutual funds or ETFs that hold securities which would not independently meet all of Tower View’s selection criteria. While diversification is intended to reduce risk, it does not eliminate the possibility of loss. Our investment processes inherently contain risks of significant loss, including risks associated with market volatility, liquidity, credit quality, and currency exposure. Pledged Asset and Margin Risk Clients who utilize margin or pledge assets as collateral for loans should be aware of the associated risks. A lender may have the ability to liquidate securities in the account, potentially without prior notice, in order to meet margin or collateral requirements. Such liquidations may occur at unfavorable prices and may be inconsistent with the client’s investment strategy or tax objectives. In these situations, neither the client nor Tower View may have control over which assets are sold. Tower View does not control or direct actions taken by a lender in connection with pledged assets or margin accounts. General Market and Economic Risks Investment performance may be affected by market conditions, interest rates, inflation, economic cycles, geopolitical events, and other external factors. Climate change represents an emerging risk factor that may impact corporate profitability, regulatory environments, and global economic conditions. These factors may result in increased market volatility and could negatively impact investment returns. 13 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  C. Risks Associated with Specific Types of Securities Mutual Funds and ETFs Mutual funds are subject to advisory, transaction, marketing, and operating expenses, and each fund carries specific risks related to its underlying investments. The value of fund holdings and net asset value (NAV) will fluctuate based on market conditions. Different funds held within a client portfolio may hold the same underlying securities, increasing exposure to those securities. In addition, fund managers may deviate from their stated investment strategies, which could affect performance or suitability. For more information, we encourage shareholders to review the fund prospectus. ETFs are traded on exchanges and may not always trade at prices that reflect the underlying value of their holdings, particularly during periods of market stress or reduced liquidity. Equity Securities 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 generally more volatile than bonds. Tower View may invest in companies of varying sizes, including smaller companies. Smaller companies often have fewer shares traded daily, which can make the stock less liquid and its price more volatile. This can negatively impact the price paid when purchasing or the price received when selling such securities. In addition, smaller companies often have shorter operating histories, more limited product or service offerings, and less access to capital. These factors can increase the risk that such companies may experience poor performance or fail. Foreign Investing Risks Investments in foreign companies, whether through ADRs, direct ownership of foreign securities, or mutual funds and ETFs that invest internationally, involve additional risks beyond those associated with U.S. companies and markets. These risks include greater price volatility, less supervision and regulation of securities markets, issuers, and brokers, higher transaction costs, potential adverse tax consequences, and delays in settlement. Foreign investments are also subject to currency risk. Fluctuations in exchange rates can impact the value of an investment, as well as any income received. For example, if a foreign currency declines in value relative to the U.S. dollar, the value of the investment and any associated dividends may decrease when converted to U.S. dollars, even if the underlying investment performs well in its local market. Fixed Income Securities Client accounts with all or a portion of assets invested in fixed income securities, whether directly or through mutual funds, are subject to a number of risks. Interest Rate Risk: Prices of fixed income securities rise and fall in response to changes in interest rates. Generally, when interest rates rise, the prices of existing fixed income securities fall. Securities with longer maturities are typically more sensitive to interest rate changes due to their longer duration. 14 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Credit Risk: 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. Call Risk: Fixed income securities with a call feature (“callable bonds”) may be redeemed by the issuer prior to maturity. If a bond is called, proceeds may need to be reinvested at lower prevailing interest rates, which can reduce overall income and return. This is more likely to happen when interest rates are falling. Liquidity Risk: Liquidity risk refers to the possibility that a bond may not be readily sold at a favorable price or time. As a result, a security may need to be sold at a discount, other securities may need to be liquidated to raise cash, or investment opportunities may be missed, any of which could have a negative effect on investor’s performance. Below Investment Grade (High Yield) Risk: Below investment grade securities, sometimes referred to as high yield or “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. Municipal Bond Risk: 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. Cybersecurity and Operational Risks Clients may be subject to cybersecurity risks, including unauthorized access to accounts, identity theft, and the potential compromise of personal or financial information. While custodians such as Charles Schwab & Co., Inc. maintain security measures to protect client accounts, no system is entirely immune to breaches. Tower View makes reasonable efforts to monitor client accounts and maintain internal safeguards; however, the firm cannot guarantee that unauthorized access or cyber incidents will be detected or prevented. In addition, protections offered by custodians may not apply 15 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  in situations where account access is granted by the client to third parties, including family members or other authorized individuals. If a client chooses to custody assets at another institution, Tower View may have limited ability to monitor those accounts, which could increase risk. Tower View maintains a cybersecurity insurance policy; however, coverage is subject to the terms and limitations of the policy and may not fully compensate for all losses. As a matter of policy, Tower View does not reimburse clients for losses resulting from cybersecurity breaches or identity theft. Clients are strongly encouraged to promptly report any suspected unauthorized activity to both Tower View and their custodian. Clients are strongly encouraged to promptly notify both Tower View and their custodian if they believe their personal information or account access has been compromised. Clients should also contact their custodian directly to report suspicious activity or potential fraud. For example, Charles Schwab & Co., Inc. maintains a 24-hour fraud hotline for client support. Key Person Risk Tower View is a relatively small firm and relies significantly on its Chief Investment Officer for investment decisions and portfolio management. As a result, the firm is subject to key person risk. In the event of the incapacity, departure, or reduced availability of the Chief Investment Officer, clients may experience some level of disruption in investment management or service continuity. However, client assets are held with an independent custodian and remain accessible to clients at all times. Force Majeure / Disaster Risk Tower View maintains disaster recovery plans and procedures; however, certain events are beyond the firm’s reasonable control. These may include natural disasters, acts of terrorism, global health events, utility failures, or other significant disruptions. Such events may impact financial markets, communication systems, trading capabilities, or access to client accounts. The effects of these events are inherently unpredictable and may result in significant market volatility, delays in service, or disruptions in normal business operations. Item 9: Disciplinary Information Tower View and our investment adviser representatives have not been involved in any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of the firm or its personnel. 16 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Item 10: Other Financial Industry Activities and Affiliations A. Broker-Dealer Registration: Neither Tower View Wealth Management nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or registered representative of a broker-dealer. B. Commodity-Related Registration: Neither Tower View Wealth Management nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. C. Other Financial Industry Relationships: Tower View does not have any affiliations with broker-dealers, investment companies, insurance companies, banks, or other financial institutions. The firm does not maintain any formal partnerships, ownership interests, or fee-sharing arrangements with external financial firms. Tower View does not have any formal referral agreements with outside professionals, such as accountants or attorneys. However, upon client request, the firm may provide referrals as a courtesy. Tower View does not receive any compensation or economic benefit for such referrals. Clients are encouraged to independently evaluate any referred professionals. Although Tower View does not maintain formal affiliations with other financial firms, the following disclosures describe certain situations that may present potential conflicts of interest. a. Coordination with Other Professionals and Referrals: Tower View may coordinate with other financial professionals engaged by the client, such as accountants or attorneys, to support the client’s overall financial plan. These relationships are client-directed. From time to time, Tower View may also provide referrals to accountants, attorneys, or other professionals as a courtesy. Tower View does not have any formal affiliation with these professionals and does not receive any compensation or economic benefit for such referrals. This could create a potential conflict of interest to the extent Tower View introduces a client to a third-party professional. Tower View addresses this by not receiving compensation and encouraging clients to independently evaluate any referred professionals. b. Real Estate and Limited Partnership Interest: One of the firm’s clients is involved in sponsoring real estate limited partnerships. While such opportunities may be discussed with clients from time to time, Tower View does not receive any compensation or economic benefit in connection with these opportunities. 17 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  This could create a potential conflict of interest if such opportunities are discussed with clients. Tower View addresses this by not receiving compensation, not acting as a sponsor or promoter, and allowing clients to independently evaluate any such investments. c. Trustee / Executor Roles: Raman J. Ghei, Chief Investment Officer of Tower View, may serve in a personal capacity as a trustee or executor for certain clients. These roles are undertaken at the request of the client and are not services offered by Tower View. In some cases, compensation may be received in accordance with the governing documents. This arrangement creates a potential conflict of interest, as Raman may have authority over client assets while also providing advisory services. Tower View addresses this conflict through disclosure, internal oversight, and adherence to applicable custody and fiduciary requirements, including independent verification where required. d. Other Investment Advisor Relationships: Tower View does not recommend or select other investment advisers for clients for compensation and does not receive any direct or indirect compensation from other investment advisers. Tower View does not have business relationships with other advisers that create a material conflict of interest. We do communicate with other advisors with whom we share clients. This may be to coordinate withdrawal needs, overall risk levels, taxes and other administrative and investment matters. 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 clients, there are potential conflicts inherent in the firm’s structure and activities. We have procedures in place to mitigate these risks and uphold our fiduciary duty to clients. Tower View maintains an internal Code of Ethics (the “Code”) which, in general terms, prohibits any practices that are illegal or inconsistent with the best interests of our clients. The Code sets the standard of ethical and professional business conduct that we require of our Supervised Persons, requires compliance with applicable federal securities laws and regulations, and includes provisions regarding personal securities transactions by certain Supervised Persons deemed access persons under applicable regulations. Additionally, the Code addresses the handling of material nonpublic information, confidential client information, and the fiduciary obligations that Tower View and each of its Supervised Persons owe to every advisory client. We will provide a copy of the Code of Ethics to any existing or prospective client upon request. To request a copy, please contact us using the information on the Cover Page of this brochure. 18 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  B. Participation or Interest in Client Transactions Tower View does not buy or sell investments directly to or from client accounts, and we do not recommend investments where the firm or its related persons would benefit directly from the investment itself (for example, by acting as a sponsor or issuer). However, conflicts of interest may still arise in the course of providing advisory services. Tower View addresses these conflicts through its Code of Ethics, supervisory procedures, and fiduciary obligation to act in the best interests of clients at all times. Additional conflicts related to the firm’s business practices are described below. C. Personal Trading & Investment in the Same Securities as Clients Tower View employees, including Tower View Savings Plan accounts, Raman J. Ghei (Founder and Chief Investment Officer), and certain related family or acquaintance accounts, may invest in the same securities that are recommended to or held in client portfolios. These accounts are generally managed using the same investment strategies, systems, and resources as client accounts, although in certain circumstances they may hold securities that differ from those held in client accounts. This presents a potential conflict of interest, as employees or related persons could benefit from investment opportunities available to clients. To mitigate these conflicts, Tower View has implemented policies and procedures governing personal trading. These include periodic monitoring of personal trading activity, review of holdings and transactions, required reporting by Access Persons, and oversight of adherence to firm policies. All such accounts remain subject to the firm’s Code of Ethics and personal trading policies. D. Trading the Same Securities at or About the Same Time as Clients Raman J. Ghei, Chief Investment Officer, is responsible for overseeing the firm’s investment process and trading activities, including client accounts and accounts managed within the firm’s primary trading system. Employee accounts, Tower View Savings Plan accounts, and certain related family or acquaintance accounts may also engage in trading activity. In many cases, these accounts are managed in alignment with the firm’s investment models and may participate in block trades alongside client accounts. In other instances, employees may direct trading in their own accounts, subject to the firm’s personal trading policies and oversight procedures. Additionally, certain employees have limited trading authority within client accounts for operational purposes, such as executing miscellaneous trades, raising cash to meet client needs, or implementing portfolio adjustments as directed. All such activity remains subject to the firm’s trading policies, supervision, and oversight by the Chief Investment Officer. This creates a potential conflict of interest where employees or related persons may trade the same securities at or about the same time as client accounts. To mitigate this conflict, Tower View follows a consistent trade sequencing and allocation process. Where appropriate, employee and related accounts may be included in block trades 19 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  with client accounts. Otherwise, such accounts will have trades executed after client transactions in the same security. Under no circumstances are employees or related accounts permitted to trade ahead of client transactions, with one caveat as explained in the next paragraph. In rare circumstances, Raman J. Ghei or certain related family/employee accounts may trade before client accounts due to timing or market conditions. In those situations, Tower View will take steps to ensure that client transactions are not disadvantaged, including confirming that clients receive pricing that is equal to or more favorable than that received by those accounts. In limited circumstances, Raman J. Ghei may execute trades in his personal accounts or certain related family accounts through a retail trading platform rather than the firm’s primary trading system. These instances are infrequent and generally occur due to timing or practical considerations. All such activity remains subject to the firm's trade sequencing, monitoring and personal trading policies to ensure that client transactions are not disadvantaged. All personal and related account trading remains subject to the firm’s Code of Ethics, including monitoring, reporting requirements, and periodic review to ensure compliance and that client accounts are not disadvantaged. E. Additional Conflicts of Interest and Business Practices Employee Trading Authority in Client Accounts Certain employees have limited authority to execute trades within client accounts for operational purposes, such as raising cash for client needs, processing distributions, or implementing portfolio adjustments as directed. These employees do not independently determine overall portfolio strategy and remain subject to the firm’s trading policies, supervision, and oversight by the Chief Investment Officer. Company Retirement Savings Plan Tower View maintains a company-sponsored retirement savings plan that allows employees to establish traditional and Roth 401(k) accounts. These accounts are invested using ETFs, model portfolio holdings, and mutual funds, and are managed as part of the firm’s overall investment process. Tower View exercises discretionary authority over these accounts, and they are generally managed in a manner consistent with client portfolios. As such, these accounts are included in the firm’s regulatory assets under management. While a potential conflict exists in managing employee retirement accounts alongside client accounts, Tower View has implemented policies and procedures to ensure that these accounts are not given preferential treatment. Management of Friend and/or Family Client Accounts Tower View provides advisory services to certain clients who are personal acquaintances, friends, or family members of firm personnel. These relationships are treated as standard client relationships and are subject to the same investment process, trading procedures, fee 20 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  arrangements, compliance oversight, and advisory agreements as all other clients of the firm. These accounts are managed as part of Tower View’s advisory business, are subject to discretionary authority where applicable, and are included in the firm’s regulatory assets under management to the extent required. While these relationships may present potential conflicts of interest, Tower View seeks to mitigate such conflicts by applying consistent policies and procedures and ensuring that such clients are not given preferential treatment. Personal and Related Accounts of Firm Personnel Raman J. Ghei maintains certain personal accounts and may have trading authority over accounts for family members or related persons, including accounts where he serves as trustee or otherwise exercises authority. These accounts are subject to the firm’s Code of Ethics and personal trading policies and are only included in regulatory assets under management where discretionary advisory services are provided. Firm Business Accounts Tower View maintains firm-owned, non-advisory accounts used for operational purposes. These accounts are not included in regulatory assets under management and do not influence investment decisions made on behalf of clients. Employee Compensation Tower View employees receive a base salary and may be eligible for bonuses or profit-sharing based on overall firm performance and individual contributions. In certain cases, employees may also receive additional compensation after the fact, in an amount determined by the CIO, in connection with work that requires a materially higher level of time, complexity, or involvement, such as estate-related matters or other complex client situations. These services are provided based on client needs and circumstances, and not as a result of employee-driven incentives. Tower View maintains policies and supervisory procedures designed to ensure that all recommendations and services are provided in the best interest of the client and are not influenced by compensation arrangements. For additional information regarding fees and compensation, please see Item 5 of this brochure. Independent Contractors Tower View utilizes a limited number of independent contractors, some of whom may also be clients. All such relationships are subject to the same policies and procedures to mitigate conflicts. Founder as Chief Compliance Officer Raman J. Ghei serves as both Founder and Chief Compliance Officer, creating a potential conflict related to self-supervision. This is mitigated through internal monitoring and the use of an independent compliance consulting firm. 21 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Founder Serving on Board of a Client Company Raman J. Ghei serves on the Board of Directors of a client company. He abstains from decisions related to advisory services, and accounts are managed on an arm’s-length basis with periodic review to ensure no preferential treatment. Item 12: Brokerage Practices A. Brokerage Practices Brokerage Accounts Custodied at Charles Schwab Institutional: Tower View generally recommends that clients maintain their investment accounts with Charles Schwab & Co., Inc.. Schwab is an independent custodian that holds client assets, executes trades, and provides account statements. Tower View uses Schwab’s platform to execute transactions, monitor portfolios, and assist with administrative services. 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. Although Tower View currently utilizes Charles Schwab as its primary custodian and broker-dealer for client accounts, we periodically evaluate other available brokerage and custodial options to ensure our selection remains consistent with our duty to seek best execution. 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. 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 22 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  ● 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. 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. 1. Research and Other Soft Dollar Benefits a. 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 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: i. 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. ii. 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 23 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  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 iii. 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. 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 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. 24 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  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 described 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. 2. Brokerage for Client Referrals Use of Commissions to Gain Clients Tower View does not direct any brokerage commissions in exchange for client referrals. 3. Directed Brokerage 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. In addition, directing brokerage may limit Tower View’s ability to obtain best execution and may prevent participation in aggregated trades. As a result clients may experience higher transaction costs or less favorable pricing. Tower View does not allow clients who are custodied at Schwab to direct trades to a specific outside broker. 25 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  Trading Practices & Trade Errors If you have questions about our trading practices and handling of trade errors you may contact us for further information. B. Aggregation of Orders Tower View may aggregate the purchase or sale of securities for multiple client accounts, when it believes aggregation is consistent with its duty to seek best execution and is in the best interest of clients. When orders are aggregated, participating accounts will generally receive the same average execution price, and transactions will be allocated in a fair and equitable manner based on factors such as account size, investment objectives, and available cash. In certain circumstances, Tower View may not aggregate orders. This may occur when client-directed brokerage is used, or when new client cash withdrawal requests or deposits occur after previously aggregated orders are executed. In addition, mutual fund orders are not aggregated as there is no benefit to doing so, in that all mutual fund orders are executed at the same price by the fund. When errors in aggregation are identified - such as a client mistakenly being left off an order or the wrong number of shares being allocated, we will reimburse the client for any associated losses. When orders are not aggregated, clients may receive less favorable execution prices or incur higher transaction costs than if transactions had been aggregated. 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 account holdings 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, participation in model portfolio holdings 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. In addition to these periodic reviews, accounts may be reviewed on a non-periodic basis in response to material changes in market conditions, significant cash flows, changes in a client’s financial situation or investment objectives, or other relevant events. Financial Planning 26 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  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. Financial plans are generally reviewed annually, or as needed based on client circumstances. 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. 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 these arrangements 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 is deemed to have custody of client assets in limited circumstances under SEC rules, as described below. 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 under SEC rules, as these accounts remain under client ownership and control. 27 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  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. The firm is deemed to have custody under SEC rules solely because a supervised person of the firm, Raman Ghei, may serve in a personal capacity as a trustee or executor for certain clients. In some of these trustee roles, Raman may have authority to move client funds to third parties in accordance with the governing documents of the trust or estate. These appointments are made directly by clients and are not services offered by Tower View. When a personal trustee or executor appointment involves assets managed by Tower View, those accounts are included in the firm’s custody reporting and are subject to the SEC’s custody rule requirements, including an annual surprise examination conducted in accordance with the SEC Rule 206(4)-2. Tower View will engage an independent public accounting firm, Wipfli LLP, to conduct an initial surprise custody examination within six months of the effective date of this change and to perform annual examinations thereafter in accordance with SEC Custody Rule 206(4)-2. In addition, Tower View is including a few family-related accounts in its annual custody examinations to enhance transparency, even though one or more of these accounts may not strictly meet the custody definition under SEC rules. Tower View does not otherwise have authority to move client funds to third parties. All third-party money movements outside of these trustee or custodial roles require direct client authorization, and the firm does 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. Item 17: Voting Client Securities 28 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A  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. 29 | Page Tower View Wealth Management- Form ADV Brochure - Part 2A