Twelve Points Wealth Management

Item 1: Cover Page Form ADV Part 2A Brochure Version date: March 31, 2026 Twelve Points Wealth Management 9 Pond Lane, Suite 3A Concord, MA 01742 Phone: (978) 318-9500 Fax: (978) 318-9505 www.twelvepointswealth.com Firm CRD#: 171107  Item 2: Material Changes There have been material changes to this Brochure since Twelve Points Wealth Management’s last annual updating amendment on 03/31/2025. Material changes relate to Twelve Points Wealth Management’s policies, practices, or conflicts of interest. Item 5  o The Firm updated its Retirement Plan Advisory fee schedule. o The Firm included disclosure concerning fees paid for U.S. Treasury Bill securities. o The Firm updated its minimum initial financial planning services fee to $5,000. Additional information about Twelve Points Wealth Management and its representatives is also available on the SEC’s website at www.adviserinfo.sec.gov.  Item 3: Table of Contents Cover Page .........................................................................................................1 Item 1: Item 2: Material Changes ...............................................................................................2 Table of Contents ...............................................................................................3 Item 3: Investment Advisory Business ...........................................................................4 Item 4: Fees and Compensation ...................................................................................11 Item 5: Types of Clients Performance-Based Fees and Side by Side Management ....14 Item 6: Types of Clients ...............................................................................................14 Item 7: Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ........................14 Item 9: Disciplinary Information ..................................................................................17 Item 10: Other Financial Industry Activities and Affiliations .......................................17 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............................................................................................................18 Item 12: Brokerage Practices .........................................................................................19 Item 13: Review of Accounts .........................................................................................20 Item 14: Client Referrals and Other Compensation .......................................................21 Item 15: Custody ............................................................................................................22 Item 16: Investment Discretion ......................................................................................22 Item 17: Voting Client Securities ...................................................................................22 Item 18: Financial Information.......................................................................................23  Item 4: Investment Advisory Business Established in 2014 by David Clayman, Francesca Federico and Emanuel Frangiadakis, Twelve Points Wealth Management LLC (“the firm”) provides investment advisory services to clients on a discretionary and non-discretionary basis. The firm provides discretionary investment advisory services on a fee basis per the fee schedule set forth at Item 5 below. The firm’s annual investment advisory fee shall generally (with exceptions-see below) include investment advisory services, and, to the extent specifically requested by a retail client, financial planning and consulting services. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of the firm), the firm may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. To commence the investment advisory process, the firm will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, the firm provides ongoing supervision of the account(s). Before engaging the firm to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with the firm setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by the client, the firm will generally provide financial planning and related consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. The firm will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, special projects, stand-alone planning engagements, etc. for which the firm may charge a separate or additional fee). Please Note. The firm believes that it is important for the client to address financial planning issues on an ongoing basis. The firm’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with the firm. Please Also Note: The firm does not serve as an attorney or accountant and no portion of our services should be construed as same. Accordingly, the firm does not prepare legal documents or prepare tax returns. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.) including a firm representative in his/her separate individual capacity as a licensed insurance agent-see Item 10 below. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the firm and/or its representatives. Please Note: If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged unaffiliated licensed professional[s] (i.e. Page 4 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  attorney, accountant, insurance agent, etc.), and not the firm, shall be responsible for the quality and competency of the services provided. Please Also Note-Conflict of Interest: The recommendation by a firm representative that a client purchase an insurance product presents a conflict of interest, as the receipt of an insurance commission may provide an incentive to recommend insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any insurance commission products from a firm representative. Clients can purchase insurance products recommended by a firm representative through other, non-affiliated insurance agents. ANY QUESTIONS: The firm’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding the above conflicts of interest. Stand-Alone Planning Engagements. The firm can be engaged to provide financial planning services per the terms and conditions of a separate agreement and a separate fee as discussed at Item 5 above, the fee for which shall be based upon the individual providing the service and the scope of the services to be provided. Prior to engaging the firm to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with the firm setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to the firm commencing services. Retirement Rollovers-Potential for Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If the firm recommends that a client roll over their retirement plan assets into an account to be managed by the firm, such a recommendation creates a conflict of interest if the firm will earn new (or increase its current) compensation as a result of the rollover. If the firm provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), the firm is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by the firm, whether it is from an employer’s plan or an existing IRA. The firm’ Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Portfolio Activity. The firm has a fiduciary duty to provide services consistent with the client’s best interest. The firm will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not Page 5 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Interval Funds/Risks and Limitations. Where appropriate, the firm may utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares, and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short- term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct the firm, in writing, not to employ any or all such strategies for the client’s account. Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by the firm), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. The firm does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. If implemented, the firm shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or Page 6 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  separate account manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Use of Mutual Funds and Exchange Traded Funds. The firm utilizes mutual funds and exchange traded funds for its client portfolios. In addition to the firm’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Unaffiliated Private Investment Funds. The firm also provides investment advice regarding private investment funds. The firm, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. The firm’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of the firm calculating its investment advisory fee. The firm’s fee shall be in addition to the fund’s fees. The firm’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that the firm references private investment funds owned by the client on any supplemental account reports prepared by the firm, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. Please Also Note: As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless Page 7 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  otherwise indicated, the firm shall calculate its fee based upon the latest value provided by the fund sponsor. Wrap Program-Conflict of Interest. Except for participant directed retirement plan engagements referenced below, the firm provides services on a wrap fee basis as a wrap program sponsor. Under the firm’s wrap program, the client generally receives investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the client more or less than purchasing such services separately. The terms and conditions of a wrap program engagement are more fully discussed in the firm’s Wrap Fee Program Brochure. Conflict of Interest. Because wrap program transaction fees and/or commissions are being paid by the firm to the account custodian/broker-dealer, the firm could have an economic incentive to maximize its compensation by seeking to minimize the number of trades in the client’s account. See separate Wrap Fee Program Brochure. The firm’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding a wrap fee arrangement and the corresponding conflict of interest. Cash Positions. The firm continues to treat cash as an asset class. As such, unless determined to the contrary by the firm, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating the firm’ advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), the firm may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, the firm’ advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: The firm’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Use of Participant Account Management Platform (Pontera). The firm uses a third party platform, Pontera, to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. Through Pontera, we do not have custody of Client funds since we do not have direct access to Client login credentials to affect trades. We are not affiliated with Pontera in any way and receive no compensation from Pontera for using the platform. A link will be provided to the Client allowing them to connect one or more accounts to the platform. Once Client accounts are connected to the platform, the firm will review the current account allocations. When deemed necessary, the firm will rebalance the account considering client investment goals, risk tolerance, and investment profile, and any change in allocations will consider current economic and market trends. The firm aims to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client accounts will be reviewed at least quarterly and allocation changes will be made as deemed necessary by the firm in its discretion. Page 8 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS:  Trustee Directed Plans. The firm may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, the firm will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). The firm will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the firm. Participant Directed Retirement Plans. The firm may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between the firm and the plan. For such engagements, the firm shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by the firm), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process. Client Retirement Plan Assets. If requested to do so, the firm shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, the firm shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. The firm’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. The firm will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify the firm of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by the firm to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of the firm calculating its advisory fee. The firm does not maintain possession of client retirement account passwords. Client Obligations. In performing our services, the firm shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify the firm if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks that the firm and its third-party service providers use to provide services to the firm’s clients employ various Page 9 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  controls that are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in the firm’s operations and/or result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and the firm are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur financial losses and/or other adverse consequences. Although the firm has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that the firm does not control the cybersecurity measures and policies employed by third-party service providers, issuers of securities, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchanges and other financial market operators and providers. Client Privacy and Confidentiality. The firm maintains policies and procedures designed to help protect the confidentiality and security of client nonpublic personal information (“NPPI”). NPPI includes, but is not limited to, social security numbers, credit or debit card numbers, state identification card numbers, driver’s license number and account numbers. The firm maintains administrative, technical, and physical safeguards designed to protect such information from unauthorized access, use, loss, or destruction. These safeguards include controls relating to data access, information security, and incident response, and are reviewed to address changes in risk and business. Client information may be disclosed in response to regulatory requests, legal obligations, or as otherwise permitted by law, and any such disclosure is made in accordance with applicable privacy and confidentiality requirements. The firm may engage non-affiliated service providers in connection with providing advisory services, and such providers may have access to client NPPI, as necessary, to perform their functions. These service providers represent to the firm that they maintain safeguards designed to protect client information from unauthorized access or use and that they will provide notice to the firm in the event of a cybersecurity incident involving client information. While the firm maintains policies and procedures designed to protect client information, such measures cannot eliminate all risk. Upon becoming aware of a data breach involving a client’s NPPI, the firm will notify clients of such breach as may be required by applicable state and federal laws. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by the firm) will be profitable or equal any specific performance level(s). The Firm managed $2,135,958,620 on a discretionary basis and $107,903,954 on a non- discretionary basis for a total of $2,243,862,574 of assets under management as of December 31, 2025. Page 10 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  Item 5: Fees and Compensation Twelve Points Portfolio Plan: The Plan offers investors the opportunity to obtain professional investment services and brokerage services for one all-inclusive fee (“wrap fee”) based on assets under management. The wrap fee is an asset-based fee which includes the management fee paid to the firm for its services as portfolio manager, as well as broker- dealer, custodial and clearing expenses. The complete fee schedule for the Portfolio Plan is available in our Wrap Fee Program Brochure. The fee schedule is as follows: Assets Under Management Annual Fee (%) Under $5,000,000 1.00%/Negotiable $5,000,001 - $15,000,000 0.60%/Negotiable Over $15,000,001 0.40%/Negotiable Additional details on the firm’s wrap fee program can be found in the annexed Wrap Fee Program Brochure. The firm maintains a minimum asset level of $500,000 and a minimum fee level of 1.00%. Retirement Plan Advisory Fees. The firm charges an asset-based fee for its retirement plan advisory services according to the fee schedule below. The fee structure is expressed on an annualized basis and fees are charged in advance based on the market value of assets on the last trading day of each calendar quarter. In any partial calendar quarter, fees are pro-rated based on the number of days in which the account is open during the quarter. Plan Assets ($) Fee (%)1,2 Up to $1,000,000 $1,000,001 to $5,000,000 $5,000,001 to $10,000,000 $10,000,001 to $20,000,000 $20,000,001 to $50,000,000 $50,000,001 to $100,000,000 $100,000,001 to $500,000,000 $500,000,001 to $1,000,000,000 Over $1,000,000,001 0.500% 0.400% 0.250% 0.200% 0.100% 0.050% 0.025% 0.010% Negotiable 1 Minimum annual fee: $5,000 2 Maximum annual fee: $250,000 Page 11 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  Clients who engage the firm are charged an asset management fee of 50 basis points (0.50%) for U.S. Treasury Bill securities. Custodian Charges - Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, the firm generally recommends that Schwab, Fidelity, or Goldman Sachs serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab, Fidelity, and Goldman Sachs charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, dealer spreads, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker- dealer/custodian. While certain custodians, including Schwab, Fidelity, and Goldman Sachs, generally (with exceptions) do not currently charge fees on individual equity transactions (including ETFs), others do. There can be no assurance that Schwab, Fidelity, or Goldman Sachs will not change its transaction fee pricing in the future. Please Also Note: Schwab, Fidelity, and Goldman Sachs may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. Fee Dispersion. The firm, in its discretion, may charge a lesser investment advisory fee, charge a flat fee, waive its fee entirely, or charge fee on a different interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules, employees and family members, courtesy accounts, competition, negotiations with client, etc.). Please Note: As result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees. ANY QUESTIONS: The firm’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding advisory fees. The firm and/or you may terminate the account agreement, in whole or in part, at any time with 30 days written notice. Upon termination, any fees paid in advance will be prorated to the date of termination and any excess shall be refunded to you. Your advisory agreement with the firm is non-transferable without your written approval. Margin Accounts: Risks. The firm Management does not recommend the use of margin for investment purposes. A margin account is a brokerage account that allows investors to borrow money to buy securities and/or for other non-investment borrowing purposes. The broker/custodian charges the investor interest for the right to borrow money and uses the securities as collateral. By using borrowed funds, the customer is employing leverage that will magnify both account gains and losses. Please Note: The use of margin can cause significant adverse financial consequences in the event of a market correction. ANY QUESTIONS: Our Chief Compliance Officer, Kimberly Van Winkle, remains Page 12 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  available to address any questions that a client or prospective client may have regarding the use of margin. Mutual Fund Fees and Expenses. The advisory fees discussed above do not include certain indirect costs that may be associated with securities purchased or held in an account. Examples of indirect costs include expenses associated with investments in ETFs, mutual funds (as described below), or other pooled investments. Clients should understand that the annual advisory fees charged in the wrap program are in addition to the management fees and operating expenses charged by open-end, closed- end and exchange-traded funds. Certain open-end mutual funds may also assess a distribution fee or an administrative or service fee (“trail”). Such fees are included in the calculation of operating expenses of a mutual fund and are disclosed in the fund prospectus. To the extent that a client intends to hold fund shares for an extended period of time, it may be more economical for the client to purchase fund shares outside of these programs. Clients may be able to purchase mutual funds directly from their respective fund families without incurring the firm’s advisory fee. When purchasing directly from fund families, clients may incur a front- or back-end sales charge, or “load”. Clients should note that only no-load or load-waived funds may be purchased in the Plan. Clients should also understand that the shares of certain mutual funds offered in these programs may impose short-term trading charges (typically 1%-2% of the amount originally invested) for redemptions generally made within short periods of time. These short-term charges are imposed by the funds (and not by the firm) to deter “market timers” who trade actively in fund shares. Clients should consider these short-term trading charges when selecting the program and/or mutual funds in which they invest. These market timing charges are available in each fund’s prospectus. Financial Planning Fees. The minimum fixed fee for creating client financial plans is $5,000. The fee is negotiable and the final fee schedule will be attached in the Financial Planning Agreement. The hourly fee for these services ranges between $400 and $1,000 depending upon the planner. The fees are negotiable and the final fee schedule will be attached in the Financial Planning Agreement. Fixed and hourly financial planning fees are paid via check. Fees are paid upon delivery of the financial plan. Clients may terminate the agreement without penalty, for full refund of the firm’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients Page 13 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  may terminate the Financial Planning Agreement upon written notice but fees will be due for work already performed. Item 6: Types of Clients Performance-Based Fees and Side by Side Management The firm does not charge performance-based fees. Item 7: Types of Clients The firm provides investment advisory services to individuals, pension and profit sharing plans, trusts, corporations, accredited investors, family offices and high net worth investors. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss The firm's research methods include charting, fundamental and technical analysis. Charting prepares a technical analysis using diagrams to illustrate various patterns or progressions in market or account movement. Fundamental analysis is an assessment of various factors including, but not limited to security price, book value, industry and market outlook and other characteristics of the security. Technical analysis employs the use of advanced data aggregation techniques to define certain trends of progressions in market place activity. We use technical analysis to place stops in accounts when appropriate. We also monitor all models on a daily basis in order to determine that they are within our expected parameters. The firm's primary approach to asset management utilizes a tactical allocation strategy which has been designed to reduce risk and increase performance. In order to accomplish this objective, the firm primarily invests in exchange-listed securities, corporate debt, municipal securities (bonds), treasury securities (bonds), variable life insurance, variable annuities and options-securities over the long term. The firm may recommend, on occasion, redistributing investment allocations to diversify the portfolio. The firm may make similar recommendations on specific stocks to increase sector weighting and/or dividend potential. Additionally, the firm may recommend employing cash positions as a possible hedge against market movement, where such movements may adversely affect the portfolio. The firm may also recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position(s) in the portfolio, change in risk tolerance of client, or any risk deemed unacceptable for the client’s risk tolerance. Page 14 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  The firm's main sources of research information include financial newspapers and magazines, annual reports, prospectuses, filings with the United States Securities and Exchange Commission, company press releases, and research materials prepared by others. Interval funds: are a type of closed-end fund that allow withdrawals only at set times, usually once a quarter. The fund may also impose limits on how much may be withdrawn during a quarter. Interval funds will usually invest in high-yielding and low-liquidity type investments that may not be found in normal mutual funds. This carries additional liquidity and valuation risk Risk of Loss: Investing in securities involves a certain amount of risk that clients should be prepared to bear. Accordingly, loss of money is a risk of investing in the securities recommended. Clients may be subject to the risk that the firm may allocate assets to an asset class that underperforms other asset classes. Prices of securities recommended by the firm may fall. As a result, your investment may decline in value and you could lose money. The following is a description of the specific material risks relating to the investment strategy employed and types of securities recommended by the firm: • Market Risk: Prices of securities recommended by us and held by you may fall. As a result, your investment may decline in value and you could lose money. • Growth Stocks Risk: The growth style may, over time, go in and out of favor. At times when the growth investing style is out of favor, your account may underperform accounts that use different investment styles. • Active Trading Risk: Active trading (“high portfolio turnover”) generally results in correspondingly greater transaction expenses. • Asset Allocation Risk: The firm maintains an asset allocation strategy and the amount invested in various asset classes of securities may change over time. Your account is subject to the risk that we may allocate assets to an asset class that underperforms other asset classes. • Interest Rate Risk: The value of debt obligations will typically fluctuate with interest rate changes. These fluctuations can be greater for debt obligations with longer maturities. When interest rates rise, debt obligations will generally decline in value and you could lose money as a result. Periods of declining or low interest rates may negatively impact the yield. • Credit Risk: Credit risk is the risk that the issuer of the debt obligation will be unable to make interest or principal payments on time. A decrease in an issuer’s credit rating may cause a decline in the value of the debt obligations held. • Private Fund Risk: The firm may invest in hedge funds or private equity funds. These private funds are not registered under the Investment Company Act or any other U.S. Page 15 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  federal or state securities laws or the laws of any other authority. The Investment Company Act provides certain protections to investors and imposes certain restrictions on registered investment companies, which will not be applicable to the private funds. • Derivatives Risk: The use of derivatives, such as futures, forwards, options and swaps, involves risks different from, or possibly greater than the risks associated with investing directly in securities. Prices of derivatives can be volatile and may move in unexpected ways, especially in unusual market conditions. Some derivatives are particularly sensitive to changes in interest rates. In addition, there may be imperfect or even negative correlation between the price of the derivatives contract and the price of the underlying securities. Other risks arise from the potential inability to terminate or sell derivative positions. Further, derivatives could result in loss if the counterparty to the transaction does not perform as promised. • Options Strategies: In limited situations, generally upon client direction and/or consent, the firm may engage in options transactions (or engage an independent investment manager to do so) for the purpose of hedging risk and/or generating portfolio income. The use of options transactions as an investment strategy can involve a high level of inherent risk. Option transactions establish a contract between two parties concerning the buying or selling of an asset at a predetermined price during a specific period of time. During the term of the option contract, the buyer of the option gains the right to demand fulfillment by the seller. Fulfillment may take the form of either selling or purchasing a security, depending upon the nature of the option contract. Generally, the purchase or sale of an option contract shall be with the intent of “hedging” a potential market risk in a client’s portfolio and/or generating income for a client’s portfolio. Please Note: Certain options- related strategies (i.e. straddles, short positions, etc.), may, in and of themselves, produce principal volatility and/or risk. Thus, a client must be willing to accept these enhanced volatility and principal risks associated with such strategies. In light of these enhanced risks, client may direct the firm, in writing, not to employ any or all such strategies for his/her/their/its accounts. • Covered Call Writing: Covered call writing is the sale of in-, at-, or out-of-the-money call options against a long security position held in a client portfolio. This type of transaction is intended to generate income. It also serves to create partial downside protection in the event the security position declines in value. Income is received from the proceeds of the option sale. Such income may be reduced or lost to the extent it is determined to buy back the option position before its expiration. There can be no assurance that the security will not be called away by the option buyer, which will result in the client (option writer) to lose ownership in the security and incur potential unintended tax consequences. Covered call strategies are generally better suited for positions with lower price volatility. • Long Put Option Purchases: Long put option purchases allow the option holder to sell or “put” the underlying security at the contract strike price at a future date. If the price of the underlying security declines in value, the value of the long-put option can increase in Page 16 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  value depending upon the strike price and expiration. Long puts are often used to hedge a long stock position to protect against downside risk. The security/portfolio could still experience losses depending on the quantity of the puts bought, strike price and expiration. In the event that the security is put to the option holder, it will result in the client (option seller) to lose ownership in the security and to incur potential unintended tax consequences. Options are wasting assets and expire (usually within months of issuance). • Long/Short Equity Strategy: On a limited basis, the firm may determine to allocate client assets to a long/short equity strategy (the “Strategy”) whereby both long and short positions within the same portfolio. Long-short equity is an investment strategy that seeks to take a long position in underpriced stocks while selling short, overpriced shares. Please Note: There can be no assurance that the Strategy will prove successful. Opt Out: A client can advise the firm, in writing, not to utilize the Strategy. Please Note: There can be no guarantee that an options strategy will achieve its objective or prove successful. No client is under any obligation to enter into any option transactions. However, if the client does so, he/she must be prepared to accept the potential for unintended or undesired consequences (i.e., losing ownership of the security, incurring capital gains taxes). ANY QUESTIONS: The firm’ Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding options. Questions regarding these risks and/or increased costs may be directed to the firm and its representatives. Item 9: Disciplinary Information Rule 206(4)-4 of the Investment Advisers Act of 1940 requires investment advisers to provide clients with disclosures as to any legal or disciplinary activities deemed material to the client’s evaluation of the adviser. Please note, neither the firm nor its personnel have any disciplinary, regulatory, criminal, civil, or otherwise reportable history to disclose at this time. Item 10: Other Financial Industry Activities and Affiliations Insurance: As indicated at Item 4 above, a client can purchase an insurance product from a firm representative in his/her separate individual capacity as a licensed insurance agent. Please Note-Conflict of Interest: The recommendation by a firm representative that a client purchase an insurance product presents a conflict of interest, as the receipt of an insurance commission may provide an incentive to recommend insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any insurance commission products from a firm representative. Clients can purchase insurance products recommended by a firm representative through other, non-affiliated insurance agents. Page 17 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  Commodities. The firm is also affiliated with Twelve Points Capital (“TPC”), an NFA member guaranteed introducing broker, whose business is separate and independent of the firm. Please Note-Conflict of Interest: Because a firm affiliate can earn compensation, the recommendation by a firm representative that a client purchase commodities through TPC presents a conflict of interest. No client is under any obligation to engage TPC. Clients can purchase commodities through other, non-affiliated brokers. Trustee Services. The firm is affiliated with Twelve Points Fiduciary Services (“Fiduciary”), a MA corporate trustee that provides trustee services for the firm’s clients. Please Note-Conflict of Interest: Because a firm affiliate can earn compensation, the recommendation by a firm representative that a client engage Fiduciary for trustee services presents a conflict of interest. No client is under any obligation to engage Fiduciary. Clients can obtain trustee services through other, non-affiliated trustees. See custody related disclosure at Item 15 below. Mr. Frangiadakis is a trustee of Frangiadakis and Deligiannides Family Trust. Mr. Frangiadakis does not receive any compensation for this activity and only helps administratively on family projects that are in the trust. ANY QUESTIONS: The firm’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding the above conflicts of interest. in Client Item 11: Code of Ethics, Participation or Interest Transactions and Personal Trading As required by Rule 204A-1 of the Investment Advisers Act of 1940, the firm has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all managers, officers, and employees of the firm. The Code of Ethics describes the firm’s fiduciary duties and obligations to clients, and sets forth the firm’s practice of supervising the personal securities transactions of employees who maintain access to client information. The Code of Ethics is available upon request. The firm collects and maintains records of securities holdings and transactions made by employees. The firm reviews the personal trading practices of its employees to identify and resolve any potential or realized conflicts of interest. The firm and/or its representatives may purchase or sell investments for their personal accounts that they have similarly recommended to clients. Page 18 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  Item 12: Brokerage Practices Brokerage Practices In the event that the client requests that the firm recommend a broker-dealer/custodian for execution and/or custodial services, the firm generally recommends that investment advisory accounts be maintained at Charles Schwab & Co., Inc., Fidelity, or Goldman Sachs. Prior to engaging the firm to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with the firm setting forth the terms and conditions under which the firm shall advise on the client's assets, and a separate custodial/clearing agreement with each designated broker-dealer/custodian. Factors that the firm considers in recommending Schwab, Fidelity, or Goldman Sachs (or any other broker-dealer/custodian to clients) include historical relationship with the firm, financial strength, reputation, execution capabilities, pricing, research, and service. Research and Benefits: Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, the firm can receive from Schwab, Fidelity, and/or Goldman Sachs (or another broker- dealer/custodian, investment manager, platform sponsor, mutual fund sponsor, or vendor) without cost (and/or at a discount) support services and/or products, certain of which assist the firm to better monitor and service client accounts maintained at such institutions. Included within the support services that can be obtained by the firm can be investment- related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support- including client events, computer hardware and/or software and/or other products used by the firm in furtherance of its investment advisory business operations. The firm’s clients do not pay more for investment transactions effected and/or assets maintained at Schwab, Fidelity, and/or Goldman Sachs as the result of this arrangement. There is no corresponding commitment made by the firm to Schwab, Fidelity, Goldman Sachs, or any other any entity, to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as result of the above arrangement. ANY QUESTIONS: The firm’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding the above arrangements and the corresponding conflict of interest presented by such arrangements. Directed Brokerage. The firm recommends that its clients utilize the brokerage and custodial services provided by Schwab, Fidelity, or Goldman Sachs. The firm generally does not accept directed brokerage arrangements (but could make exceptions). A directed brokerage arrangement arises when a client requires that account transactions be effected Page 19 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  through a specific broker-dealer/custodian, other than one generally recommended by the firm (i.e., Schwab, Fidelity, or Goldman Sachs). In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and the firm will not seek better execution services or prices from other broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers with orders for other accounts managed by the firm. As a result, a client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Please Note: In the event that the client directs the firm to effect securities transactions for the client’s accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative clearing arrangements that may be available through the firm. Please Also Note: Higher transaction costs adversely impact account performance. Please Further Note: Transactions for directed accounts will generally be executed following the execution of portfolio transactions for non-directed accounts. Order Aggregation. Transactions for each client account generally will be effected independently unless the firm decides to purchase or sell the same securities for several clients at approximately the same time. The Firm may (but is not obligated to) combine or “batch” such orders for individual equity transactions (including ETFs) with the intention to obtain better price execution, to negotiate more favorable commission rates, or to allocate more equitably among the firm’s clients differences in prices and commissions or other transaction costs that might have occurred had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. In the event that the firm becomes aware that a firm employee seeks to trade in the same security on the same day, the employee transaction will either be included in the “batch” transaction or transacted after all discretionary client transactions have been completed. The firm shall not receive any additional compensation or remuneration as the result of such aggregation. Item 13: Review of Accounts Accounts will be monitored on an ongoing basis by the firm. Accounts will be reviewed more frequently as necessary to respond to significant changes in client circumstances or changes in market conditions. Triggering factors to warrant more in depth review could include the following;  Awareness of a change in your investment objective change in market conditions  change in your employment status  re-balancing of assets to maintain proper asset allocation   other activity discovered as the account is normally reviewed. Page 20 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  You will receive written brokerage or custodial statements each quarter. You are encouraged to notify us of changes to your personal finances, especially those changes that might adversely affect your investment plan. All financial planning accounts are reviewed upon financial plan creation and plan delivery by the firm. There is only one level of review for financial plans, and that is the total review conducted to create the financial plan. With respect to financial plans, the firm’s services will generally conclude upon delivery of the financial plan. The firm will provide monthly, quarterly and annual holdings reports in addition to the quarterly statements that you receive from the broker-dealer or custodian. The reports will generally include a portfolio appraisal, realized and unrealized gains/losses, income and expenses, contributions and withdrawals, and performance history. Item 14: Client Referrals and Other Compensation As indicated at Item 12 above, the firm can receive from Schwab, Fidelity, or Goldman Sachs (and others) without cost (and/or at a discount), support services and/or products. The firm’s clients do not pay more for investment transactions effected and/or assets maintained at Schwab, Fidelity, or Goldman Sachs (or any other institution) as result of this arrangement. There is no corresponding commitment made by the firm to Schwab, Fidelity, Goldman Sachs, or to any other entity, to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as the result of the above arrangement. ANY QUESTIONS: The firm’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding the above arrangement and the corresponding conflicts of interest presented by such arrangements. The firm engages promoters to introduce new prospective clients to the Promoter consistent with the Investment Advisers Act of 1940, its corresponding. Rules, and applicable state regulatory requirements. If the prospect subsequently engages the Promoter, the promoter shall generally be compensated by the Promoter for the introduction. Because the promoter has an economic incentive to introduce the prospect to the Promoter, a conflict of interest is presented. The promoter’s introduction shall not result in the prospect’s payment of a higher investment advisory fee to the Promoter (i.e., if the prospect was to engage the Promoter independent of the promoter’s introduction). The promoter, at the time of the introduction, shall usually provide the prospective client with a written disclosure statement reflecting the arrangement with the Promoter, together with a copy of: (1) the Promoter ’s written disclosure Brochure; and, (2) Form CRS (if the prospect is a retail client). Page 21 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  Item 15: Custody The firm shall have the ability to deduct its advisory fee from the client’s custodial account. Clients are provided with written transaction confirmation notices, and a written summary account statement directly from the custodian (i.e., Schwab, Fidelity, Goldman Sachs, etc.) at least quarterly. Please Note: To the extent that the firm provides clients with periodic account statements or reports, the client is urged to compare any statement or report provided by the firm with the account statements received from the account custodian. Please Also Note: The account custodian does not verify the accuracy of the firm’s advisory fee calculation. In addition, the firm, certain of its employees, and its affiliate (see disclosure regarding Fiduciary at Item 10 above) can engage in other services and/or practices (i.e., billpaying, trustee service, etc.) requiring disclosure at Item 9 of Part 1 of Form ADV. These services and practices result in the firm having custody under Rule 206(4)-2 of the Advisers Act. Per the Rule, having such custody requires the firm to undergo an annual surprise CPA examination, and make a corresponding Form ADV-E filing with the SEC, for as long as the firm and/or its employees and affiliates provide such services and/or engages in such practices. ANY QUESTIONS: The firm’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding custody-related issues. Item 16: Investment Discretion The firm maintains discretionary authority over the selection and amount of securities to be bought or sold in client accounts without obtaining prior consent or approval from clients. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the client and agreed to by the firm. Discretionary authority will only be authorized upon full disclosure to the client. The granting of such authority will be evidenced by the client’s execution of an agreement containing all applicable limitations to such authority. All discretionary trades made by the firm will be in accordance with each client’s investment objectives and goals. Item 17: Voting Client Securities The firm has adopted and implemented written Proxy Voting Policies and Procedures (“Proxy Voting Procedures”). These procedures have been designed to reasonably ensure that votes are made in your best interest. The Proxy Voting Procedures describe how the firm addresses voting authority, material conflicts of interest, voting decisions, notification to you, books and records requirements, etc. and ensures that proxies are voted in the best interest of you, the client. Page 22 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC  Within the firm's fiduciary obligation to clients, the firm must ensure that any proxies for which it has voting authority are voted solely in the best interests, and for the exclusive benefit, of you, the client. The Proxy Voting Procedures are intended to guide the firm and its personnel in ensuring that proxies are voted in such manner without limiting the firm or its personnel in specific situations to vote in a predetermined manner. These policies are designed to assist the firm in identifying and resolving any conflicts of interest with regard to voting client proxies. A copy of the firm’s Proxy Voting Policies and Procedures may be obtained upon request. The firm shall vote proxies in conjunction with the proxy voting administrative and due diligence services provided by Proxy Edge, an unaffiliated nationally recognized proxy voting service of Broadridge Financial Solutions, Inc. (“Broadridge”). The firm, in conjunction with the services provided by Broadridge, shall monitor corporate actions of individual issuers and investment companies consistent with the firm’s fiduciary duty to vote proxies in the best interests of its clients. Item 18: Financial Information Under Rule 206(4)-4 of the Investment Advisers Act of 1940, investment advisers are required to disclose certain financial information about their business practices that might serve as material to the client’s decision in choosing an investment adviser. On April 23, 2020, the firm received a Paycheck Protection Plan Loan through the SBA in conjunction with the relief afforded from the CARES Act. The firm used the PPP to continue payroll for the firm and it did not suffer any interruption of service. As of the date of this filing, the firm does not require the pre-payment of more than $1,200 in fees per client six months or more in advance or maintain any financial hardships or other conditions that might impair its ability to meet its contractual obligations to clients. ANY QUESTIONS: The firm’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions regarding this Part 2A. Page 23 Form ADV Part 2A: Investment Adviser Brochure Twelve Points Wealth Management LLC 

Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC Twelve Points Wealth Management LLC 9 Pond Lane Suite 3A Concord, MA 01742 Telephone 978-318-9500 Fax 978-318-9505 Form ADV Part 2A Appendix 1 Wrap Fee Program Brochure www.twelvepointswealth.com Firm CRD#: 171107 March 31, 2026 This Wrap Fee Program Brochure provides information about the qualifications and business practices of Twelve Points Wealth Management LLC (“Twelve Points Wealth”). This Brochure also describes Twelve Points Wealth’s wrap fee investment advisory plan (the “Plan Program”) and contains information that should be considered before becoming a client of the Plan Program. If you have any questions about the contents of this brochure, please contact us at 978-318-9500. The Plan Program may cost more or less than purchasing investment advisory, brokerage, and custodial services separately, depending upon the separate costs of such services and the trading activity in the client’s account. Additional information about Twelve Points Wealth is also available on the SEC’s website at www.adviserinfo.sec.gov. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. 1  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC Item 2 – Material Changes There have been material changes to this brochure since Twelve Points Wealth Management’s last annual updating amendment on 03/31/2025. Material changes relate to Twelve Points Wealth Management’s policies, practices or conflicts of interest.  Item 4 o The Firm included disclosure concerning fees paid for U.S. Treasury Bill securities. Additional information about Twelve Points Wealth and its representatives is also available on the SEC’s website at www.adviserinfo.sec.gov. Item 3 – Table of Contents Item 1 – Cover Page ........................................................................................................................ 1 Item 2 – Material Changes ...............................................................................................................2 Item 3 – Table of Contents ...............................................................................................................2 Item 4 - Services, Fees and Compensation.......................................................................................2 Item 5- Account Requirements and Types of Accounts ...................................................................5 Item 6- Portfolio Manager Selection and Evaluation .......................................................................6 Item 7- Client Information Provided to Portfolio Managers .......................................................... 11 Item 8- Client Contact with Portfolio Managers ............................................................................ 11 Item 9- Additional Information ...................................................................................................... 11 Item 4 - Services, Fees and Compensation Twelve Points Wealth Management LLC (“Twelve Points Wealth”), a registered investment adviser, operates a wrap fee advisory service called the Twelve Points Portfolio Plan (the “Plan”). The Twelve Points Portfolio Plan is an advisory program where portfolio management services are provided to the client on a discretionary basis for a wrap fee based on the market value of all of the securities in the account. As a discretionary account, the portfolio manager is not required to contact the client prior to each transaction. Twelve Points Wealth's primary approach to asset management utilizes a tactical allocation strategy which has been designed to reduce risk and increase performance. Accounts will be monitored on an on-going basis by Twelve Points Wealth. Accounts will be reviewed more frequently as necessary to respond to significant changes in client circumstances or changes in market conditions. The Firm managed $2,135,958,620 on a discretionary basis and $107,903,954 on a non- discretionary basis for a total of $2,243,862,574 of assets under management as of December 31, 2025. 2  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC The fee schedule is as follows: Assets Under Management Annual Fee (%) Under $5,000,000 1.00%/Negotiable $5,000,001 - $15,000,000 0.60%/Negotiable Over $15,000,001 0.40%/Negotiable The firm maintains a minimum asset level of $500,000 and a minimum fee level of 1.00%. 75-90% of the total fee is paid to the portfolio manager(s). Clients who engage the firm are charged an asset management fee of 50 basis points (0.50%) for U.S. Treasury Bill securities. Fee Dispersion. Twelve Points Wealth, in its discretion, may charge a lesser investment advisory fee, charge a flat fee, waive its fee entirely, or charge fee on a different interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules, employees and family members, courtesy accounts, competition, negotiations with client, etc.). Please Note: As result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees. ANY QUESTIONS: Twelve Points Wealth’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding advisory fees. Wrap Program-Conflict of Interest. Except for participant directed retirement plan engagements referenced below, Twelve Points Wealth provides services on a wrap fee basis as a wrap program sponsor. Under Twelve Points Wealth’s wrap program, the client generally receives investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the client more or less than purchasing such services separately. The terms and conditions of a wrap program engagement are more fully discussed in Twelve Points Wealth’s Wrap Fee Program Brochure. Conflict of Interest. Because wrap program transaction fees and/or commissions are being paid by Twelve Points Wealth to the account custodian/broker-dealer, Twelve Points Wealth could have an economic incentive to maximize its compensation by seeking to minimize the number of trades in the client's account. See separate Wrap Fee Program Brochure. Twelve Points Wealth’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding a wrap fee arrangement and the corresponding conflict of interest. 3  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC Services and Fees The Plan offers investors the opportunity to obtain professional investment services and brokerage services for one all-inclusive fee based on assets under management. The wrap fee is an asset- based fee which includes the management fee paid to Twelve Points Wealth for its services as portfolio manager, as well as broker-dealer, custodial and clearing expenses. Fees are charged in advance based on the market value of assets on the last trading day of each calendar quarter. In any partial calendar quarter, fees are pro-rated based on the number of days in which the account is open during the quarter. Although Twelve Points Wealth has an established fee schedule set forth in this brochure, the asset- based fees are negotiable at the sole discretion of Twelve Points Wealth. Fees may be negotiated based on a variety of factors, including the complexity and nature of the services, and the scope of the overall engagement. Upon termination, any fees paid in advance will be prorated to the date of termination and any excess shall be refunded to you. Your advisory agreement with Twelve Points Wealth is non-transferable without your written approval. The client’s portfolio manager may have a financial incentive to recommend the wrap fee program over other programs or services. Portfolio Managers of Twelve Points Wealth will receive a percentage of the wrap fees paid by advisory clients to compensate them for solicitation, shareholder support, advice, order placement and execution and other services. This compensation may be more than the portfolio manager would receive under an alternative Program or if the client paid for advisory, brokerage, and other services separately. If a client were to purchase services similar to those offered in the Plan separately, he or she would be required to pay brokerage commissions, custodial fees (if any), and investment advisory fees. Therefore, the plan may cost more or less than purchasing these services independently. The factors that should be considered when determining whether to participate in the Plan include the expected level of trading activity in the account, the corresponding brokerage commissions and transaction- related expenses that would be charged for the execution of trades, and the fees charged for the investment advisory services offered within the Plan. The Plan fee includes not only the fee of Twelve Points Wealth, but also all custody and brokerage commissions for transactions executed in the client’s account. In making the determination of whether the aforementioned wrap fee programs are appropriate for their needs, clients should bear in mind that wrap fee arrangements, when compared with the option of paying transaction charges separately, generally result in lower costs during periods when trading activity is heavier, such as the year an account is established. During periods when trading activity is lower, such arrangements may result in a higher annual cost for transactions. Thus, the overall cost of the Plan will vary significantly, depending on the account size, amount of turnover, type of securities purchased or sold, quantities of securities purchased or sold, commission rates negotiated with the broker/dealer, and the client’s tax situation. When making cost comparisons, clients should be aware that the combination of investment advisory, custodial and brokerage services available 4  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC through these programs may not be available separately or may require multiple accounts, documentation and fees. Other Expenses and Fees The advisory fees discussed above do not include certain indirect costs that may be associated with securities purchased or held in an account. Examples of indirect costs include custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), markups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the wrap-fee you are charged by our firm. Clients should understand that the annual advisory fees charged in the wrap program are in addition to the management fees and operating expenses charged by open-end, closed-end and exchange- traded funds. Certain open-end mutual funds may also assess a distribution fee or an administrative or service fee (“trail”). Such fees are included in the calculation of operating expenses of a mutual fund and are disclosed in the fund prospectus. To the extent that a client intends to hold fund shares for an extended period of time, it may be more economical for the client to purchase fund shares outside of these programs. Clients may be able to purchase mutual funds directly from their respective fund families without incurring Twelve Points Wealth’s advisory fee. When purchasing directly from fund families, clients may incur a front- or back-end sales charge, or “load”. Clients should note that only no-load or load-waived funds may be purchased in the Plan. Clients should also understand that the shares of certain mutual funds offered in these programs may impose short-term trading charges (typically 1%-2% of the amount originally invested) for redemptions generally made within short periods of time. These short-term charges are imposed by the funds (and not by Twelve Points Wealth) to deter “market timers” who trade actively in fund shares. Clients should consider these short-term trading charges when selecting the program and/or mutual funds in which they invest. These market timing charges are available in each fund’s prospectus. As Twelve Points Wealth absorbs certain transaction costs in wrap fee accounts, the company may have a financial incentive not to place transaction orders in those accounts since doing so increases its transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement. Item 5 - Account Requirements and Types of Accounts Although Twelve Points Wealth has an established fee schedule set forth in this brochure, the asset- based fees are negotiable and are at the discretion of Twelve Points Wealth. 5  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC Types of Wrap Fee Account Clients Twelve Points Wealth offers participation in the Twelve Points Portfolio Plan programs to the following types of clients: Individuals • • Pension and profit sharing plans • Trusts, estates and charitable organizations • Corporations (including S Corps and LLCs) • Small Business and others • Accredited and high net worth investors • Family offices Item 6 - Portfolio Manager Selection and Evaluation David Clayman, Principal and Co-Founder, oversees and is responsible for the advisory program offered at Twelve Points Wealth. Twelve Points Wealth selected Mr. Clayman for this position based upon his educational and work experience within the investment field (bio below). Twelve Points Wealth generally requires that the portfolio manager meets the following standards in order to initially participate in the program: • Series 7 and State-required licenses (unless state exemption is available) • Not more than three sales practice-related complaints in the past 5 years and no forgery, misappropriation, unauthorized trading or similar settled or otherwise finalized actions in the last 10 years. • Work experience of three years (as a portfolio manager or equivalent experience directly related to management of client assets). Twelve Points Wealth may make exceptions to the policy above if the firm believes there are extenuating circumstances or considerations. Once an employee is approved as portfolio manager, Twelve Points Wealth will normally allow them to continue operating in that capacity. BIO David Clayman, Principal, Co-Founder, CMT®, AIF®, C(k)P, CPWA® Business Background: Before joining Twelve Points, Mr. Clayman’s professional associations included Senior Vice President positions with Citigroup Global Markets Inc. and UBS Financial Services. Most recently Mr. Clayman was a registered representative and registered advisor with Morgan Stanley. Selection and Review of Portfolio Managers 6  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC The Twelve Points Portfolio Plan is a proprietary investment program. All new participants must enter into an investment advisory agreement with Twelve Points Wealth. Accounts will be monitored on an on-going basis by Twelve Points Wealth. Accounts will be reviewed more frequently as necessary to respond to significant changes in client circumstances or changes in market conditions. Clients are encouraged to notify us of changes to your personal finances, especially those changes that might adversely affect your investment plan. Clients will receive written brokerage or custodial statements each quarter. Twelve Points Wealth will also provide monthly, quarterly and annual holdings reports in addition to the quarterly statements that you receive from the broker-dealer or custodian. The reports will generally include a portfolio appraisal, realized and unrealized gains/losses, income and expenses, contributions and withdrawals, and performance history. Types of Advisory Services Offered, Tailoring of Advisory Programs and Reasonable Restrictions Twelve Points Wealth provides investment advisory services to clients on a discretionary basis. Twelve Points Wealth provides investment supervisory services to individuals, pension and profit sharing plans, trusts, corporations, accredited investors, family offices and high net worth investors. The firm's investment management strategy is implemented in conjunction with the client’s investment objectives, risk tolerance level, liquidity needs, tax and/or legal implications and other concerns where applicable. The foregoing services are provided pursuant to one or more written agreements setting forth the terms and conditions of services rendered. Clients may request that reasonable restrictions be imposed on the management of their wrap account. Methods of Analysis, Investment Strategies and Risk of Loss Twelve Points Wealth's research methods include charting, fundamental and technical analysis. Charting prepares a technical analysis using diagrams to illustrate various patterns or progressions in market or account movement. Fundamental analysis is an assessment of various factors including, but not limited to security price, book value, industry and market outlook and other characteristics of the security. Technical analysis employs the use of advanced data aggregation techniques to define certain trends of progressions in market place activity. We use technical analysis to place stops in accounts when appropriate. We also monitor all models on a daily basis in order to determine that they are within our expected parameters. Twelve Points Wealth's primary approach to asset management utilizes a tactical allocation strategy which has been designed to reduce risk and increase performance. In order to accomplish this objective, Twelve Points Wealth primarily invests in exchange-listed securities, corporate debt, municipal securities (bonds), treasury securities (bonds), variable life insurance, variable annuities and options-securities over the long term. 7  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC Twelve Points Wealth may recommend, on occasion, redistributing investment allocations to diversify the portfolio. The firm may make similar recommendations on specific stocks to increase sector weighting and/or dividend potential. Additionally, the firm may recommend employing cash positions as a possible hedge against market movement, where such movements may adversely affect the portfolio. Twelve Points Wealth may also recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position(s) in the portfolio, change in risk tolerance of client, or any risk deemed unacceptable for the client’s risk tolerance. Twelve Points Wealth's main sources of research information include financial newspapers and magazines, annual reports, prospectuses, filings with the United States Securities and Exchange Commission, company press releases, and research materials prepared by others. Interval funds: are a type of closed-end fund that allow withdrawals only at set times, usually once a quarter. The fund may also impose limits on how much may be withdrawn during a quarter. Interval funds will usually invest in high-yielding and low-liquidity type investments that may not be found in normal mutual funds. This carries additional liquidity and valuation risk Risk of Loss: Investing in securities involves a certain amount of risk that clients should be prepared to bear. Accordingly, loss of money is a risk of investing in the securities recommended. Clients may be subject to the risk that Twelve Points Wealth may allocate assets to an asset class that underperforms other asset classes. Prices of securities recommended by Twelve Points Wealth may fall. As a result, your investment may decline in value and you could lose money. The following is a description of the specific material risks relating to the investment strategy employed and types of securities recommended by Twelve Points Wealth: Market Risk: Prices of securities recommended by us and held by you may fall. As a • result, your investment may decline in value and you could lose money. Active Trading Risk: Active trading (“high portfolio turnover”) generally results in • Growth Stocks Risk: The growth style may, over time, go in and out of favor. At times when the growth investing style is out of favor, your account may underperform accounts that use different investment styles. • correspondingly greater transaction expenses. • Asset Allocation Risk: Twelve Points Wealth maintains an asset allocation strategy and the amount invested in various asset classes of securities may change over time. Your account is subject to the risk that we may allocate assets to an asset class that underperforms other asset classes. • Interest Rate Risk: The value of debt obligations will typically fluctuate with interest rate changes. These fluctuations can be greater for debt obligations with longer maturities. When 8  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC interest rates rise, debt obligations will generally decline in value and you could lose money as a result. Periods of declining or low interest rates may negatively impact the yield. • Credit Risk: Credit risk is the risk that the issuer of the debt obligation will be unable to make interest or principal payments on time. A decrease in an issuer’s credit rating may cause a decline in the value of the debt obligations held. • Private Fund Risk: Twelve Points Wealth may invest in hedge funds or private equity funds. These private funds are not registered under the Investment Company Act or any other U.S. federal or state securities laws or the laws of any other jurisdiction. The Investment Company Act provides certain protections to investors and imposes certain restrictions on registered investment companies, which will not be applicable to the private funds. • Derivatives Risk: The use of derivatives, such as futures, forwards, options and swaps, involves risks different from, or possibly greater than the risks associated with investing directly in securities. Prices of derivatives can be volatile and may move in unexpected ways, especially in unusual market conditions. Some derivatives are particularly sensitive to changes in interest rates. In addition, there may be imperfect or even negative correlation between the price of the derivatives contract and the price of the underlying securities. Other risks arise from the potential inability to terminate or sell derivative positions. Further, derivatives could result in loss if the counterparty to the transaction does not perform as promised. • Options Strategies: In limited situations, generally upon client direction and/or consent, Twelve Points may engage in options transactions (or engage an independent investment manager to do so) for the purpose of hedging risk and/or generating portfolio income. The use of options transactions as an investment strategy can involve a high level of inherent risk. Option transactions establish a contract between two parties concerning the buying or selling of an asset at a predetermined price during a specific period of time. During the term of the option contract, the buyer of the option gains the right to demand fulfillment by the seller. Fulfillment may take the form of either selling or purchasing a security, depending upon the nature of the option contract. Generally, the purchase or sale of an option contract shall be with the intent of “hedging” a potential market risk in a client’s portfolio and/or generating income for a client’s portfolio. Please Note: Certain options-related strategies (i.e. straddles, short positions, etc.), may, in and of themselves, produce principal volatility and/or risk. Thus, a client must be willing to accept these enhanced volatility and principal risks associated with such strategies. In light of these enhanced risks, client may direct Twelve Points, in writing, not to employ any or all such strategies for his/her/their/its accounts. • Covered Call Writing: Covered call writing is the sale of in-, at-, or out-of-the-money call options against a long security position held in a client portfolio. This type of transaction is intended to generate income. It also serves to create partial downside protection in the event the security position declines in value. Income is received from the proceeds of the option sale. Such income may be reduced or lost to the extent it is determined to buy back the option position before its expiration. There can be no assurance that the security will not be called away by the option buyer, which will result in the client (option writer) to lose ownership in the security and incur potential unintended tax consequences. Covered call strategies are generally better suited for positions with lower price volatility. 9  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC • Long Put Option Purchases: Long put option purchases allow the option holder to sell or “put” the underlying security at the contract strike price at a future date. If the price of the underlying security declines in value, the value of the long-put option can increase in value depending upon the strike price and expiration. Long puts are often used to hedge a long stock position to protect against downside risk. The security/portfolio could still experience losses depending on the quantity of the puts bought, strike price and expiration. In the event that the security is put to the option holder, it will result in the client (option seller) to lose ownership in the security and to incur potential unintended tax consequences. Options are wasting assets and expire (usually within months of issuance). • Long/Short Equity Strategy: On a limited basis, Twelve Points may determine to allocate client assets to a long/short equity strategy (the “Strategy”) whereby both long and short positions within the same portfolio. Long-short equity is an investment strategy that seeks to take a long position in underpriced stocks while selling short, overpriced shares. Please Note: There can be no assurance that the Strategy will prove successful. Opt Out: A client can advise Twelve Points, in writing, not to utilize the Strategy. Questions regarding these risks and/or increased costs may be directed to the firm and its representatives. Performance-Based Fees and Side-By-Side Management Twelve Points Wealth does not charge performance-based fees. Voting Client Securities Twelve Points Wealth has adopted and implemented written Proxy Voting Policies and Procedures (“Proxy Voting Procedures”). These procedures have been designed to reasonably ensure that votes are made in your best interest. The Proxy Voting Procedures describe how Twelve Points Wealth Management LLC addresses voting authority, material conflicts of interest, voting decisions, notification to you, books and records requirements, etc. and ensures that proxies are voted in the best interest of you, the client. Within Twelve Points Wealth's fiduciary obligation to clients, the firm must ensure that any proxies for which it has voting authority are voted solely in the best interests, and for the exclusive benefit, of you, the client. The Proxy Voting Procedures are intended to guide Twelve Points Wealth Management LLC and its personnel in ensuring that proxies are voted in such manner without limiting the firm or its personnel in specific situations to vote in a predetermined manner. These policies are designed to assist Twelve Points Wealth Management LLC in identifying and resolving any conflicts of interest with regard to voting client proxies. A copy of Twelve Points Wealth's Proxy Voting Policies and Procedures may be obtained upon request. 10  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC Item 7 - Client Information Provided to Portfolio Managers Information Provided to Affiliated Portfolio Managers Twelve Points Wealth employees who serve as portfolio managers have access to all client information, and updates to such information, obtained by Twelve Points Wealth with respect to the particular client accounts they manage. Item 8 - Client Contact with Portfolio Managers The primary point of contact for clients is the client’s portfolio manager. There are no restrictions on a client’s access to his or her portfolio manager. Item 9 - Additional Information Disciplinary Information Rule 206(4)-4 of the Investment Advisers Act of 1940 requires investment advisers to provide clients with disclosures as to any legal or disciplinary activities deemed material to the client’s evaluation of the adviser. Please note, neither the firm nor its personnel have any disciplinary, regulatory, criminal, civil, or otherwise reportable history to disclose at this time. Other Financial Industry Activities and Affiliations Certain employees of Twelve Points Wealth are licensed insurance agents offering health insurance, life insurance, and long-term care insurance to select individuals including clients of Twelve Points Wealth as appropriate. The licensed insurance agents receive compensation in the form of commissions for this activity. Certain employees also provide commodities-related services on behalf of Twelve Points Capital LLC to select individuals including clients of Twelve Points Wealth as appropriate. Twelve Points Capital LLC is currently registered with the National Futures Association (NFA) as a guaranteed introducing broker and is under common control with Twelve Points Wealth. Clients of Twelve Points Capital pay a commission for commodities-related transactions. The firm is affiliated with Twelve Points Fiduciary Services (“Fiduciary”), a MA corporate trustee that provides trustee services for the firm’s clients. Please Note-Conflict of Interest: Because a firm affiliate can earn compensation, the recommendation by a firm representative that a client engage Fiduciary for trustee services presents a conflict of interest. No client is under any obligation to engage Fiduciary. Clients can obtain trustee services through other, non-affiliated trustees. The relationships described above create conflicts of interest, including the receipt of additional compensation. These conflicts are mitigated by a variety of factors, including the following: (1) Twelve Points Wealth’s fiduciary obligations to act in the best interest of its clients, (2) 11  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC Employees’ duty to honor the Code of Ethics, which prohibit firm personnel from acting in such a manner as to promote their own interests over those of the client, (3) Twelve Points Wealth’s obligation, on an ongoing basis, to review client accounts, and (4) Twelve Points Wealth’s commitment not to place its interests or those of any of its affiliates before its clients’ interests when providing investment management services. For additional information concerning these conflicts of interest, please review the firm’s ADV Part 2A Brochure. Code of Ethics As required by Rule 204A-1 of the Investment Advisers Act of 1940, Twelve Points Wealth has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all managers, officers, and employees of the firm. The Code of Ethics describes the firm's fiduciary duties and obligations to clients, and sets forth the firm’s practice of supervising the personal securities transactions of employees who maintain access to client information. The Code of Ethics is available upon request. Twelve Points Wealth collects and maintains records of securities holdings and transactions made by employees. The firm reviews the personal trading practices of its employees to identify and resolve any potential or realized conflicts of interest. Twelve Points Wealth and/or its representatives may purchase or sell investments for their personal accounts that they have similarly recommended to clients. Review of Accounts Accounts will be monitored on an on-going basis by Twelve Points Wealth. Accounts will be reviewed more frequently as necessary to respond to significant changes in client circumstances or changes in market conditions. Triggering factors to warrant more in-depth review could include the following: • Awareness of a change in your investment objective • • • • change in market conditions change in your employment status re-balancing of assets to maintain proper asset allocation other activity discovered as the account is normally reviewed. You will receive written brokerage or custodial statements each quarter. You are encouraged to notify us of changes to your personal finances, especially those changes that might adversely affect your investment plan. Twelve Points Wealth will provide monthly, quarterly and annual holdings reports in addition to the quarterly statements that you receive from the broker-dealer or custodian. The reports will generally 12  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC include a portfolio appraisal, realized and unrealized gains/losses, income and expenses, contributions and withdrawals, and performance history. Economic Benefits Disclosure Twelve Points Wealth may recommend/require that clients establish brokerage accounts with a particular custodian (currently Schwab Advisor Services, Fidelity, or Goldman Sachs) to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with a custodian is at the discretion of the Advisor’s clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. Twelve Points Wealth is independently owned and operated and not affiliated with the custodians. The custodians provide Twelve Points with access to their institutional trading and custody services, which are typically not available to the custodians’ retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor’s clients’ assets are maintained in accounts at the particular custodian. The custodians’ services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For Twelve Points client accounts maintained in its custody, the custodian generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through the custodian or that settle into the custodian’s accounts. The custodian also makes available to Twelve Points other products and services that benefit Twelve Points but may not benefit its clients’ accounts. . These benefits may include national, regional or Twelve Points specific educational events organized and/or sponsored by the custodian. Other potential benefits may include occasional business entertainment of personnel of Twelve Points by the custodians’ personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist Twelve Points in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment Twelve Points’ fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of Twelve Points’ accounts, including accounts not maintained at the custodian. The custodian also makes available to Twelve Points other services intended to help Twelve Points manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, the 13  Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure Twelve Points Wealth Management LLC custodian may make available, arrange and/or pay vendors for these types of services rendered to Twelve Points by independent third parties. The custodian may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to Twelve Points. While, as a fiduciary, Twelve Points endeavors to act in its clients’ best interests, Twelve Points’ recommendation/requirement that clients maintain their assets in accounts at either custodian may be based in part on the benefit to Twelve Points of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by the custodian, which may create a potential conflict of interest. Client Referrals and Other Compensation Twelve Points Wealth may from time to time compensate, either directly or indirectly, any person (defined as a natural person or a company) for client referrals. Pursuant to Section 206 (4)-1 of the Investment Advisers Act of 1940, all appropriate disclosures shall be made, all written documentation will be maintained by Twelve Points Wealth and all applicable federal and/or state laws will be observed. Financial Information Under Rule 206(4)-4 of the Investment Advisers Act of 1940, investment advisers are required to disclose certain financial information about their business practices that might serve as material to the client’s decision in choosing an investment adviser. As of the date of this filing, Twelve Points Wealth does not require the pre-payment of more than $1,200 in fees per client six months or more in advance or maintain any financial hardships or other conditions that might impair its ability to meet its contractual obligations to clients. 14