Valiant Wealth, LLC

Valiant Wealth, LLC Form ADV Part 2A March 24, 2026 Address: 3408 Woodland Avenue #204 West Des Moines, Iowa 50266 (515) 223-6068 Phone: Website: https://www.valiantwealth.com Email: michael@valiantwealth.com This brochure provides information about the qualifications and business practices of Valiant Wealth, LLC (“Valiant Wealth”). If you have any questions about the contents of this brochure, please contact us at the phone number or email address listed above. 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. Valiant Wealth is a registered investment adviser, but registration does not imply a certain level of skill or training Additional information about Valiant Wealth is also available on the SEC’s website at www.adviserinfo.sec.gov. Valiant Wealth’s CRD number is: 146911.  Item 2: Material Changes In this Item, Valiant Wealth is required to identify and discuss material changes since filing its last annual amendment in 2025. The following material changes have occurred since that filing: Item 4 has been amended to disclose further information about additional services and to provide our updated amount of regulatory assets under management. Item 5 has been amended to disclose information about additional services provided by our affiliates. Item 10 has been amended to disclose additional information about our affiliates. If you have questions about these changes or if you would like a copy of our brochure, please reach out to us using the contact information provided in Item 1. 2  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ........................................................................................................................... 2 Item 3: Table of Contents ........................................................................................................................... 3 Item 4: Advisory Business ........................................................................................................................... 4 Item 5: Fees and Compensation .................................................................................................................. 7 Item 6: Performance-Based Fees and Side-by-Side Management .............................................................. 10 Item 7: Types of Clients ............................................................................................................................ 10 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss........................................................ 10 Item 9: Disciplinary Information ............................................................................................................... 15 Item 10: Other Financial Industry Activities and Affiliations ...................................................................... 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................... 17 Item 12: Brokerage Practices .................................................................................................................... 18 Item 13: Review of Accounts .................................................................................................................... 19 Item 14: Client Referrals and Other Compensation ................................................................................... 20 Item 15: Custody ...................................................................................................................................... 20 Item 16: Investment Discretion ................................................................................................................. 21 Item 17: Voting Client Securities ............................................................................................................... 21 Item 18: Financial Information ................................................................................................................. 22 3  Item 4: Advisory Business A. Description of the Advisory Firm Valiant Wealth, LLC (hereinafter “Valiant Wealth,”, “we,” “us,” and “our”) is a Limited Liability Company organized in the State of Iowa. The firm was formed in 2008, and the principal owner is Douglas Dean Vander Weide. B. Types of Advisory Services Investment Supervisory Services Valiant Wealth offers ongoing portfolio management services to advisory clients through separately managed accounts based on the individual goals, objectives, time horizon, and risk tolerance of each client. Valient Wealth creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a portfolio that matches each client’s specific situation. Portfolio management services include, but are not limited to, the following: investment strategy, asset allocation, risk tolerance, personal investment policy, asset selection, and regular portfolio monitoring. Valiant Wealth evaluates the current investments of each client with respect to their risk tolerance and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Valiant Wealth provides portfolio management services on a discretionary basis, meaning that we do not need to seek and obtain permission from the accountholder before placing trades in the account. We monitor your accounts under our management on a continuous basis and rebalance the portfolios as needed. We require each of our clients to execute an investment advisory agreement to receive our services. Details regarding our services, including the authority with which we manage your accounts, along with our fees, are described in the agreement. Valiant Wealth also provides asset management services to pooled investment vehicles. The scope of such services is described in the Investment Management Agreement executed by Valiant Wealth and the pooled investment vehicle. Other clients of Valiant Wealth may invest in or be invited to invest in such pooled investment vehicles. Valiant Wealth also offers due diligence and other related services to its pooled investment vehicle clients, such due diligence consulting, bridge loan sourcing, and equity sources. These services are described in detail in each pooled investment vehicle’s offering documents. At times, such services may be performed by an affiliated entity. Financial Planning Financial planning may include, but is not limited to: investment planning, insurance planning, tax concerns, retirement planning, education planning, and debt/credit planning. The fees associated with these services are variable depending upon the 4  complexity of the services needed. Each client’s financial planning fee is documented in the client’s advisory contract. Services Limited to Specific Types of Investments Valiant Wealth offers investment advice and/or money management regarding mutual funds, equities, bonds, fixed income, debt securities, ETFs, REITs, private placements, options and government securities. Valiant Wealth may use other securities as well to help diversify a portfolio when applicable. Upon request, Valiant Wealth may offer advice on securities that clients hold outside of their accounts at Valiant Wealth. Additional Services Valiant may offer additional services to high-net-worth individuals, such as lifestyle management, personal accounting, estate plan coordination,, property management oversight, risk mitigation, insurance reviews, and family governance. Valiant Wealth may refer clients to Valiant Capital Solutions for business consultancy services and/or Valiant Tax Solutions, LLC for tax planning and preparation services. Both entities are Valiant Wealth affiliates – please see Item 10 for additional information and disclosures about these entities. Written Acknowledgement of Fiduciary Status When Valiant Wealth provides investment advice to clients regarding their retirement plan accounts or individual retirement accounts, Valiant Wealth acts 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. The manner in which Valiant Wealth earns fees can create conflicts with clients’ interests, so Valiant Wealth operates under a special rule that requires Valiant Wealth to act in clients’ best interest and not put Valiant Wealth’s interest ahead of clients’. Under this special rule’s provisions, Valiant Wealth must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put its financial interests ahead of clients when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that Valiant Wealth gives advice that is in clients’ best interest; • Charge no more than is reasonable for its services; and • Give clients basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions As noted above, Valiant Wealth may tailor its service offerings to meet the needs of its clients. The services to be provided to each client are described in each client’s advisory agreement. Financial plans and their implementation are specific to each client and dependent upon the client’s investment profile (income, tax levels, and risk tolerance). Clients may impose investment restrictions in certain securities or types of securities in 5  accordance with their values or beliefs. However, if the restrictions prevent Valiant Wealth from properly servicing the client account, or if the restrictions would require Valiant Wealth to deviate from its standard suite of services, Valiant Wealth reserves the right to end the relationship. D. Wrap Fee Programs Valiant Wealth does not participate in any wrap fee programs. E. Assets under Management Valiant Wealth manages the following amount of client assets calculated as of December 31, 2025: Discretionary: Non-Discretionary: Total: $423,078,536 $0 $423,078,536 6  Item 5: Fees and Compensation A. Fee Schedule and Payment Portfolio Management Valiant Wealth’s compensation for the provision of portfolio management services for separately managed accounts is as follows: Assets under Management First $1,000,000 Next $1,000,000 Next $3,000,000 Above $5,000,000 Annual Fees 1.50% 1.20% 0.9% Negotiable Advisory fees are based upon a percentage of assets under management and are negotiable. Clients should refer to the fee schedule in their advisory agreements for fee information. Advisory fees are paid quarterly in arrears and are based upon the total market value of assets in the client’s account(s) as of the last business day of the quarter. Clients may terminate their contracts with thirty (30) days’ written notice. If a client terminates prior to the end of a quarter, Valiant Wealth is entitled to a pro rata fee for the days of service provided during the final quarter. The client will be sent an invoice detailing the charges, and payment will be required within thirty (30) days. Because our advisory fees are charged in arrears, no refund policy is necessary. Clients may terminate their accounts without penalty within five (5) business days of signing the advisory contract. Advisory fees are withdrawn directly from the client’s account(s) with client written authorization. In cases where advisory fees are directly deducted, Valiant Wealth is required to: a) obtain client authorization, b) send a copy of the invoice to the client at the same time that the Valiant Wealth directs invoice to the custodian for payment, and c) disclose that Valiant Wealth will send quarterly invoices to the client wherein advisory fees are itemized. We treat cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of assets under management for purposes of calculating our 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), we may maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts could miss market advances and, depending upon current yields, at any point in time, our advisory fee could exceed the interest paid by the client’s cash or cash equivalent positions. Unless otherwise agreed in writing, the gross amount of assets in the client’s account, including margin balances, are included as part of assets under management for 7  purposes of calculating the firm’s advisory fee. Clients should note that this practice will increase total assets under management used to calculate advisory fees which will in turn increase the amount of fees collected by our firm. This practice creates a conflict of interest in that our firm has an incentive to use margin in order to increase the amount of billable assets. At all times, the firm and its Associated Persons strive to uphold their fiduciary duty of fair dealing with clients. Clients are free to restrict the use of margin by our firm. However, clients should note that any restriction on the use of margin may negatively impact an account’s performance in a rising market. Valiant Wealth has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Valiant Wealth will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when Valiant Wealth determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless otherwise agreed in writing, Valiant Wealth’s management fee will continue to apply during these periods, and there can be no assurance that investment decisions made by Valiant Wealth will be profitable or equal any specific performance level(s). Pooled investment vehicle clients are charged either a flat management fee or a management fee based upon the amount of assets under management. This management fee is described in the vehicle’s offering documents, including the frequency of collection. A performance-based fee may also be charged, which is payable upon distribution of the investment, and may be subject to a high-water mark per the offering documents. Depending on the pooled investment vehicle, some performance-based fees are owed to an affiliate of Valiant Wealth, as described in the offering documents. Payment for other services provided to pooled investment vehicles is payable at the time indicated in the offering documents. Financial Planning Depending upon the complexity of the situation and the needs of the client, the rate for financial planning is usually between $1,000 and $15,000. Fees are paid in advance, but never more than three months in advance. Fees that are charged in advance can be refunded based on the prorated amount of work completed at the point of termination. The fees are negotiable, and the final fee schedule will included in the advisory contract. Clients may terminate their contracts without penalty within five (5) business days of signing the advisory contract. After such time, clients may terminate their account with thirty (30) days’ written notice. Upon client authorization, financial planning fees will be directly deducted from the client’s account. Alternatively, clients may pay via check or wire. Additional Services Fees for additional services are negotiated directly with the client and memorialized in 8  their advisory contract and/or its exhibits. Such fees are variable, depending upon the complexity of the services needed, and are usually comprised of flat fees. These fees are due quarterly in advance. Clients may cancel these additional services at any time upon thirty (30) days written notice. Fees that are charged in advance can be refunded based on the prorated amount of days left in the quarter. Upon client authorization, fees for additional services are deducted directly from the client’s account. If you engage one of our affiliates for business consultancy or tax preparation and planning, you will pay additional fees for these services directly to our affiliate(s) under a separate non-advisory engagement agreement. Please see Item 10 for more information. B. Client Responsibility for Third Party Fees In addition to the fees charged by Valiant Wealth, clients will incur brokerage and other transaction costs. Please refer to Item 12: Brokerage Practices, for further information on such brokerage and other transaction-related practices. Clients will also typically incur additional fees and expenses imposed by independent and unaffiliated third-parties, which can include qualified custodian fees, mutual fund or exchange traded fund fees and expenses, mark-ups and mark-downs, spreads paid to market makers, wire transfer fees, check-writing fees, early-redemption charges, certain deferred sales charges on previously-purchased mutual funds, margin fees, charges or interest, IRA and qualified retirement plan fees, and other fees and taxes on brokerage accounts and securities transactions. These additional charges are separate and apart from the fees charged by Valiant Wealth. C. Prepayment of Fees Valiant Wealth only collects financial planning fees in advance. Fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. Fees will be returned within fourteen days to the client via check or it will be deposited back into client’s account. D. Outside Compensation for the Sale of Securities to Clients Neither Valiant Wealth nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or services fees from the sale of mutual funds. However, Valiant Wealth receives compensation from the services it provides to the pooled investment vehicles it manages, including management fees, performance-based fees, and diligence fees amongst others, as described in the offering documents. 9  Item 6: Performance-Based Fees and Side-by-Side Management Performance-based fees are fees based on a share of capital gains or capital appreciation of a client’s account. We, or one of our affiliated entities, charge performance-based fees to certain pooled investment vehicles that we manage. Through our investment advisory services, we manage accounts that are charged a performance-based fee and accounts that are not. This creates a conflict of interest, as it creates an incentive for Valiant Wealth and our staff to favor accounts for which we receive performance-based fees. However, the CCO reviews accounts periodically to ensure that all accounts are managed in accordance with their investment objectives and in the client’s best interest. Performance-based fees may also create an incentive for our firm to overvalue investments, which lack a market quotation. In order to address such conflict, we have adopted policies and procedures that require our firm to “fairly value” any investments which do not have a readily ascertainable value. Additionally, performance-based fees are only charged at the time the investment is liquidated, when the value is readily ascertainable. Item 7: Types of Clients Valiant Wealth generally provides advisory services to the following types of clients: Individuals • • High Net Worth Individuals • Pension Plans • Pooled Investment Vehicles • Charitable Organizations Valiant Wealth generally requires an account minimum of $100,000 for separately managed account clients, which may be waived at Valiant Wealth’s discretion. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis Valiant Wealth’s primary method of analysis includes the use of proprietary data and tools of Dimensional Fund Advisors. 10  Investing in securities involves risk of loss. Clients should be able to bear the loss of their entire investment. B. Investment Strategies Valiant Wealth employs a “buy and hold” approach to asset management. The practice of this style of asset management is based on the belief that no one can time the market. Valiant Wealth adheres to the following principles: • Markets are efficient and assets are fairly priced. • Diversification reduces the risk of uncertainty. Asset allocation and expenses determine results in the portfolio. Valiant Wealth utilizes a range of model portfolios for management of separately managed accounts. Each model portfolio is designed to offer an optimized asset allocation based on varying levels of risk. In setting their investment objectives, Valiant Wealth recommends clients consider their risk profile. Investing in securities involves a risk of loss of principal. C. Risks of Specific Securities Utilized Valiant Wealth generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. Mutual Funds: Investing in mutual funds carries the risk of capital loss. Mutual funds are not guaranteed or insured by the FDIC or any other government agency. You can lose money investing in mutual funds. All mutual funds have costs that lower investment returns. They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned above). Equity: Investing in equities generally refers to buying shares of a company in return for receiving a future payment of dividends and capital gains. There is an innate risk involved when purchasing a stock that it may decrease in value, and there is a risk of capital loss. Fixed income investments generally pay a contractual return on principal on a fixed schedule, though the amount of the payments can vary. Fixed income investments can include corporate and government debt securities, leveraged loans, high yield debt, investment grade debt, and structured products, such as mortgage and other asset- backed securities. In general, the fixed income market can be volatile, as fixed income instruments carry interest rate risk (as interest rates rise, bond prices usually fall, and vice versa, which effect is usually more pronounced for longer duration instruments.) Fixed income instruments also carry inflation risk, liquidity risk, call risk and credit and default risks for both issuers and counterparties. Risks of investing in foreign fixed income instruments also include the general risk of non-U.S. investing described below. Debt: Investing in debt instruments carries risks such as the possibility of default on the principal, fluctuation in interest rates, and counterparties being unable to meet 11  obligations. Exchange-Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges. Investing in ETFs carries the risk of capital loss. Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value, or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value. The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Real Estate Funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Private Placements: Investing in private placements, such as unregistered pooled investment vehicles, carries a substantial risk, as they are largely unregulated offerings. Private placement offering documents contain important information that investors should review carefully and consider when conducting due diligence into the investment opportunity. The primary risks of unregistered pooled investment vehicles include the following: (a) the illiquidity of interests, as there is no public market (an investor may not be able to exit the vehicle when desired); (b) valuation risks, especially if the underlying 12  investment is difficult to value; (c) risks inherent to the underlying investment (for example, if the vehicle invests in real estate, the risks inherent to real estate investments would largely apply). Investing in private placements is risky and involves the risk of complete capital loss. Option Risk: The risk with option buying includes the risk of losing your entire investment in a relatively short period time and losing your entire investment as the option goes out of the money and as expiration nears. The risk with option selling is that options sold may be exercised at any time before expiration and forgoing the right to profit when the underlying stock rises above the strike price of the call option sold. With uncovered options, loss can be unlimited. Environmental, Social, and Governance Investment Criteria Risk: If a portfolio is subject to certain environmental, social and governance (ESG) investment criteria it may avoid purchasing certain securities for ESG reasons when it is otherwise economically advantageous to purchase those securities, or may sell certain securities for ESG reasons when it is otherwise economically advantageous to hold those securities. In general, the application of the portfolio’s ESG investment criteria may affect the portfolio’s exposure to certain issuers, industries, sectors and geographic areas, which may affect the financial performance of the portfolio, positively or negatively, depending on whether these issuers, industries, sectors or geographic areas are in or out of favor. An adviser can vary materially from other advisers with respect to its methodology for constructing ESG portfolios or screens, including with respect to the factors and data that it collects and evaluates as part of its process. As a result, an adviser’s ESG portfolio or screen may materially differ from or contradict the conclusions reached by other ESG advisers concerning the same issuers. Further, ESG criteria are dependent on data and are subject to the risk that such data reported by issuers or received from third-party sources may be subjective, or it may be objective in principle but not verified or reliable. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. D. Risks of Trading Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various other types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short-term trading risks include liquidity, economic stability, and inflation. Short sales risks include the upward trend of the market and the infinite possibility of loss. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. 13  Options writing involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss of principal. Interest Rate Risk is the risk that an investment's value will change due to a change in the absolute level of interest rates, spread between two rates, shape of the yield curve, or in any other interest rate relationship. These changes can be reduced by diversifying or hedging, since the changes usually affect securities inversely. Economic Risk is the chance that macroeconomic conditions like exchange rates, government regulation, or political stability will affect an investment. Tariff Risk is the risk presented by tariffs and trade wars. The scope, implementation, and duration of tariffs remain uncertain domestically and globally. Industries that rely on imported raw material or that have heavily integrated cross-border manufacturing practices may be most impacted by the imposition of tariffs. However, it is challenging to predict the impact of actual and/or threatened tariffs and impossible to predict future policy decisions. When tariffs are imposed, there is also a higher probability that retaliatory tariffs could be imposed, which could further impact industries and products. Tariffs in general can also permanently alter global supply chains and have far-reaching indirect impacts. Tariffs can hurt economic growth and add to inflation, which can also lead to pressure on interest rates. Political Risk, also known as geopolitical risk, is the risk that an investment's returns could suffer as a result of political changes or instability in a country. Instability affecting investment returns could stem from a change in government, legislative bodies, other foreign policy makers or military control. Regulatory Risk is the risk that a change in laws and/or regulations will materially impact a security, business, sector or market. These changes can increase the costs of operating a business, reduce the attractiveness of an investment, or change the competitive landscape, and are made by either the government or a regulatory body. Liquidity Risk stems from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. It is typically reflected in unusually wide bid-ask spreads or large price movements. Typically, the smaller the size of the security or its issuer, the larger the liquidity risk. Credit Risk traditionally refers to the risk that a lender may not receive the owed principal and interest, which results in an interruption of cash flows and increased costs for collection. Credit risk is the probable risk of loss resulting from a borrower's failure to repay a loan or meet contractual obligations. While impossible to know exactly who will default on obligations, with proper assessment and credit risk management, the severity of loss can be lessened. A lender's or investor's reward for assuming credit risk include the interest payments from the borrower or issuer of a debt obligation. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 14  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-Regulatory Organization (SRO) Proceedings There are no SRO proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker-Dealer or Broker-Dealer Representative Neither Valiant Wealth nor its representatives are registered as, or having pending applications to become, a broker-dealer or a representative of a broker-dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither Valiant Wealth nor its representatives are registered as an FCM, CPO, or CTA. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interest Valiant Wealth is the investment manager to multiple unregistered pooled investment vehicles that are offered and sold to “accredited investors” (as that term is defined in Rule 501(a) of the Securities Act of 1933) and “qualified clients” (as that term is defined in Rule 205-3 of the Investment Advisers Act of 1940). Valiant Wealth may recommend that clients invest in one or more of these pooled investment vehicles. This presents a conflict of interest, as Valiant Wealth has a financial incentive to increase participation in its pooled investment vehicles due to the fees collected from these vehicles. Valiant Wealth addresses this conflict of interest by fully disclosing it in this brochure and by only recommending that clients invest in a vehicle if such recommendation is believed to be in such clients’ best interest. Investors in the pooled investment vehicles managed by Valiant Wealth should refer to the vehicle’s offering documents for further information about the vehicle and its management, including compensation to be paid to Valiant Wealth, its financial objectives, risks, and conflicts of interest associated with the investment. It should be noted that the values of clients’ assets invested in these vehicles are not included in the calculation of those clients’ advisory fees. 15  Valiant Wealth has agreements with several of these vehicles to provide certain services for compensation, such as due diligence consulting, bridge loan sourcing, and equity sourcing in addition to management. These services are described in more detail in each vehicle’s offering documents. Investors and prospective investors should read the offering documents carefully. One of the pooled investment vehicles managed by Valiant Wealth is Valiant Regenexx LLC, which was formed for the purpose of investing in Regenexx, LLC (“Regenexx”), a privately held biotechnology company. Douglas Vander Weide serves on Regenexx’s Board of Directors and receives compensation through this role in the form of company shares and a nominal amount of cash. As a Director of Regenexx, Mr. Vander Weide has an incentive to recommend investments in Regenexx to boost the value of his shares in the company. Several of the pooled investment vehicles managed by Valiant Wealth were formed for the purpose of investing in Sucker Punch Gourmet, LLC (“Sucker Punch”), a pickle company. Douglas Vander Weide serves on Sucker Punch’s Board of Directors and receives compensation through this role in the form of company shares and nominal cash compensation. As a Director of Sucker Punch, Mr. Vander Weide has an incentive to recommend investments in Sucker Punch to boost the value of his shares in the company. One of the pooled investment vehicles managed by Valiant Wealth is Valiant Vexilar, LLC, which was formed for the purpose of investing in Vexilar Holdings, LLC (“Vexilar”). Michael Jiskoot serves on Vexilar’s Board of Directors and receives nominal cash compensation through this role. One of the pooled investment vehicles managed by Valiant Wealth is Valiant Rambo, LLC, which was formed for the purpose of investing in Rex Enterprises, LLC (“Rex”). Michael Jiskoot also serves on the board of Rex. Several of the pooled investment vehicles managed by Valiant Wealth were formed to invest in Bespoke Manufacturing Company, LLC (“BMC”). Douglas Vander Weide and Michael Jiskoot both serve on BMC’s Board of Directors. Valiant Holdings, LLC (“VH”) is owned by Douglas Vander Weide and a former employee. Due to VH’s legacy work with several of the pooled investment vehicles managed by Valiant Wealth, it maintains equity ownership in such vehicles and has a claim over future performance fees, as described in the term sheets of such vehicles. Valiant Investment Holdings, LLC (“VIH”) is owned by Douglas Vander Weide, Michael Jiskoot, and a former employee. Due to VIH’s work with several of the pooled investment vehicles managed by Valiant Wealth, it maintains equity ownership in such vehicles and has a claim over future performance fees, as described in the term sheets of such vehicles. Valiant Capital Solutions, LLC (“VCS”) provides business consultancy services and is 16  wholly owned by Valiant Wealth, LLC. VCS does not provide investment advice and does not serve its clients in a fiduciary capacity. The business of VCS is separate and distinct from the investment advisory business provided by Valiant Wealth. Business consultancy services are provided in accordance with a contractual engagement between VCS and its clients. While the business lines of VCS and Valiant Wealth are separate and distinct, the two entities may share clientele. Clients of Valiant Wealth are never required to engage VCS, and clients of VCS are never required to engage Valiant Wealth. Valiant Tax Solutions, LLC (“VTS”) provides tax preparation and filing services and is wholly owned by Valiant Wealth, LLC. VTS does not provide investment advice and does not serve its clients in a fiduciary capacity. The business of VTS is separate and distinct from the investment advisory business provided by Valiant Wealth. Tax preparation and filing services are provided in accordance with a contractual engagement between VTS and its clients. While the business lines of VTS and Valiant Wealth are separate and distinct, the two entities may share clientele. Clients of Valiant Wealth are never required to engage VTS, and clients of VTS are never required to engage Valiant Wealth. D. Selection of Other Advisers or Managers Valiant Wealth does not utilize or select other advisors or third-party managers. All assets are managed by Valiant Wealth management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics The employees of Valiant Wealth have committed to a Code of Ethics. The purpose of our Code of Ethics is to ensure that when employees buy or sell securities for their personal account, they do not create actual or potential conflict with our clients. We do not allow any employees 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. Valiant Wealth’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 Valiant Wealth 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. Valiant Wealth’s Code of Ethics is based on the guiding principle that the interests of the client are our top priority. Valiant Wealth’s officers, directors, advisors, and other employees have a fiduciary duty to our clients and must diligently perform that duty to maintain the complete trust and confidence of our clients. When the potential for conflict 17  arises, it is our obligation to put the client’s interests over the interests of either employees or the company. The Code of Ethics applies to “access” persons. “Access” persons are employees 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. The firm will provide a copy of the Code of Ethics to any client or prospective client upon request. B. Recommendations Involving Material Financial Interests Refer to Item 10 C and 11 C. of this brochure. C. Investing Personal Money in the Same Securities as Clients Principals of, officers of, and/or other persons associated with Valiant Wealth may invest in private placements that we also recommend to clients, including the pooled investment vehicles we manage. As such, this creates a conflict of interest, as we have a financial incentive to increase investment in these vehicles. Valiant Wealth addresses potential conflicts of interest by making full disclosure of such relationships to its Clients and adhering to written investment policies and strategies in recommending investments. Although we receive management fees and/or performance-based fees from the pooled investment vehicles we manage, investors who are clients of Valiant Wealth are not charged advisory fees on the value of their investments in those pooled investment vehicles. D. Trading Securities at/around the Same Time as Clients’ Securities From time to time, representatives of Valiant Wealth may buy or sell securities for themselves at or around the same time as clients. The Chief Compliance Officer of Valiant Wealth is Michael Jiskoot. He reviews all employee trades each quarter. The personal trading reviews help us ensure that the personal trading of employees does not affect the markets and that clients of the firm receive preferential treatment. Doug Vander Weide, Managing member, reviews Michael Jiskoot’s trades. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers The Custodian, Schwab Institutional, a division of Charles Schwab & Co., Inc., CRD # 5393, was chosen as the custodian based on their relatively low transaction fees and access to mutual funds and ETFs. Valiant Wealth does not charge a premium or commission on transactions, beyond the actual cost imposed by Schwab Institutional. 1. Research and Other Soft-Dollar Benefits 18  Valiant Wealth utilizes the services of custodial broker-dealers. Economic benefits are received by Valiant Wealth, which would not be received if Valiant Wealth 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 Valiant Wealth’s accounts, the ability to conduct "block" client trades, electronic download of trades, balances and positions, duplicate and batched client statements, and the ability to have advisory fees directly deducted from client accounts. Valiant Wealth does not currently have any soft dollar arrangements in place. 2. Brokerage for Referrals Valiant Wealth receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use to execute transactions. Clients must use Valiant Wealth will not allow clients to direct Valiant Wealth to use a specific broker- dealer the broker-dealer/custodian recommended by Valiant Wealth. By requiring clients to use a specific custodian, Valiant Wealth may be unable to achieve most favorable execution of client transactions and this may cost clients money over using a lower-cost custodian. B. Aggregation of Trades While Valiant Wealth typically does not engage in block trading on behalf of its clients, it maintains the ability to do so. In situations where Valiant Wealth determines that the purchase or sale of a particular security is appropriate for multiple accounts, Valiant Wealth may, but is not required to, aggregate the orders of multiple accounts into block trades if, in Valiant Wealth’s reasonable judgment, such aggregation is reasonably likely to result in an overall economic benefit to the affected accounts. Block trading may benefit a large group of clients by providing Valiant Wealth the ability to purchase larger blocks of trades resulting in smaller transaction costs to the client. Declining to block trade may increase the costs of trades for clients. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Valiant Wealth monitors client accounts on a continuous basis and conducts formal account reviews at least annually. Accounts are reviewed by Douglas Vander Weide, and Michael Jiskoot. B. Factors that will Trigger a Non-Periodic Review of Client Accounts Additional reviews may be offered in certain circumstances. Triggering factors that may 19  warrant additional reviews include, but are not limited to, changes in economic conditions, changes in the client’s financial situation or investment objectives, or a client’s request. C. Content and Frequency of Regular Reports Provided to Clients Each client will receive quarterly written reports detailing account performance, which will come from Valiant Wealth. Clients may be provided with financial planning deliverables. Such deliverables could include any of the following: cash flow analysis, net worth statement, retirement projections, education analysis, and/or Valiant Wealth’s proprietary wealth management system. Verbal advice may also be given which may or may not include tangible deliverables. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients Refer to Item 10 C. of this brochure. B. Compensation to Non – Advisory Personnel for Client Referrals Non-employee (outside) consultants, individuals, and/or entities, who are directly responsible for bringing a client to Valiant Wealth, may receive compensation from the firm. Such arrangements will comply with the requirements set forth in Rule 206(4)-3 of the Investment Advisers Act of 1940, including the requirement that the relationship between the solicitor and the investment adviser be disclosed to the client at the time of the solicitation or referral. Valiant may refer clients to “VCS” for non-advisory services. In addition, all applicable state laws will be observed. Under these arrangements, the client does not pay higher fees than Valiant Wealth’s normal/typical advisory fees. Item 15: Custody All assets are held at qualified custodians. On a quarterly basis, clients will receive from Valiant Wealth statements and billing invoices for their account(s). Clients will also receive account statements directly from their qualified custodian(s). Clients are urged to carefully compare and review the statements received for accuracy. Custody, as it applies to investment advisers, has been defined by regulators as having access or control over client funds and/or securities. For accounts over which we have been deemed to have custody, we have established procedures to ensure that all funds and securities are held at a qualified custodian in a separate account for each client under the client’s name. We are deemed to have custody in the four arrangements described below. In 20  accordance with Rule 206(4)-2(a)(4) under the Advisers Act, we have retained an independent certified public accountant to conduct an annual surprise examination of client funds and securities in such arrangements. One: At the request of some clients, Valiant Wealth has obtained login information for client financial accounts. In doing so, we are deemed to have custody over client funds and securities. Two: Associated Persons of Valiant Wealth serve as trustees to certain accounts for which we provide investment advisory services. Our capacity as trustees gives us custody over these client relationships. These accounts will be held with a bank, broker- dealer, or other independent, qualified custodian. If any Associated Person acts as trustee for any of your advisory accounts, you will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. You should carefully review account statements for accuracy. Three: We are deemed to have custody of client funds and securities because of the fee deduction authority granted by the client in the investment advisory agreement and in certain situations where we accept standing letters of authorization from clients to transfer assets to third parties. We maintain safeguards in accordance with regulatory requirements regarding custody of client assets. Four: We are also deemed to have custody of the assets of the pooled investment vehicles that we manage, as mentioned in Item 10. Such assets are held by an independent qualified custodian. The subscription documents for those private placement offerings are also held by an independent, qualified custodian. Item 16: Investment Discretion For those client accounts where Valiant Wealth provides ongoing management, the client has given Valiant Wealth written discretionary authority over the client’s accounts with respect to securities to be bought or sold and the amount of securities to be bought or sold. Details of this relationship are fully disclosed to the client before any advisory relationship has commenced. The client provides Valiant Wealth discretionary authority via the investment advisory contract. Item 17: Voting Client Securities (Proxy Voting) Valiant Wealth will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. 21  Item 18: Financial Information A. Balance Sheet Valiant Wealth does not require nor solicit prepayment of more than $500 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Valiant Wealth nor its management has any financial conditions that are likely to reasonably impair its ability to meet contractual commitments to clients. C. Bankruptcy Petitions in the Past Ten Years Valiant Wealth has not been the subject of a bankruptcy petition. 22