Urs Advisory

F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Main Office Address: 4425 N Military Trail, Suite 208 Jupiter, FL 33458 Tel: 561-594-0100 Fax: 561-584-6892 Website: www.URSAdvisory.com Email: Compliance@URSAdvisory.com May 4, 2026 This brochure provides information about the qualifications and business practices of URS Advisory. Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 561-594-0100. 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. A D D I T I O N A L I N F O R M A T I O N A B O U T U R S A D V I S O R Y L L C ( C R D # 2 8 9 8 9 2 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V i URS Advisory  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update Since the last filing of this brochure on March 30, 2026, the following changes have occurred: • We have updated our email address. • Item 4 has been updated to disclose the most recent calculation for client assets under management. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm. ii URS Advisory  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Full Brochure Available .................................................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 2 Wrap Fee Programs ......................................................................................................................................................... 2 Client Assets under Management .............................................................................................................................. 3 Item 5: Fees and Compensation ....................................................................................................... 3 Method of Compensation and Fee Schedule .......................................................................................................... 3 Client Payment of Fees ................................................................................................................................................... 5 Additional Client Fees Charged ................................................................................................................................... 5 Prepayment of Client Fees ............................................................................................................................................ 5 External Compensation for the Sale of Securities to Clients ........................................................................... 5 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 5 Sharing of Capital Gains ................................................................................................................................................. 5 Item 7: Types of Clients ....................................................................................................................... 5 Description .......................................................................................................................................................................... 5 Account Minimums .......................................................................................................................................................... 6 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 6 Methods of Analysis ......................................................................................................................................................... 6 Investment Strategy ........................................................................................................................................................ 6 Security Specific Material Risks .................................................................................................................................. 7 Item 9: Disciplinary Information ..................................................................................................... 9 Criminal or Civil Actions ................................................................................................................................................ 9 Administrative Enforcement Proceedings ............................................................................................................. 9 iii  Self- Regulatory Organization Enforcement Proceedings ............................................................................... 9 Item 10: Other Financial Industry Activities and Affiliations ............................................. 10 Broker-Dealer or Representative Registration ................................................................................................. 10 Futures or Commodity Registration ...................................................................................................................... 10 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 10 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................................................................................... 11 Code of Ethics Description ......................................................................................................................................... 11 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 11 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 11 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest .................................................................................................................. 12 Item 12: Brokerage Practices ......................................................................................................... 12 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 12 Aggregating Securities Transactions for Client Accounts ............................................................................. 13 Item 13: Review of Accounts ........................................................................................................... 13 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 13 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 13 Content of Client Provided Reports and Frequency ........................................................................................ 13 Item 14: Client Referrals and Other Compensation ................................................................ 14 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 14 Advisory Firm Payments for Client Referrals .................................................................................................... 14 Item 15: Custody .................................................................................................................................. 14 Account Statements ...................................................................................................................................................... 14 Item 16: Investment Discretion ..................................................................................................... 14 Discretionary Authority for Trading...................................................................................................................... 14 Item 17: Voting Client Securities ................................................................................................... 14 Proxy Votes ...................................................................................................................................................................... 14 Item 18: Financial Information ...................................................................................................... 14 Balance Sheet .................................................................................................................................................................. 14 iv  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 15 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 15 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 17 Principal Executive Officer – Erik Lembcke ........................................................................................................ 17 Item 2 - Educational Background and Business Experience ....................................................................... 17 Item 3 - Disciplinary Information ........................................................................................................................... 18 Item 4 - Other Business Activities Engaged In ................................................................................................... 18 Item 5 - Additional Compensation .......................................................................................................................... 18 Item 6 - Supervision ..................................................................................................................................................... 19 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 21 Principal Executive Officer – Julia Lembcke ....................................................................................................... 21 Item 2 - Educational Background and Business Experience ....................................................................... 21 Item 3 - Disciplinary Information ........................................................................................................................... 23 Item 4 - Other Business Activities Engaged In ................................................................................................... 23 Item 5 - Additional Compensation .......................................................................................................................... 24 Item 6 - Supervision ..................................................................................................................................................... 24 v  Item 4: Advisory Business Firm Description URS Advisory LLC dba URS Advisory was founded in 2017. Erik Lembcke and Julia Lembcke are each 50% owner. URS Advisory is a fee-based financial planning and investment advisory firm. URS does not sell annuities or insurance products, but the Managing Members offers these products through an affiliated company, JEL Enterprises, Inc. dba URS Insurance. URS Advisory does not act as a custodian of Client assets. An evaluation of each Client's initial situation is provided to the Client, often in the form of a net worth statement, risk analysis or similar document. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the Client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are engaged directly by the Client on an as-needed basis and may charge fees of their own. Conflicts of interest will be disclosed to the Client in the event they should occur. Types of Advisory Services ASSET MANAGEMENT URS Advisory offers discretionary asset management services to advisory Clients. URS Advisory will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize URS Advisory discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. When deemed appropriate for the Client, URS Advisory may hire Sub-Advisors to manage all or a portion of the assets in the Client account. URS Advisory has full discretion to hire and fire Sub-Advisors as we deem suitable. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and URS Advisory. Sub-Advisors execute trades on behalf of URS Advisory in Client accounts. URS Advisory will be responsible for the overall direct relationship with the Client. URS Advisory retains the authority to terminate the Sub-Advisor relationship at URS Advisory’s discretion. FINANCIAL PLANNING AND CONSULTING URS Advisory offers Comprehensive Financial Planning services as well as Special Needs Financial Planning services as outlined below: Comprehensive Financial Plan Financial planning services include a complete evaluation of an investor's current and future financial state and will be provided by using currently known variables to predict future cash flows, asset values and withdrawal plans. URS Advisory will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Clients that engage financial planning services can expect the following: • A four-month relationship. - 1 -  • Including two Zoom or in-person meetings, a strategy session, a final review meeting, and unlimited phone calls and emails during the four-month period. URS Advisory offers two tiers of financial planning, services include but are not limited to: Tier One – Basic Plan • Comprehensive financial plan Tier Two – Premium Plan All services provided in Tier One, plus: • Monte Carlo-based financial stress testing • Roth Conversion Planning with breakeven analysis • Modern Guardrail-based financial stress testing • Distribution Planning- efficiently utilize accounts • Portfolio composition report • Required Minimum Distribution including annual range midpoint, risk-adjusted return, and analytics • Safe withdrawal rates per year by (RMD) analysis from a tax perspective and account coordination percent and dollar amount based on your budget/needs • Upper and lower portfolio return • Complex cases involving business sales, real estate sales, divorce, inheritance, and estate plan review guardrails • Special needs planning, if applicable • Sequence of returns stress testing, modeling lower returns, high inflation, or other scenarios • Asset allocation recommendation • Pension breakeven analysis • Social Security planning • Insurance review and recommendations If a conflict of interest exists between the interests of URS Advisory and the interests of the Client, the Client is under no obligation to act upon URS Advisory’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to process the transaction through URS Advisory or its affiliates. Initial financial plans will be completed and delivered within 60 days, which is contingent upon the timely delivery of all required documentation. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs URS Advisory does not sponsor any wrap fee programs. - 2 -  Client Assets under Management URS has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $175,814,813 $0 April 30, 2026 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT URS Advisory offers direct discretionary asset management services to advisory Clients. URS Advisory charges an annual investment advisory fee based on the total assets under management as follows: Assets Under Management Up to $1,000,000 $1,000,000.01 to $3,000,000 $3,000,000.01 to $10,000,000 $10,000,000.01 to $20,000,000 $20,000,001 to $50,000,000 Over $50,000,000 Annual Fee 0.95% 0.80% 0.70% 0.50% 0.40% 0.30% Quarterly Fee .2375% .2% .175% .125% 0.10% 0.075% This is a blended fee schedule, the asset management fee is calculated by applying different rates to different portions of the portfolio. URS may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. Total fees to Client will never exceed the 2% of assets under management per year. For example (based on quarterly billing period): Client with $2,500,000 under management would pay $5,000.00 on an quarterly basis. Quarterly fee x 0.2375% = x 0.2% = AUM First $1,000,000 Next $1,500,000 Grand total for the quarter Total $2,375.00 $3,000.00 $5,375.00 The annual fee is negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are billed quarterly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous quarter. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial 5 business days, the agreement may be terminated by URS with thirty (30) days written notice to Client and by the Client at any time with written notice to URS. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to URS. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. It is unlawful to enter into, extend, or renew any investment advisory contract unless it provides in writing, no assignment of the contract - 3 -  may be made by adviser without the consent of the other party to the contract. Hold harmless or hedge clauses which purport to require clients to waive potential claims or rights they are entitled to or that mislead clients about their rights are prohibited. Lower fees for comparable services may be available from other sources. Total fees to Client will never exceed the safe harbor threshold of 2% of assets under management per year. URS Advisory may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios by executing a Sub-Advisor agreement with other registered investment advisor firms. When using Sub-Advisors, the Client will not pay additional fees, except for accounts utilizing the Wasmer Schroeder platform which will be charged an additional 12 basis points. Sub-Advisor directly deducts their portion of the fee separately from URS Advisory. FINANCIAL PLANNING AND CONSULTING URS Advisory charges a fixed fee for financial planning. Prior to the planning process the Client will be provided an estimated plan fee, clients may choose the following options: Tier One – Basic Plan • $8,000 Tier Two – Premium Plan • $10,000 Due upon signing the agreement. The client chooses not to have asset management services provided by URS Advisory. Due upon signing the agreement. The client chooses not to have asset management services provided by URS Advisory. • $3,000 • $4,000 Due upon signing the agreement. The client commits to investing at least $2,000,000 with URS Advisory within 60 days. Due upon signing the agreement. The client commits to investing at least $2,000,000 with URS Advisory within 60 days. Financial planning services are typically completed and delivered within sixty (60) calendar days. The client may cancel within seven (7) business days of signing the URS Retirement Roadmap Financial Planning Agreement without incurring any obligation or penalty. If the client terminates the planning agreement after seven (7) business days, URS Advisory will refund fees based on the following schedule: Financial Planning Step Completed* Fee Refund Percentage Step 1: Data Gathering & Questionnaires 75% Step 2: Onboarding Stage & Money Match Setup 50% Step 3: Once we begin the Analysis Phase 25% Step 4: Upon the start of the Strategy Session meeting 0% *If client cancels prior to Step 1 being completed, the client will receive a full refund. Investment advisory contracts cannot be entered into, extended, or renewed unless they include a written provision stating that the adviser cannot assign the contract without the other party’s consent. Clauses that require clients to waive certain rights or claims, or that mislead clients about their rights, are not allowed. URS Advisory reserves the right to waive - 4 -  all or a portion of the fee should the Client implement the plan through URS Advisory. Lower fees for comparable services may be available from other sources. Client Payment of Fees Fees for asset management services are: • Deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. Fees for financial plans will be billed: • Check – to be remitted by Client to URS Advisory • Electronic Payment via ACH, Debit Card, or Credit Card (fees will be paid via a third- party payment processor in which the client will securely input payment information and pay the advisory fee through a secure portal. URS Advisory will not have continuous access to the Client’s banking information.) Additional Client Fees Charged Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-traded funds. These charges may include Mutual Fund transactions fees, postage and handling and miscellaneous fees. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Client Fees URS Advisory does not require any prepayment of fees of more than $1200 per Client and six months or more in advance. Fees for financial plans are billed and paid upfront in full before the planning meetings. URS Advisory reserves the right to discount or waive financial planning fees when applicable. If the Client cancels after (7) seven business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to URS Advisory. External Compensation for the Sale of Securities to Clients URS Advisory does not receive any external compensation for the sale of securities to clients, nor do any of the investment advisor representatives of URS Advisory. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. URS Advisory does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for URS Advisory to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description URS Advisory generally provides investment advice to individuals and high net worth individuals. Client relationships vary in scope and length of service. - 5 -  Account Minimums URS Advisory requires a minimum of $2,000,000 to open and maintain an account. In certain instances, the minimum account size may be lowered or waived. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include Asset Allocation analysis, fundamental analysis, technical analysis, charting, and cyclical analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Asset Allocation is a broad strategy that mixes non-correlating assets together to find a balance of risk and return based on client’s investment profile and investment objectives. Asset allocation intends to maximize returns and minimize portfolio risk. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. The main sources of information include financial newspapers and magazines, annual reports, prospectuses, and filings with the Securities and Exchange Commission. In developing a financial plan for a Client, URS Advisory’s analysis may include cash flow analysis, investment planning, risk management, tax planning and estate planning. Based on the information gathered, a detailed strategy is tailored to the Client’s specific situation. The main sources of information used may include financial newspapers and magazines, research materials prepared by others, corporate rating services, annual reports, prospectuses, and filings with the Securities and Exchange Commission. Investment Strategy The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time. Each Client - 6 -  executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Security Specific Material Risks All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investing in securities involves risk of loss that clients should be prepared to bear. • Market Risk: The prices of securities held by mutual funds in which Clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Management Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. • Equity Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the Client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • Fixed Income Risk: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating - 7 -  agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. • Investment Companies Risk: When a Client invests in open end mutual funds or ETFs, the Client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, which may be duplicative. In addition, the Client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de- listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which Client invests. • REIT Risk: To the extent that a Client invests in REITs, it is subject to risks generally associated with investing in real estate, such as (i) possible declines in the value of real estate, (ii) adverse general and local economic conditions, (iii) possible lack of availability of mortgage funds, (iv) changes in interest rates, and (v) environmental problems. In addition, REITs are subject to certain other risks related specifically to their structure and focus such as: dependency upon management skills; limited diversification; the risks of locating and managing financing for projects; heavy cash flow dependency; possible default by borrowers; the costs and potential losses of self-liquidation of one or more holdings; the possibility of failing to maintain exemptions from securities registration; and, in many cases, relatively small market capitalization, which may result in less market liquidity and greater price volatility. • Foreign Securities Risk: Funds in which Clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Long-term purchases: Long-term investments are those vehicles purchased with the intension of being held for more than one year. Typically, the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. - 8 -  • Short-term purchases: Short-term investments are typically held for one year or less. Generally, there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. • Trading risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. • Leveraged Risk: The risks involved with using leverage may include compounding of returns (this works both ways – positive and negative), possible reset periods, volatility, use of derivatives, active trading and high expenses. • Equity Linked CD Risk: Penalties may apply to early withdrawals. Fair market value of CD’s when sold in the secondary market may be worth more or less than face value. May or may not be FDIC insured. Returns are not based solely on market returns, as there may be a maximum rate of interest the CD will earn. May be taxed on income earned, but interest isn’t accrued (received) until the CD matures. Many CDs may have “call” features, allowing the bank to close the contract early with no penalty, paying back principle and any accrued interest. The risks associated with utilizing Sub-Advisors include: • Manager Risk o Sub-Advisor fails to execute the stated investment strategy • Business Risk o Sub-Advisor has financial or regulatory problems The specific risks associated with the portfolios of the Sub-Advisor’s which is disclosed in the Sub-Advisor’s Form ADV Part 2. The specific risks associated with financial planning include: • Risk of Loss o Client fails to follow the recommendations of URS Advisory resulting in loss o Client has changes in financial status or lifestyle and therefore plan recommendations are no longer valid Item 9: Disciplinary Information Criminal or Civil Actions URS Advisory and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings URS Advisory and its management have not been involved in administrative enforcement proceedings. Self- Regulatory Organization Enforcement Proceedings URS Advisory and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of URS Advisory or the integrity of its management. - 9 -  Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration No affiliated representatives of URS Advisory are registered representatives of a broker- dealer. Futures or Commodity Registration Neither URS Advisory nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Managing Members Erik Lembcke and Julia Lembcke are also licensed insurance agents with an affiliated firm, JEL Enterprises, Inc. dba URS Insurance. Approximately 50% of both Erik Lembcke and Julia Lembcke’s time is spent in this practice. From time to time, they will offer Clients services from those activities. These practices represent a conflict of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent or payroll company of their choosing. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest URS Advisory may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and URS Advisory. Sub-Advisors execute all trades on behalf of URS Advisory in Client accounts. URS Advisory will be responsible for the overall direct relationship with the Client. URS Advisory retains the authority to terminate the Sub- Advisor relationship at URS Advisory’s discretion. In addition to the authority granted to URS Advisory, Clients will grant URS Advisory full discretionary authority and authorizes URS Advisory to select and appoint one or more independent investment advisors (“Advisors”) to provide investment advisory services to Client without prior consultation with or the prior consent of Client. Such Advisors shall have all of the same authority relating to the management of Client’s investment accounts as is granted to URS Advisory in the Agreement. In addition, at URS Advisory’s discretion, URS Advisory may grant such Advisors full authority to further delegate such discretionary investment authority to additional Advisors. URS Advisory ensures that before selecting other advisors for Client that the other advisors are properly licensed or registered as an investment advisor. This practice represents a conflict of interest as URS Advisory may select Sub-Advisors who charge a lower fee for their services than other Sub-Advisors. This conflict is mitigated by disclosures, procedures, and by the fact that URS Advisory has a fiduciary duty to place the best interest of the Client first and will adhere to their code of ethics. - 10 -  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of URS Advisory have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of URS Advisory affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of URS Advisory. The Code reflects URS Advisory and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. URS Advisory’s policy prohibits any person from acting upon or otherwise misusing non- public or inside information. No advisory representative or other employee, officer or director of URS Advisory may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. URS Advisory’s Code is based on the guiding principle that the interests of the Client are our top priority. URS Advisory’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. URS Advisory will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest URS Advisory and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest URS Advisory and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide URS Advisory with copies of their brokerage statements. The Chief Compliance Officer of URS Advisory is Erik Lembcke. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal - 11 -  trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest URS Advisory does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide URS Advisory with copies of their brokerage statements. The Chief Compliance Officer of URS Advisory is Erik Lembcke. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions URS Advisory will require the use of a particular broker-dealer based on their duty to seek best execution for the client, meaning they have an obligation to obtain the most favorable terms for a client under the circumstances. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. URS Advisory will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. URS Advisory relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by URS Advisory. URS Advisory does not receive any portion of the trading fees. URS Advisory will require the use of Charles Schwab & Co, Inc. • Directed Brokerage URS Advisory does not allow directed brokerage accounts. • Best Execution Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is effected, the ability to affect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The firm does not receive any portion of the trading fees. • Soft Dollar Arrangements - 12 -  The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by URS Advisory from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of 1934, URS Advisory receives economic benefits as a result of commissions generated from securities transactions by the broker-dealer from the accounts of URS Advisory. These benefits include both proprietary research from the broker and other research written by third parties. A conflict of interest exists when URS Advisory receives soft dollars. This conflict is mitigated by the fact that URS Advisory has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. URS Advisory utilizes the services of custodial broker dealers. Economic benefits are received by URS Advisory which would not be received if URS Advisory did not give investment advice to Clients. These benefits include: A dedicated trading desk, a dedicated service group and an account services manager dedicated to URS Advisory's accounts, ability to conduct "block" Client trades, electronic download of trades, balances and positions, duplicate and batched Client statements, Aggregating Securities Transactions for Client Accounts URS Advisory is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of URS Advisory. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro- rated basis. If aggregation if not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-late trades, etc.) an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Accounts are reviewed on a quarterly basis by Erik Lembcke, Chief Compliance Officer. Account reviews are performed more frequently when market conditions dictate. Financial Plans are considered complete when recommendations are delivered to the Client and a review is done only upon request of Client. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Content of Client Provided Reports and Frequency Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by the third party money manager’s custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs. - 13 -  Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest URS Advisory receives additional economic benefits from external sources as described above in Item 12. Advisory Firm Payments for Client Referrals URS Advisory does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by URS Advisory. URS Advisory is deemed to have custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of URS Advisory. Item 16: Investment Discretion Discretionary Authority for Trading URS Advisory requires discretionary authority to manage securities accounts on behalf of Clients. URS Advisory has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. URS Advisory allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to URS Advisory in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. URS Advisory does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes URS Advisory does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, URS Advisory will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because URS Advisory does not serve as a custodian for Client funds or securities and URS Advisory does not require prepayment of fees of more than $1200 per Client and six months or more in advance. - 14 -  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients URS Advisory has no condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. Bankruptcy Petitions during the Past Ten Years Neither URS Advisory nor its management has had any bankruptcy petitions in the last ten years. - 15 -  Item 1 Cover Page S U P E R V I S E D P E R S O N B R O C H U R E F O R M A D V P A R T 2 B Erik Lembcke, CFP® Main Office Address: 4425 N Military Trail, Suite 208 Jupiter, FL 33458 Tel: 561-594-0100 Fax: 561-584-6892 Website: www.URSAdvisory.com Email: Compliance@URSAdvisory.com May 4, 2026 This brochure supplement provides information about Erik Lembcke and supplements the URS Advisory LLC dba URS Advisory’s brochure. You should have received a copy of that brochure. Please contact Erik Lembcke if you did not receive the brochure or if you have any questions about the contents of this supplement. A D D I T I O N A L I N F O R M A T I O N A B O U T E R I K L E M B C K E ( C R D # 5 9 5 3 8 9 4 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V . - 16 -  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer – Erik Lembcke • Year of birth: 1983 Item 2 - Educational Background and Business Experience Educational Background: • University of Miami; Masters of Business Administration - Business; 2013 • University of Central Florida; Bachelors of Science – Finance; 2006 Business Experience: • URS Advisory LLC dba URS Advisory; Investment Advisor Representative; 01/2018 - Present • URS Advisory LLC dba URS Advisory; President; 08/2017 – Present • JEL Enterprises, Inc. dba URS Insurance; Insurance Agent/Owner; 10/2016 - Present • Gradient Securities, LLC; Registered Representative/Investment Advisor Representative; 11/2016 -12/2017 • First Republic Securities Company, LLC; Registered Representative; 12/2013 – 09/2016 • First Republic Investment Management, Inc.; Investment Advisor Representative; 01/2014 – 09/2016 • Deutsche Bank Securities Inc.; Registered Representative/Investment Advisor Representative; 08/2011 – 08/2013 • SunTrust; Financial Services Representative; 03/2008 – 06/2011 • Island Capital Advisors; Vice President; 11/2005 – 03/2008 Professional Certifications Employees have earned certifications and credentials that are required to be explained in further detail. The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or - 17 -  university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. Item 3 - Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. Item 4 - Other Business Activities Engaged In Erik Lembcke has a financial affiliated business as an insurance agent with JEL Enterprises, Inc. dba URS Insurance. Approximately 50% of his time is spent on these activities. From time to time, he will offer Clients services from those activities. As an insurance agent, he may receive separate yet typical compensation. These practices represent a conflict of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. See Item 10 for more details. Item 5 - Additional Compensation Erik Lembcke receives commissions on the insurance he sells. He does not receive any performance-based fees. He does not receive any additional compensation for performing advisory services other than what is disclosed in Item 5 of Part 2A. - 18 -  Item 6 - Supervision Since Erik Lembcke is the Chief Compliance Officer of URS Advisory. He is solely responsible for all supervision and formulation and monitoring of investment advice offered to Clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manual. He can be reached at Compliance@URSAdvisory.comor 561-594-0100. - 19 -  Item 1 Cover Page S U P E R V I S E D P E R S O N B R O C H U R E F O R M A D V P A R T 2 B Julia Lembcke, CFP®, ChFC®, CLU®, CLTC, ChSNC® Main Office Address: 4425 N Military Trail, Suite 208 Jupiter, FL 33458 Tel: 561-594-0100 Fax: 561-584-6892 Website: www.URSAdvisory.com Email: Compliance@URSAdvisory.com May 4, 2026 This brochure supplement provides information about Julia Lembcke and supplements the URS Advisory LLC dba URS Advisory’s brochure. You should have received a copy of that brochure. Please contact Julia Lembcke if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Julia Lembcke (CRD #6430148) is available on the SEC’s website at www.adviserinfo.sec.gov. - 20 -  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer – Julia Lembcke • Year of birth: 1987 Item 2 - Educational Background and Business Experience Educational Background: • University of Florida; Bachelors of Science – Business; 2009 Business Experience: • URS Advisory LLC dba URS Advisory; Investment Advisor Representative; 01/2018 - Present • URS Advisory LLC dba URS Advisory; Managing Director; 08/2017 – Present • JEL Enterprises, Inc. dba URS Insurance; Owner/Insurance Agent; 04/2010 – Present • Gradient Securities; Investment Advisor Representative; 11/2016 – 12/2017 • Gradient Advisors, LLC; Investment Advisor Representative; 02/2015 – 11/2016 • Banker’s Life and Casualty; Insurance Agent; 07/2009 – 05/2010 • University of Florida; Full Time Student; 09/2005 – 06/2009 Professional Certifications Employees have earned certifications and credentials that are required to be explained in further detail. The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial - 21 -  planning issues and apply one’s knowledge of financial planning to real world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. Chartered Financial Consultant® (ChFC®): Chartered Financial Consultant (ChFC®) is a designation issued by the American College. ChFC® designation requirements: • Complete ChFC® coursework within five years from the date of initial enrollment. • Pass the exams for all required elective courses. A minimum score of 70% must be achieved to pass. • Meet the experience requirements: Three years of full-time business experience within the five years preceding the date of the award. An undergraduate or graduate degree from an accredited educational institution qualifies as one year of business experience. • Take the Professional Ethics Pledge. • When you achieve your CHFC® designation, you must earn 30 hours of continuing education credit every two years. Chartered Life Underwriter (CLU®): Chartered Life Underwriter is a designation granted by the American College. CLU® designation requirements: • Successfully complete CLU® coursework: five required and three elective courses. • Meet the experience requirements: Three years of business experience immediately preceding the date of the use of the designation are required. An undergraduate or graduate degree from an accredited education institution qualifies as one year of business experience. • Take the Professional Ethics Pledge. • When you achieve the CLU® designation, you must complete 30 hours of continuing education credit every two years. Certified in Long-Term Care (CLTC) is a designation that focuses on the discipline of extended care planning. It provides professionals the critical tools necessary to discuss the subject of longevity and its consequences on their Client’s family and finances. To earn the designation, the following must be completed: - 22 -  • Complete course outline including: - Extended Care: Family vs. Statistics - Extended Care Services - What Pays for Extended Care - Long-Term Care Insurance - Proper Implementation of Long-Term Care - The Ethical Promotion of Long-Term Care Insurance • Pass the certification examination of 100 multiple-choice questions accessible on- line. • To maintain the CLTC designation, all designees are required to complete the CLTC renewal course biennially and making an annual renewal payment to support the continuing education. The Chartered Special Needs Consultant® or (ChSNC®): designation is awarded by the American College of Financial Services, candidates must: • Successful completion of the courses numbered HS 375, HS376, and HS 377. • An application for designation approved by the Registrar of The American College of Financial Services. Ata minimum, any individual must present an application that clearly identifies: o At least five years of professional experience in financial services or the practice of law, or o Four years of professional financial services experience and an undergraduate degree. • Individuals who hold the CLU® or ChFC® designations, the CFP®, MSFS, and/or who have met the sufficient experience requirements are eligible to use the designation after completion of the ChSNC® coursework. The aforementioned experience requirements may be reduced or waived depending upon academic background and a petition to The College requesting such a waiver. • Adhere to The American College of Financial Services Code of Ethics and comply with the College’s Professional Recertification Program. Item 3 - Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. Item 4 - Other Business Activities Engaged In Julia Lembcke has a financial affiliated business as an insurance agent with JEL Enterprises, Inc. dba URS Insurance. Approximately 50% of her time is spent on these activities. From time to time, she will offer Clients services from those activities. As an insurance agent, she may receive separate yet typical compensation. These practices represent a conflict of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. See Item 10 for more details. - 23 -  Item 5 - Additional Compensation Julia Lembcke receives commissions on the insurance she sells. She does not receive any performance-based fees. She does not receive any additional compensation for performing advisory services other than what is disclosed in Item 5 of Part 2A. Item 6 - Supervision Erik Lembcke is the Chief Compliance Officer of URS Advisory. Mr. Lembcke reviews Mrs. Lembcke’s work through client account reviews and quarterly personal transaction reports, as well as fact-to face and phone interactions. Mr. Lembcke can be reached at Compliance@URSAdvisory.com or 561-594-0100. - 24 -