Overview

Assets Under Management: $1.0 billion
Headquarters: DOWNERS GROVE, IL
High-Net-Worth Clients: 284
Average Client Assets: $2.7 million

Frequently Asked Questions

VERTEX PARTNERS charges 2.00% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #316839), VERTEX PARTNERS is subject to fiduciary duty under federal law.

VERTEX PARTNERS is headquartered in DOWNERS GROVE, IL.

VERTEX PARTNERS serves 284 high-net-worth clients according to their SEC filing dated March 30, 2026. View client details ↓

According to their SEC Form ADV, VERTEX PARTNERS offers financial planning, portfolio management for individuals, portfolio management for institutional clients, pension consulting services, and selection of other advisors. View all service details ↓

VERTEX PARTNERS manages $1.0 billion in client assets according to their SEC filing dated March 30, 2026.

According to their SEC Form ADV, VERTEX PARTNERS serves high-net-worth individuals, institutional clients, and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (DISCLOSURE BROCHURE FOR VERTEX PARTNERS)

MinMaxMarginal Fee Rate
$0 and above 2.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $20,000 2.00%
$5 million $100,000 2.00%
$10 million $200,000 2.00%
$50 million $1,000,000 2.00%
$100 million $2,000,000 2.00%

Clients

Number of High-Net-Worth Clients: 284
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 76.18%
Average Client Assets: $2.7 million
Total Client Accounts: 2,580
Discretionary Accounts: 2,565
Non-Discretionary Accounts: 15
Minimum Account Size: None

Regulatory Filings

CRD Number: 316839
Filing ID: 2077928
Last Filing Date: 2026-03-30 22:30:15

Form ADV Documents

Primary Brochure: DISCLOSURE BROCHURE FOR VERTEX PARTNERS (2026-03-30)

View Document Text
Disclosure Brochure March 27, 2026 VERTEX PLANNING PARTNERS, LLC Registered Investment Adviser 3000 Woodcreek Drive, Suite 100 Downers Grove, IL 60515 (630) 836-3300 www.vertexplanningpartners.com This brochure provides information about the qualifications and business practices of Vertex Planning Partners, LLC (hereinafter “Vertex Partners” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at the telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training. Disclosure Brochure Vertex Planning Partners, LLC Item 2. Material Changes In this Item, Vertex Partners has made the following material changes to the brochure since the last annual amendment. • Vertex Partners has updated their Assets Under Management. (Item 4) • Vertex Partners has updated its Other Financial Industry Activities and Affiliations. (Item 10) • Vertex Partners has updated their advisory business in offering independent manager programs through AQR Capital Management LLC (AQR), Vestmark Advisory Solutions, Inc. (Vestmark), and Vise AI Advisors, LLC (Vise). In turn, Vertex Partners updated sections under Advisory Business (Item 4), Fees and Compensation (Item 5), and Methods of Analysis, Investment Strategies, and Risk of Loss (Item 8). Page | 2 Disclosure Brochure Vertex Planning Partners, LLC Item 3. Table of Contents Item 2. Material Changes ................................................................................................................................................................ 2 Item 3. Table of Contents ................................................................................................................................................................ 3 Item 4. Advisory Business .............................................................................................................................................................. 4 Item 5. Fees and Compensation .................................................................................................................................................... 10 Item 6. Performance-Based Fees and Side-by-Side Management ................................................................................................. 15 Item 7. Types of Clients ................................................................................................................................................................ 15 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss .......................................................................................... 15 Item 9. Disciplinary Information ................................................................................................................................................... 19 Item 10. Other Financial Industry Activities and Affiliations........................................................................................................ 19 Item 11. Code of Ethics ................................................................................................................................................................ 20 Item 12. Brokerage Practices ........................................................................................................................................................ 21 Item 13. Review of Accounts ........................................................................................................................................................ 26 Item 14. Client Referrals and Other Compensation ....................................................................................................................... 27 Item 15. Custody ........................................................................................................................................................................... 27 Item 16. Investment Discretion ..................................................................................................................................................... 27 Item 17. Voting Client Securities .................................................................................................................................................. 28 Item 18. Financial Information...................................................................................................................................................... 28 Page | 3 Disclosure Brochure Vertex Planning Partners, LLC Item 4. Advisory Business Vertex Partners offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to Vertex Partners rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Vertex Partners setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Vertex Partners filed for registration as an investment adviser in December 2021 and is owned by Gregory Benner, Michael Bellis, Christopher Huston, Steven Franzen, and Scott Sandee. As of December 31, 2025, Vertex Partners has $1,011,939,498.09 of assets under management; $1,009,436,132.34 of which was managed on a discretionary basis and $2,503,365.75 of which was managed on a non-discretionary basis. While this brochure generally describes the business of Vertex Partners, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on Vertex Partners’ behalf and are subject to the Firm’s supervision or control. Vertex Partners provides advisory services through certain programs sponsored by LPL Financial LLC (“LPL”), a registered investment advisor and broker-dealer. Vertex Partners has included a brief description of each LPL advisory program that it intends to use. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. Financial Planning and Consulting Services Vertex Partners offers clients a broad range of financial planning and consulting services, which include any or all of the following functions: • Cash Flow Analysis • Trust and Estate Planning • Retirement Planning • Risk Management • Tax Management • Education Planning While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). Page | 4 Disclosure Brochure Vertex Planning Partners, LLC In performing these services, Vertex Partners is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Vertex Partners recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Vertex Partners or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Vertex Partners under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Vertex Partners’ recommendations and/or services. Investment and Wealth Management Services Vertex Partners provides certain clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. Vertex Partners primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Vertex Partners to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Vertex Partners directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Vertex Partners tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Vertex Partners consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Vertex Partners if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Vertex Partners determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Page | 5 Disclosure Brochure Vertex Planning Partners, LLC Sponsor and Manager of Wrap Program Vertex Partners provides substantially all investment management services as the sponsor and manager of the Vertex Partners Wrap Program (the “Wrap Program”), a wrap fee program (i.e., an arrangement where certain brokerage commissions and transaction costs are absorbed by the Firm). Accounts managed through the Wrap Program are done so in substantially the same manner as those managed under a non-wrap arrangement. Participants in the Wrap Program may pay a higher or lower aggregate fee than if investment management and brokerage services are purchased separately. Additional information about the Wrap Program is available in Vertex Partners’ Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form ADV (the “Wrap Brochure”). Retirement Plan Consulting Services Vertex Partners provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services: • Plan Design and Strategy • Plan Review and Evaluation • Executive Planning & Benefits • Investment Selection • Plan Fee and Cost Analysis • Plan Committee Consultation • Fiduciary and Compliance • Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Vertex Partners as a fiduciary under 3(21) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Vertex Partners’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Use of Independent Managers As mentioned above, Vertex Partners selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Page | 6 Disclosure Brochure Vertex Planning Partners, LLC Vertex Partners evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Vertex Partners also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Vertex Partners continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Vertex Partners seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The client may incur additional fees than those charged by Vertex Partners. In certain circumstances, Vertex Partners receives compensation pursuant to its agreements with the Independent Managers for introducing clients to the Independent Managers and for certain ongoing services provided to clients. This compensation is disclosed to the client in a separate disclosure document and is typically equal to a percentage of the investment advisory fee charged by that Independent Manager or a fixed fee. Since compensation Vertex Partners receives may differ depending on the agreement with each Independent Manager, Vertex Partners has an incentive to recommend an Independent Manager with a more favorable compensation arrangements. Since the Independent Manager may pay the fee for the investment advisory services of Vertex Partners, the fee paid to Vertex Partners is not negotiable, under most circumstances. Fees paid by clients to the Independent Managers are established and payable in accordance with the disclosure documents of each Independent Manager, and may or may not be negotiable, as disclosed in the disclosure documents of the Independent Manager. Certain Independent Manager(s) may impose more restrictive account requirements and varying billing practices than Vertex Partners. In such instances, Vertex Partners may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Manager(s) or wrap fee program sponsor, including charging the client and debiting the client’s account on behalf of a third-party manager(s) The Firm expects to use certain of the LPL programs as discussed herein which use Independent Managers. In addition, the Firm expects to use independent manager programs including but not limited to those offered through Vestmark Advisory Solutions, Inc. (“Vestmark”), Vise AI Advisors, LLC (“Vise”) and AQR Capital Management, LLC (“AQR”) for clients with accounts at Charles Schwab & Co., Inc. (Charles Schwab). Vestmark Advisory Solutions, Inc. Vestmark offers a platform at Charles Schwab to run multiple Independent Managers within a single account (Unified Managed Account). The Firm will assist clients in identifying third party portfolio Page | 7 Disclosure Brochure Vertex Planning Partners, LLC managers from a list of Independent Managers available through the Vestmark’s platform, and also available on the LPL Manager Access Select platform. Utilizing the Vestmark platform, clients authorize Vestmark to direct the investment and reinvestment of the assets in their accounts, and perform tax-loss harvesting, in accordance with the selected model portfolio provided by Vestmark, Vertex Partners, or a third-party investment advisor. A minimum account value of $250,000 is required to gain access to the Vestmark’s platform, however, in certain instances, the minimum account size may be lower or higher. Vertex Partners expects to collect Independent Manager fees related to proprietary fees and subadvisory services payable to Vestmark from the client account, and remit such fees to Vestmark on behalf of the client. Direct Indexing Vestmark Direct Indexing provides fully customizable separately managed accounts that seek to match index returns pre-tax while producing enhanced after-tax returns. These separately managed account portfolios can be customized for tax purposes, to align with investor values and concerns, or a combination of both. Accounts may be actively managed to optimize tax loss harvesting while providing beta exposure to an index. This type of solution may help investors mitigate tax liability in their portfolios, minimize capital gains, and plan for future taxable events. Vise AI Advisors, LLC Vise offers a platform at Charles Schwab to run multiple Independent Managers within a single account (Unified Managed Account). The Firm will assist clients in identifying third party portfolio managers from a list of Independent Managers available through the Vise platform, and also available on the LPL Manager Access Select platform. In Utilizing the Vise platform, clients authorize Vise to direct the investment and reinvestment of the assets in their accounts, and performance tax-loss harvesting, in accordance with the selected model portfolio provided by Vise, Vertex Partners, or a third-party investment advisor. Strategies may include execution and implementation services where Vise implements Vertex Partner’s investment strategy, execution and implementation services where Vise acts as a subadvisor and implements a third party asset manager’s investment strategy, and/or ongoing discretionary portfolio management, including investment advice, execution and implementation services, in accordance with investment guidelines provided by Vertex Partners. In some instances, Vertex Partners, may recommend strategies available on the Vise platform which use options contracts and/or portfolio margin. A minimum account value of $250,000 is required to gain access to the Vestmark Advisory Solutions, Inc. platform, however, in certain instances, the minimum account size may be lower or higher. Vertex Partners expects to collect Independent Manager fees related to proprietary fees and subadvisory services payable to Vise from the client account, and remit such fees to Vise on behalf of the client. Direct Indexing Page | 8 Disclosure Brochure Vertex Planning Partners, LLC Vise provides customizable separately managed accounts that seek to match index returns pre-tax while producing enhanced after-tax returns. These separately managed account portfolios can be customized for tax purposes, to align with investor values and concerns, or a combination of both. Accounts may be actively managed to optimize tax-loss harvesting while providing beta exposure to an index. This type of solution may help investors mitigate tax liability in their portfolios, minimize capital gains, and plan for future taxable events. AQR Capital Management, LLC Vertex Partners expects to use independent manager programs offered through AQR for certain clients with accounts at Charles Schwab. AQR offers “Flex” tax-aware equity strategies in a separately managed account format (“Flex SMAs”). Flex SMAs seek to outperform a designated equity benchmark on a pre- tax basis over a full market cycle while managing realized gains and losses that is intended to enhance after- tax results for taxable investors. Flex SMAs invest primarily in diversified long and short positions in equity securities (including U.S.-listed stocks, exchange-traded funds (“ETFs”), mutual funds and, in some cases, American Depositary Receipts (“ADRs”). They typically target a specified beta, tracking error, and level of long and short “gross” exposure relative to a stated benchmark index such as the Russell 1000 or Russell 3000 Index. Certain Flex SMA implementations employ higher gross exposure and require the client’s account to be approved for options and portfolio margin at the custodian. This allows the Flex strategy to use margin secured by the account’s holdings (including, for “Overlay” implementations, a separate “Collateral Sleeve”) to support the long/short positions implemented by AQR. Use of margin and portfolio margin increases the risk of losses, including the potential for margin calls and forced liquidation of securities and may increase the volatility of the account. The Firm will assist clients in determining whether an AQR Flex SMA is appropriate considering the client’s investment objectives, risk tolerance, tax profile, funding assets (including whether concentrated stock or other legacy positions will be contributed in kind), and the custodian’s account-level eligibility requirements for portfolio margin and options. Clients who participate in the AQR Flex program authorize AQR, as an Independent Manager, to direct the investment and reinvestment of the assets in the AQR- managed portion of their account in accordance with the selected Flex strategy and AQR’s investment guidelines, including the use of leverage through margin. Clients also acknowledge that deviations from target beta, tracking error, and leverage may occur due to market conditions, funding securities, account restrictions, or other factors outside AQR’s control. Vertex Partners expects to collect the AQR Independent Manager fee for Flex SMAs from the client account and remit such fee to AQR on the client’s behalf, in addition to the Firm’s own advisory fee, as disclosed in Item 5 of this Brochure. Use of LPL Programs As described above, the Firm expects to use the following LPL programs. Manager Access Select Program Manager Access Select offers clients the ability to participate in the Separately Managed Account Platform (the “SMA Platform”) or the Model Portfolio Platform (the “MP Platform”). In the SMA Platform, Vertex Partners will assist client in identifying a third-party portfolio manager (the Independent Manager) from a Page | 9 Disclosure Brochure Vertex Planning Partners, LLC list of Independent Managers made available by LPL, and the Independent Manager manages client’s assets on a discretionary basis. Vertex Partners will provide initial and ongoing assistance regarding the Independent Manager selection process. In the MP Platform, clients authorize LPL to direct the investment and reinvestment of the assets in their accounts, in accordance with the selected model portfolio provided by LPL’s Research Department or a third-party investment advisor. A minimum account value of $50,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Vertex Partners will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Vertex Partners will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit a lower minimum account size. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. Vertex Partners will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. Vertex Partners will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department, a third-party portfolio strategist and/or Vertex Partners, through its investment adviser representative, may act as a portfolio strategist responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted. Item 5. Fees and Compensation Vertex Partners offers services on a fee basis, which includes fixed fees, as well as fees based upon assets under management. Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offers securities brokerage services and/or insurance products under a separate commission-based Page | 10 Disclosure Brochure Vertex Planning Partners, LLC arrangement. For investment management fees associated with participation in the Wrap Program, please see the Wrap Brochure. Financial Planning and Consulting Fees Vertex Partners charges a fixed and/or hourly fee for providing financial planning and consulting services under a stand-alone engagement. These fees are negotiable, but range from $500 to $15,000 depending upon the scope and complexity of the services and the professional rendering the financial planning and/or the consulting services. The fee can be for a defined project, such as the delivery of a plan, or for ongoing services. If the client engages the Firm for additional investment advisory services, Vertex Partners can offset all or a portion of its fees for those services based upon the amount paid for the financial planning and/or consulting services. The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory Agreement. For project-based services Vertex Partners requires one-half of the fee (estimated hourly or fixed) payable upon execution of the Advisory Agreement. The outstanding balance is due upon delivery of the financial plan or completion of the agreed upon services. Ongoing services are charged as described in the investment management section, below. The Firm does not, however, take receipt of $1,200 or more in prepaid fees, six or more months in advance of services rendered. Investment Management Fees Vertex Partners offers investment management services for an annual fee based on the amount of assets under the Firm’s management. This management fee varies between 30 and 200 basis points (0.30% – 2.00%), depending upon the size and composition of a client’s portfolio, the type and amount of services rendered and the individual(s) providing the services. The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by Vertex Partners on the last day of the previous quarter as determined by a party independent from the Firm (including the client’s custodian or another third-party). If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), Vertex Partners can negotiate a fee rate that differs from the range set forth above. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Vertex Partners for additional services for compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon Page | 11 Disclosure Brochure Vertex Planning Partners, LLC any of the recommendations. Any LPL Program referenced above is subject to maximum fees, depending on which program is used. Retirement Plan Consulting Fees Vertex Partners charges as fixed project-based fee to provide clients with retirement plan consulting services. Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor, as memorialized in the Agreement. These fees vary, based on the scope of the services to be rendered, and ranges up to $15,000 per annum on a fixed fee basis depending upon services provided, the person providing the services, and the amount of assets to be advised on. Fee Discretion Vertex Partners may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention, pro bono activities, or competitive purposes. Additional Fees and Expenses In addition to the advisory fees paid to Vertex Partners, clients also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges include securities brokerage commissions, transaction fees, custodial fees, fees attributable to alternative assets, fees charged by the Independent Managers, margin and other borrowing costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. The Firm’s brokerage practices are described at length in Item 12, below. Direct Fee Debit Clients provide Vertex Partners and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to Vertex Partners. Alternatively, clients may elect to have Vertex Partners send a separate invoice for direct payment for financial planning or consulting services. In certain circumstances, the Firm will take its fee as well as charge the client and debit the client’s account on behalf of third-party Independent Managers, including but not limited to Vestmark, Vise, and AQR, and remit the Independent Manager’s fee to that manager. Page | 12 Disclosure Brochure Vertex Planning Partners, LLC Use of Margin Vertex Partners can be authorized by clients to use margin in the management of the client’s investment portfolio. In these cases, the fee payable will be assessed gross of margin such that the market value of the client’s account and corresponding fee payable by the client to Vertex Partners will be increased. Where investment management fees are assessed gross of margin, a conflict of interest exists as the Firm has an incentive to use margin to increase its fees. For certain clients, the Firm also utilizes AQR Capital Management, LLC’s (“AQR”) Flex separately managed account strategies, some of which employ margin and, in some cases, portfolio margin at the custodian to implement leveraged long/short exposure. The advisory fee charged by Vertex Partners, as well as any separate AQR management fee for these strategies, is typically calculated based on the gross market value of the assets in the account (including securities purchased on margin), which similarly creates a conflict of interest. as both Vertex Partners and AQR may receive higher fees when margin is employed. Clients who authorize the use of margin, including for participation in AQR Flex strategies, should understand that margin borrowing increases account-level risk and cost, and that they are not obligated to authorize or maintain margin to receive ongoing advisory services from Vertex Partners for non-margin strategies. For taxable clients, the use of margin-borrowing in their accounts may have important tax consequences, including that interest paid on margin loans may not be fully deductible and, in some cases, may be entirely nondeductible. Clients should understand that when margin interest is deductible, it is generally subject to specific limitations and character rules. This can cause the after-tax cost of borrowing to differ from the stated interest rate. Margin interest is generally treated as “investment interest expense” under Internal Revenue Code § 163(d). Investment interest expense is deductible only to the extent of the taxpayer’s net investment income for the year. Taxpayers should consult their own tax advisors regarding the treatment of any margin interest and related expenses considering individual circumstances. Account Additions and Withdrawals Clients can make additions to and withdrawals from their account at any time, subject to Vertex Partners’ right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients can withdraw account assets on notice to Vertex Partners, subject to the usual and customary securities settlement procedures. However, the Firm designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Vertex Partners may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Commissions and Sales Charges for Recommendations of Securities Page | 13 Disclosure Brochure Vertex Planning Partners, LLC Clients can engage certain persons associated with Vertex Partners (but not the Firm directly) to render securities brokerage services under a separate commission-based arrangement. Clients are under no obligation to engage such persons and may choose brokers or agents not affiliated with Vertex Partners. Under this arrangement, the Firm’s Supervised Persons, in their individual capacities as registered representatives of LPL Financial (“LPL”), can provide securities brokerage services and implement securities transactions under a separate commission based arrangement. Supervised Persons are entitled to a portion of the brokerage commissions paid to LPL, as well as a share of any ongoing distribution or service (trail) fees from the sale of mutual funds. Vertex Partners can also recommend no-load or load- waived funds, where no sales charges are assessed, but where the Supervised Person receives other forms of compensation. Prior to effecting any transactions, clients are required to enter into a separate account agreement with LPL. A conflict of interest exists to the extent that a Supervised Person of Vertex Partners recommends the purchase or sale of securities through a brokerage relationship where that Supervised Persons receives commissions or other additional compensation as a result of that recommendation (the “Brokerage Relationship”). Because the Supervised Persons receive compensation in connection with the sale of securities in the Brokerage Relationship, a conflict of interest exists as such Supervised Persons, have an incentive to recommend more expensive securities or services to clients where such Supervised Persons earn more compensation with respect to the sale of such securities through the Brokerage Relationship rather than through an advisory relationship with the Firm. The Firm has procedures in place to ensure that any recommendations made by such Supervised Persons to engage in the Brokerage Relationship are in the best interest of that client. Clients should understand that the investments made in the Brokerage Relationship are not receiving advisory services from the Firm. Therefore, the Firm does not have a fiduciary duty over the Brokerage Relationship recommendations. Additional LPL Disclosures LPL serves as program sponsor, investment advisor and broker-dealer for most of the LPL advisory programs. Vertex Partners receives compensation as a result of a client’s participation in an LPL program. Depending on, among other things, the type and size of the account, type of securities held in the account, changes in its value over time, the ability to negotiate fees or commissions, the historical or expected size or number of transactions, and the number and range of supplementary advisory and client-related services provided to the client, the amount of this compensation may be more or less than what Vertex Partners would receive if the client participated in other programs, whether through LPL or another sponsor, or paid separately for investment advice, brokerage and other services. Clients should consider the level and complexity of the advisory services to be provided when negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with Vertex Partners. With regard to accounts utilizing third-party portfolio managers under aggregate, all-in-one account fee Page | 14 Disclosure Brochure Vertex Planning Partners, LLC structures, because the portion of the account fee retained by Vertex Partners varies depending on the portfolio strategist fee associated with a portfolio, Vertex Partners has a financial incentive to select one portfolio instead of another portfolio. Please refer to the relevant LPL Form ADV program brochure for a more detailed discussion of conflicts of interest. Item 6. Performance-Based Fees and Side-by-Side Management Vertex Partners does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Item 7. Types of Clients Vertex Partners offers services to individuals, trusts, estates, charitable organizations, corporations and other business entities, and retirement and profit-sharing plans. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies Vertex Partners believes the foundation of proper investment management stems from the understanding of client goals and objectives prior to making any investment recommendation. When recommending a portfolio strategy, Vertex Partners recognizes the importance of asset allocation and diversification, but also considers the principles of behavioral finance and the impact of investor psychology and biases. Vertex Partners maintains a series of portfolios that are recommended to clients as appropriate to the client’s preference, risk tolerance, and risk capacity. Each portfolio’s risk, return, and liquidity are in large part a function of the asset classes that are included in the portfolio. Vertex Partners utilizes third party strategies along with internally constructed model portfolios. The Firm’s models typically will employee both active and passive management strategies, as well as invest via Mutual Funds, Exchange-Traded Funds, Independent Managers, as well as Interval Funds. For clients in higher tax brackets, Vertex Partners may utilize individual equities and municipal bonds. Technology allows Vertex Partners to generate rebalancing reviews for all clients based upon predetermined tolerance bands and each individual client’s unique needs. Vertex Partners considers the tax ramifications and trading costs before rebalancing. In taxable accounts, it may make sense to do only a partial rebalance or retain non-model holdings based on the client’s personal tax consequences. Third Party Investment Strategies Vertex Partners researches investment managers and strategist and provides client access to these strategies through our portfolio management and trading technology. The due diligence process incorporates qualitative review of the investment team, their philosophy and process. This analysis is complemented with quantitate analysis of the manager’s past performance and portfolio risks. VPP monitors and maintains updated information on the investment managers and funds through routine due diligence efforts. Page | 15 Disclosure Brochure Vertex Planning Partners, LLC Model Management Vertex Partners model management is designed to maximize operational efficiencies for the Firm’s clients and advisors, and provide portfolio customization. It centralizes the delivery and manufacturing of proprietary and third-party model portfolios across asset classes. Vertex Partners relies on proprietary and vended applications to assist in the ongoing management of these strategies. Risk of Loss The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved with respect to the Firm’s investment management activities. Clients should consult with their legal, tax, and other advisors before engaging the Firm to provide investment management services on their behalf. Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of Vertex Partners’ recommendations and/or investment decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. In addition, investments may be adversely affected by financial markets and economic conditions throughout the world. There can be no assurance that Vertex Partners will be able to predict these price movements accurately or capitalize on any such assumptions. Volatility Risks The prices and values of investments can be highly volatile, and are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, the financial condition of the issuers of such assets, changing supply and demand relationships, and programs and policies of governments. Cash Management Risks The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of investments, during which time an advisory account may be prevented from achieving its investment objective. Equity-Related Securities and Instruments The Firm (through the Independent Managers recommended) may take long positions in common stocks of U.S. and non-U.S. issuers traded on national securities exchanges and over-the-counter markets. The value of equity securities varies in response to many factors. These factors include, without limitation, factors specific to an issuer and factors specific to the industry in which the issuer participates. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments, and the stock prices of such companies may suffer a decline in response. In addition, equity securities are subject to stock risk, which is the risk that stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced periods of substantial price volatility in the past and may do so again in the future. In addition, investments in small-capitalization, mid-capitalization and financially distressed companies may be subject to more abrupt or erratic price movements and may lack Page | 16 Disclosure Brochure Vertex Planning Partners, LLC sufficient market liquidity, and these issuers often face greater business risks. Fixed Income Securities While the Firm emphasizes risk-averse management and capital preservation in its fixed-income bond portfolios, clients who invest in this product can lose money, including losing a portion of their original investment. The prices of the securities in our portfolios fluctuate. The Firm does not guarantee any particular level of performance. Below is a representative list of the types of risks clients should consider before investing in this product. • Interest rate risk. Prices of bonds tend to move in the opposite direction to interest rate changes. Typically, a rise in interest rates will negatively affect bond prices. The longer the duration and average maturity of a portfolio, the greater the likely reaction to interest rate moves. • Credit (or default) risk. A bond’s price will generally fall if the issuer fails to make a scheduled interest or principal payment, if the credit rating of the security is downgraded, or if the perceived creditworthiness of the issuer deteriorates. • Liquidity risk. Sectors of the bond market can experience a sudden downturn in trading activity. When there is little or no trading activity in a security, it can be difficult to sell the security at or near its perceived value. In such a market, bond prices may fall. • Call risk. Some bonds give the issuer the option to call or redeem the bond before the maturity date. If an issuer calls a bond when interest rates are declining, the proceeds may have to be reinvested at a lower yield. During periods of market illiquidity or rising rates, prices of callable securities may be subject to increased volatility. • Prepayment risk. When interest rates fall, the principal of mortgage-backed securities may be prepaid. These prepayments can reduce the portfolio’s yield because proceeds may have to be reinvested at a lower yield. • Extension risk. When interest rates rise or there is a lack of refinancing opportunities, prepayments of mortgage-backed securities or callable bonds may be less than expected. This would lengthen the portfolio’s duration and average maturity and increase its sensitivity to rising rates and its potential for price declines. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the funds underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily Page | 17 Disclosure Brochure Vertex Planning Partners, LLC per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for index-based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Use of Independent Managers As stated above, Vertex Partners selects certain Independent Managers to manage a portion of its clients’ assets. In these situations, Vertex Partners continues to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, Vertex Partners does not have the ability to supervise the Independent Managers on a day-to-day basis. Management through Similarly Managed “Model” Accounts Vertex Partners manages certain accounts through the use of similarly managed “model” portfolios, whereby the Firm allocates all or a portion of its clients’ assets among various mutual funds and/or securities on a discretionary basis using one or more of its proprietary investment strategies. In managing assets through the use of models, the Firm remains in compliance with the safe harbor provisions of Rule 3a-4 of the Investment Company Act of 1940. The strategy used to manage a model portfolio may involve an above average portfolio turnover that could negatively impact clients’ net after tax gains. While the Firm seeks to ensure that clients’ assets are managed in a manner consistent with their individual financial situations and investment objectives, securities transactions effected pursuant to a model investment strategy are usually done without regard to a client’s individual tax ramifications. Clients should contact the Firm if they experience a change in their financial situation or if they want to impose reasonable restrictions on the management of their accounts. Use of Margin While the use of margin borrowing for investments can substantially improve returns, it may also increase overall portfolio risk. Margin transactions are generally effected using capital borrowed from a Financial Institution, which is secured by a client’s holdings. Under certain circumstances, a lending Financial Institution may demand an increase in the underlying collateral. If the client is unable to provide the additional collateral, the Financial Institution may liquidate account assets to satisfy the client’s outstanding obligations, which could have extremely adverse consequences. In addition, fluctuations in the amount of a client’s borrowings and the corresponding interest rates may have a significant effect on the profitability Page | 18 Disclosure Brochure Vertex Planning Partners, LLC and stability of a client’s portfolio. For certain clients, the Firm utilizes AQR Flex separately managed account strategies, some of which employ significant leverage using margin and, in some cases, portfolio margin at the custodian. These strategies generally seek to maintain a leveraged “gross” exposure through long and short positions in equity securities and related instruments while targeting a specified beta and tracking error to an equity benchmark. However, actual leverage and risk exposures may deviate from these targets due to market conditions, the composition or margin-ability of funding securities, client-imposed restrictions, or other factors. Since these strategies rely on margin, and portfolio margin where applicable, adverse market movements can lead to amplified losses, margin calls, and potential forced liquidation of securities by the custodian, which may occur at unfavorable prices and have adverse tax consequences for the client. Where an “overlay” implementation is used, a portion of the account may function as a collateral sleeve that is not managed by AQR but is pledged to support the AQR-managed long/short positions, exposing the client to the risk that declines in the value or margin-ability of the collateral sleeve may impair AQR’s ability to maintain the strategy and increase the likelihood of margin calls or forced de-leveraging. Currency Risks An advisory account that holds investments denominated in currencies other than the currency in which the advisory account is denominated may be adversely affected by the volatility of currency exchange rates. Interest Rate Risks Interests rates may fluctuate significantly, causing price volatility with respect to securities or instruments held by clients. Use of Structured Products Structured products involve derivatives and a higher degree of risk factors that may not be suitable for all investors. Such risks include risk of adverse or unanticipated market developments, issuer credit quality risk, risk of counterparty or issuer default, risk of lack of uniform standard pricing, risk of adverse events involving any underlying reference obligations, entity or other measure, risk of high volatility, and risk of illiquidity/ little to no secondary market. In certain transactions, investors may lose their entire investment, i.e., incur an unlimited loss. Item 9. Disciplinary Information Vertex Partners has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. Item 10. Other Financial Industry Activities and Affiliations This item requires investment advisers to disclose certain financial industry activities and affiliations. The Firm does not have any other financial industry activities or affiliations that need to be disclosed. Registered Representatives of a Broker-Dealer Page | 19 Disclosure Brochure Vertex Planning Partners, LLC Certain of the Firm’s Supervised Persons are registered representatives of LPL and provide clients with securities brokerage services under a separate commission-based arrangement. This arrangement is described at length in Item 5. Licensed Insurance Agents A number of the Firm’s Supervised Persons are licensed insurance agents and offer certain insurance products on a fully-disclosed commissionable basis. This can be done individually or as agents of another insurance agency, including LPL. A conflict of interest exists to the extent that Vertex Partners recommends the purchase of insurance products where its Supervised Persons are entitled to insurance commissions or other additional compensation. The Firm has procedures in place whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of any such affiliations. Accounting/CPA Firm Affiliation Certain of the Firm’s Supervised Persons are owners and affiliated with Vertex Accounting Partners, LLC. From time to time, they may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. The Firm always acts in the best interest of the client and clients always have the right to decide whether or not to utilize the services of any Firm representative in such individual’s outside capacities. Fees from Independent Managers As discussed above, Vertex Partners recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain Independent Managers. In certain circumstances the Firm’s compensation is included in the advisory fee charged by such Independent Managers. There is a conflict of interest to choose such Independent Managers; however, Vertex Partners evaluates Independent Managers objectively and not based on the amount of compensation it may receive from a particular Independent Manager. Item 11. Code of Ethics Vertex Partners has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Vertex Partners’ Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of Vertex Partners’ personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in Page | 20 Disclosure Brochure Vertex Planning Partners, LLC sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless: • the transaction has been completed; • the transaction for the Supervised Person is completed as part of a batch trade with clients; or • a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high-quality short-term debt instruments, including repurchase agreements; (iii) shares issued by money market funds; and iv) shares issued by other unaffiliated open-end mutual funds. Clients and prospective clients may contact Vertex Partners to request a copy of its Code of Ethics by contacting the Firm at the phone number on the cover page of this brochure. Item 12. Brokerage Practices Recommendation of Broker-Dealers for Client Transactions Vertex Partners recommends that clients utilize the custody, brokerage and clearing services of LPL and/or Charles Schwab & Co., Inc. (“Schwab” and together with LPL, "Custodians") for investment management accounts. The final decision to custody assets with the Custodians is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. Because of the relationship between the Firm and LPL, the Firm may require clients to engage LPL for the brokerage and clearing services. The Custodians are generally compensated by clients through commissions, trails, or other transaction- based fees for trades that are executed through the Custodians or that settle into Custodians’ accounts. For IRA accounts, LPL generally charges account maintenance fees. In addition, the Custodians can also charge clients miscellaneous fees and charges, such as account transfer fees. LPL charges Vertex Partners an asset- based administration fee for administrative services provided by LPL. Such administration fees are not directly borne by clients, but may be considered when Vertex Partners negotiates its advisory fee with clients. Factors which Vertex Partners considers in recommending the Custodians or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Custodians enable the Firm to obtain many mutual funds without transaction charges and other securities Page | 21 Disclosure Brochure Vertex Planning Partners, LLC at nominal transaction charges. The commissions and/or transaction fees charged by Custodians may be higher or lower than those charged by other Financial Institutions. The commissions paid by Vertex Partners’ clients to Custodians comply with the Firm’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where Vertex Partners determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. Vertex Partners seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because Vertex Partners does not have to produce or pay for the products or services. Vertex Partners periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Software and Support Provided by Financial Institutions Vertex Partners receives support services and/or products from Custodians, many of which assist the Firm to better monitor and service program accounts maintained at Custodians; however, some of the services and products benefit Vertex Partners and not client accounts. These support services and/or products may be received without cost, at a discount, and/or at a negotiated rate, and may include the following from one or more of Custodians: • investment-related research • pricing information and market data • software and other technology that provide access to client account data • compliance and/or practice management-related publications • consulting services • attendance at conferences, meetings, and other educational and/or social events • marketing support • computer hardware and/or software Page | 22 Disclosure Brochure Vertex Planning Partners, LLC • other products and services used by Vertex Partners in furtherance of its investment advisory business operations Custodians may provide these services and products directly, or may arrange for third party vendors to provide the services or products to Vertex Partners. In the case of third-party vendors, Custodians may pay for some or all of the third party’s fees. These support services are provided to Vertex Partners based on the overall relationship between Vertex Partners and Custodians. It is not the result of soft dollar arrangements or any other express arrangements with Custodians that involves the execution of client transactions as a condition to the receipt of services. Vertex Partners will continue to receive the services regardless of the volume of client transactions executed with Custodians. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by the Vertex Partners to Custodians or any other entity to invest any specific amount or percentage of client assets in any specific securities as a result of the arrangement. However, because Vertex Partners receives these benefits from Custodians, there is a conflict of interest. The receipt of these products and services presents a financial incentive for Vertex Partners to recommend that its clients use Custodians’ custodial platform rather than another custodian’s platform. Custodians also make available to Vertex Partners other services intended to help the Firm manage and further develop its business. Some of these services assist Vertex Partners to better monitor and service program accounts maintained at Custodians, however, many of these services benefit only Vertex Partners, for example, services that assist the Firm in growing its business. These support services and/or products may be provided without cost, at a discount, and/or at a negotiated rate, and include practice management- related publications; consulting services; attendance at conferences and seminars, meetings, and other educational and/or social events; marketing support; and other products and services used by Vertex Partners in furtherance of the operation and development of its investment advisory business. The products and services described above are provided to Vertex Partners as part of its overall relationship with Custodians. While as a fiduciary Vertex Partners endeavors to act in its clients’ best interests, the receipt of these benefits creates a conflict of interest because the Firm’s recommendation that clients custody their assets at LPL is based in part on the benefits received and not solely on the nature, cost or quality of custody or brokerage services provided by Custodians. Vertex Partners’ receipt of some of these benefits may be based on the amount of advisory assets custodied on the Custodians’ platforms. Charles Schwab & Co., Inc. Disclosures There is no direct link between Vertex Partners’ participation in Schwab’s institutional customer program and the investment advice it gives to its clients, although Vertex Partners receives economic benefits through its participation in the program that are typically not available to Schwab retail investors. Additionally, Vertex Partners may receive the following benefits from Schwab through its registered investment adviser division: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its Registered Investment Adviser participants; access to Page | 23 Disclosure Brochure Vertex Planning Partners, LLC block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and access to an electronic communication network for client order entry and account information. The Firm also has the ability deduct advisory fees directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to the Firm by third party vendors. Schwab may fund business consulting and professional services received by Vertex Partners’ related persons. Some of the products and services made available by Schwab through the program may benefit Vertex Partners but not its client. These products or services may assist Vertex Partners in managing and administering client accounts, including accounts not maintained at Schwab. Other services made available by Schwab are intended to help Vertex Partners manage and further develop its business enterprise. The benefits received by Vertex Partners’ participation in the program do not depend on the amount of brokerage transactions directed to Schwab. Loans and other Benefits Received by the Firm or Supervised Persons from LPL The Firm receives other benefits from LPL. Some of the benefits are available to any investment adviser utilizing LPL services. Others may only be available due to the Firm’s relationship with LPL. LPL has and will provide forgivable loans to certain Supervised Persons of the Firm. The loan payments repayable by the Supervised Persons are forgiven over time so there is an incentive for the Firm to maintain its relationship with LPL as custodian for advisory clients as well as the Supervised Persons maintaining their registered representative status in their individual capacity. LPL will also provide the Firm with financing in order to purchase other advisory businesses or recruit investment adviser representatives. The receipt of the loans and financing creates conflicts of interest relating to Vertex Partners’ advisory business because it creates a financial incentive for the Firm and its Supervised Persons to recommend clients maintain their advisory or brokerage accounts with LPL. Vertex Partners seeks to mitigate these conflicts of interest by evaluating LPL's services to determine that the recommendation to use LPL is based on the benefits that such services provide to clients, rather than the benefits received by the Firm or its Supervised Person. As set forth above, the Firm periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution, including its recommendation of LPL. However, clients should be aware of this conflict and take it into consideration in making a decision whether to custody their assets with LPL through Vertex Partners, or open a brokerage account with a Supervised Person as a registered representative at LPL. Brokerage for Client Referrals Vertex Partners does not consider, in selecting or recommending broker-dealers, whether the Firm receives client referrals from the Financial Institutions or other third party. Page | 24 Disclosure Brochure Vertex Planning Partners, LLC Directed Brokerage The client may direct Vertex Partners in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by Vertex Partners (as described above). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, Vertex Partners may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties or violate restrictions imposed by other broker-dealers (as further discussed below). Commissions or Sales Charges for Recommendations of Securities As discussed above, certain Supervised Persons in their respective individual capacities are registered representatives of LPL. These Supervised Persons are subject to FINRA Rule 3280 which restricts registered representatives from conducting securities transactions away from their broker-dealer unless the registered representatives give prior notice of such transactions to LPL and, in most circumstances, LPL provides written consent. Therefore, clients are advised that certain Supervised Persons are restricted to conducting securities transactions through LPL if they have not secured written consent from LPL to execute securities transactions though a different broker-dealer. Absent such written consent or separation from LPL, these Supervised Persons are generally prohibited from executing securities transactions through any broker-dealer other than LPL under its internal supervisory policies. In addition, LPL is responsible for supervising certain activities of Vertex Partners to the extent Vertex Partners manages assets at a broker/dealer and custodian other than LPL. LPL charges a fee to Vertex Partners for this oversight. This presents a conflict of interest in that Vertex Partners has a financial incentive to recommend that clients maintain their accounts with LPL rather than another custodian in order to avoid the oversight fee. The Firm is cognizant of its duty to obtain best execution and has implemented policies and procedures reasonably designed in such pursuit. LPL may have access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about Vertex Partners’ clients, even if client does not establish any account through LPL. Trade Aggregation Transactions for each client will be effected independently, unless Vertex Partners decides to purchase or Page | 25 Disclosure Brochure Vertex Planning Partners, LLC sell the same securities for several clients at approximately the same time. Vertex Partners may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s clients. Differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among Vertex Partners’ clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which Vertex Partners’ Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Vertex Partners does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Item 13. Review of Accounts Account Reviews Vertex Partners monitors client portfolios on a continuous and ongoing basis and regular account reviews are conducted on at least an annual basis. Such reviews are conducted by the client’s investment adviser representative(s) as well as cash reviews and drift reports by the Firm. All investment advisory clients are encouraged to discuss their needs, goals and objectives with Vertex Partners and to keep the Firm informed of any changes thereto. Account Statements and Reports Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from Vertex Partners and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with any documents or reports they Page | 26 Disclosure Brochure Vertex Planning Partners, LLC receive from Vertex Partners or an outside service provider. Item 14. Client Referrals and Other Compensation The Firm does not currently provide compensation to any third-party solicitors for client referrals. Other Compensation The Firm receives economic benefits from the Custodians. The benefits, conflicts of interest and how they are addressed are discussed above in response to Item 12. Item 15. Custody Vertex Partners is deemed to have custody of client funds and securities because the Firm is given the ability to debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained at one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such qualified custodians will send account statements to clients at least once per calendar quarter that typically detail any transactions in such account for the relevant period. In addition, as discussed in Item 13, Vertex Partners will also send, or otherwise make available, periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from Vertex Partners. Any other custody disclosures can be found in the Firm’s Form ADV Part 1. Standing Letters of Authorization Vertex Partners has custody due to clients giving the Firm limited power of attorney in a standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February 21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii) client will authorize the Firm to direct transfers to the specific third party; iii) the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have no authority or ability to designate or change the identity or any information about the third party; vi) the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the SLOA instructions. Item 16. Investment Discretion Vertex Partners is given the authority to exercise discretion on behalf of some clients. Vertex Partners is considered to exercise investment discretion over a client’s account if it can effect and/or direct transactions in client accounts without first seeking their consent. Vertex Partners is given this authority through a power-of-attorney included in the agreement between Vertex Partners and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). Vertex Partners takes discretion over the following activities: • The securities to be purchased or sold; Page | 27 Disclosure Brochure Vertex Planning Partners, LLC • The amount of securities to be purchased or sold; • When transactions are made; and • The Independent Managers to be hired or fired. Item 17. Voting Client Securities Vertex Partners does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are custodied and may contact the Firm at the contact information on the cover of this brochure with questions about any such issuer solicitations. Item 18. Financial Information Vertex Partners is not required to disclose any financial information listed in the instructions to Item 18 because: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. Page | 28

Additional Brochure: WRAP FEE PROGRAM BROCHURE FOR VERTEX PARTNERS (2026-03-30)

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Wrap Fee Program Brochure March 30, 2026 VERTEX PLANNING PARTNERS WRAP PROGRAM Sponsored by VERTEX PLANNING PARTNERS, LLC a Registered Investment Adviser 3000 Woodcreek Drive, Suite 100 Downers Grove, IL 60515 (630) 836-3300 www.vertexplanningpartners.com This brochure provides information about the qualifications and business practices of Vertex Planning Partners, LLC (hereinafter “Vertex Partners” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at the telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training. Wrap Fee Program Brochure Vertex Planning Partners, LLC Item 2. Material Changes In this Item, Vertex Partners has made the following material changes to the brochure since the last annual amendment. • Vertex Partners has updated their Assets Under Management. (Item 4) • Vertex Partners has updated their advisory business in offering independent manager programs through AQR Capital Management LLC (AQR), Vestmark Advisory Solutions, Inc. (Vestmark), and Vise AI Advisors, LLC (Vise). • Vertex Partners has updated Portfolio Manager Selection and Evaluation (Item 6) to reflect the changes To the independent manager programs. Page | 2 Wrap Fee Program Brochure Vertex Planning Partners, LLC Item 3. Table of Contents Item 2. Material Changes ................................................................................................................................................................ 2 Item 3. Table of Contents ................................................................................................................................................................ 3 Item 4. Advisory Business .............................................................................................................................................................. 4 Item 5. Account Requirements and Types of Clients ..................................................................................................................... 16 Item 6. Portfolio Manager Selection and Evaluation ..................................................................................................................... 16 Item 7. Client Information Provided to Portfolio Managers ........................................................................................................... 21 Item 8. Client Contact with Portfolio Managers ............................................................................................................................ 21 Item 9. Additional Information ..................................................................................................................................................... 22 Page | 3 Wrap Fee Program Brochure Vertex Planning Partners, LLC Item 4. Advisory Business The Vertex Planning Partners Wrap Program (the “Program”) is an investment advisory program sponsored by Vertex Partners. In addition to the Program, the Firm offers a variety of advisory services, which include financial planning, consulting, and investment management services under different arrangements than those described herein. Prior to Vertex Partners rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Vertex Partners setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Vertex Partners filed for registration as an investment adviser in December 2021 and is owned by Gregory Benner, Michael Bellis, Christopher Huston, Steven Franzen and Scott Sandee. As of December 31, 2025, Vertex Partners has $1,011,939,498.09 of assets under management; $1,009,436,132.34 of which was managed on a discretionary basis and $2,503,365.75 of which was managed on a non-discretionary basis. While this brochure generally describes the business of Vertex Partners, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Vertex Partners’ behalf and is subject to the Firm’s supervision or control. Vertex Partners provides advisory services through certain programs sponsored by LPL Financial LLC (“LPL”), a registered investment advisor and broker-dealer. Vertex Partners has included a brief description of each LPL advisory program that it intends to use. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. Description of the Program The Program is offered as a wrap fee program, which provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. A wrap fee program is considered any arrangement under which clients receive investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions for a specified fee or fees not based upon transactions in their accounts. Clients must also open a new securities brokerage account and complete a new account agreement with LPL and/or Charles Schwab & Co. Inc. (“Schwab” and together with LPL, "Custodians"), or another broker-dealer that Vertex Partners approves under the Program (collectively “Financial Institutions”). Page | 4 Wrap Fee Program Brochure Vertex Planning Partners, LLC Vertex Partners assists its clients in developing an appropriate strategy for managing their assets. Clients’ investment portfolios are generally managed on a discretionary and/or non-discretionary basis by either Vertex Partners’ investment adviser representatives or an independent investment manager (collectively “Independent Managers”), as selected by Vertex Partners. Vertex Partners and/or the Independent Managers generally allocates clients’ assets among the various investment products available under the Program, as described further in Item 6 (below). Financial Planning and Consulting Services Vertex Partners offers clients a broad range of financial planning and consulting services, which include any or all of the following functions: • Cash Flow Analysis • Risk Management • Trust and Estate Planning • Tax Management • Retirement Planning • Education Planning While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, Vertex Partners is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Vertex Partners recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Vertex Partners or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Vertex Partners under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Vertex Partners’ recommendations and/or services. Investment and Wealth Management Services Vertex Partners provides certain clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. Page | 5 Wrap Fee Program Brochure Vertex Planning Partners, LLC Vertex Partners primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Vertex Partners to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Vertex Partners directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Vertex Partners tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Vertex Partners consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Vertex Partners if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Vertex Partners determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Retirement Plan Consulting Services Vertex Partners provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services: • Plan Design and Strategy • Plan Fee and Cost Analysis • Plan Review and Evaluation • Plan Committee Consultation • Executive Planning & Benefits • Fiduciary and Compliance • Investment Selection • Participant Education Page | 6 Wrap Fee Program Brochure Vertex Planning Partners, LLC As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Vertex Partners as a fiduciary under 3(21) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Vertex Partners’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Use of Independent Managers As mentioned above, Vertex Partners selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Vertex Partners evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Vertex Partners also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Vertex Partners continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Vertex Partners seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The client may incur additional fees than those charged by Vertex Partners. In certain circumstances, Vertex Partners receives compensation pursuant to its agreements with the Independent Managers for introducing clients to the Independent Managers and for certain ongoing services provided to clients. This compensation is disclosed to the client in a separate disclosure document and is typically equal to a percentage of the investment advisory fee charged by that Independent Manager or a fixed fee. Since compensation Vertex Partners receives may differ depending on the agreement with each Independent Manager, Vertex Partners has an incentive to recommend an Independent Manager with a more favorable compensation arrangements. Since the Independent Manager may pay the fee for the investment advisory services of Vertex Partners, the fee paid to Vertex Partners is not negotiable, under most circumstances. Fees paid by clients to the Independent Managers are established and payable in accordance with the disclosure documents of each Independent Manager, and may or may not be negotiable, as disclosed in the disclosure documents of the Independent Manager. Page | 7 Wrap Fee Program Brochure Vertex Planning Partners, LLC Certain Independent Manager(s) may impose more restrictive account requirements and varying billing practices than Vertex Partners. In such instances, Vertex Partners may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Manager(s) or wrap fee program sponsor, including charging the client and debiting the client’s account on behalf of a third-party manager(s) The Firm expects to use certain of the LPL programs as discussed herein which use Independent Managers. In addition, the Firm expects to use independent manager programs including but not limited to those offered through Vestmark Advisory Solutions, Inc. (“Vestmark”), Vise AI Advisors, LLC (“Vise”) and AQR Capital Management, LLC (“AQR”) for clients with accounts at Charles Schwab & Co., Inc. (Charles Schwab). Vestmark Advisory Solutions, Inc. Vestmark offers a platform at Charles Schwab to run multiple Independent Managers within a single account (Unified Managed Account). The Firm will assist clients in identifying third party portfolio managers from a list of Independent Managers available through the Vestmark’s platform, and also available on the LPL Manager Access Select platform. Utilizing the Vestmark platform, clients authorize Vestmark to direct the investment and reinvestment of the assets in their accounts, and perform tax-loss harvesting, in accordance with the selected model portfolio provided by Vestmark, Vertex Partners, or a third-party investment advisor. A minimum account value of $250,000 is required to gain access to the Vestmark’s platform, however, in certain instances, the minimum account size may be lower or higher. Vertex Partners expects to collect Independent Manager fees related to proprietary fees and subadvisory services payable to Vestmark from the client account, and remit such fees to Vestmark on behalf of the client. Direct Indexing Vestmark Direct Indexing provides fully customizable separately managed accounts that seek to match index returns pre-tax while producing enhanced after-tax returns. These separately managed account portfolios can be customized for tax purposes, to align with investor values and concerns, or a combination of both. Accounts may be actively managed to optimize tax loss harvesting while providing beta exposure to an index. This type of solution may help investors mitigate tax liability in their portfolios, minimize capital gains, and plan for future taxable events. Vise AI Advisors, LLC Vise offers a platform at Charles Schwab to run multiple Independent Managers within a single account (Unified Managed Account). The Firm will assist clients in identifying third party portfolio managers from a list of Independent Managers available through the Vise platform, and also available on the LPL Manager Access Select platform. In Utilizing the Vise platform, clients authorize Vise to direct the investment and reinvestment of the assets in their accounts, and performance tax-loss harvesting, in accordance with the selected model portfolio provided by Vise, Vertex Partners, or a third-party investment advisor. Strategies may include execution and implementation services where Vise implements Vertex Partner’s investment strategy, execution and implementation services where Vise acts as a subadvisor and implements a third party asset manager’s investment strategy, and/or ongoing discretionary portfolio management, Page | 8 Wrap Fee Program Brochure Vertex Planning Partners, LLC including investment advice, execution and implementation services, in accordance with investment guidelines provided by Vertex Partners. In some instances, Vertex Partners, may recommend strategies available on the Vise platform which use options contracts and/or portfolio margin. A minimum account value of $250,000 is required to gain access to the Vestmark Advisory Solutions, Inc. platform, however, in certain instances, the minimum account size may be lower or higher. Vertex Partners expects to collect Independent Manager fees related to proprietary fees and subadvisory services payable to Vise from the client account, and remit such fees to Vise on behalf of the client. Direct Indexing Vise provides customizable separately managed accounts that seek to match index returns pre-tax while producing enhanced after-tax returns. These separately managed account portfolios can be customized for tax purposes, to align with investor values and concerns, or a combination of both. Accounts may be actively managed to optimize tax-loss harvesting while providing beta exposure to an index. This type of solution may help investors mitigate tax liability in their portfolios, minimize capital gains, and plan for future taxable events. AQR Capital Management, LLC Vertex Partners expects to use independent manager programs offered through AQR for certain clients with accounts at Charles Schwab. AQR offers “Flex” tax-aware equity strategies in a separately managed account format (“Flex SMAs”). Flex SMAs seek to outperform a designated equity benchmark on a pre-tax basis over a full market cycle while managing realized gains and losses that is intended to enhance after-tax results for taxable investors. Flex SMAs invest primarily in diversified long and short positions in equity securities (including U.S.-listed stocks, exchange-traded funds (“ETFs”), mutual funds and, in some cases, American Depositary Receipts (“ADRs”). They typically target a specified beta, tracking error, and level of long and short “gross” exposure relative to a stated benchmark index such as the Russell 1000 or Russell 3000 Index. Certain Flex SMA implementations employ higher gross exposure and require the client’s account to be approved for options and portfolio margin at the custodian. This allows the Flex strategy to use margin secured by the account’s holdings (including, for “Overlay” implementations, a separate “Collateral Sleeve”) to support the long/short positions implemented by AQR. Use of margin and portfolio margin increases the risk of losses, including the potential for margin calls and forced liquidation of securities and may increase the volatility of the account. The Firm will assist clients in determining whether an AQR Flex SMA is appropriate considering the client’s investment objectives, risk tolerance, tax profile, funding assets (including whether concentrated stock or other legacy positions will be contributed in kind), and the custodian’s account-level eligibility requirements for portfolio margin and options. Clients who participate in the AQR Flex program authorize AQR, as an Independent Manager, to direct the investment and reinvestment of the assets in the AQR-managed portion of their account in accordance with the selected Flex strategy and AQR’s investment guidelines, including the use of leverage through margin. Clients also acknowledge that deviations from target beta, tracking error, and leverage may occur due to market conditions, funding securities, account restrictions, or other factors Page | 9 Wrap Fee Program Brochure Vertex Planning Partners, LLC outside AQR’s control. Vertex Partners expects to collect the AQR Independent Manager fee for Flex SMAs from the client account and remit such fee to AQR on the client’s behalf, in addition to the Firm’s own advisory fee, as disclosed in Item 5 of this Brochure. Use of LPL Programs As described above, the Firm expects to use the following LPL programs. Manager Access Select Program Manager Access Select offers clients the ability to participate in the Separately Managed Account Platform (the “SMA Platform”) or the Model Portfolio Platform (the “MP Platform”). In the SMA Platform, Vertex Partners will assist client in identifying a third party portfolio manager (the Independent Manager) from a list of Independent Managers made available by LPL, and the Independent Manager manages client’s assets on a discretionary basis. Vertex Partners will provide initial and ongoing assistance regarding the Independent Manager selection process. In the MP Platform, clients authorize LPL to direct the investment and reinvestment of the assets in their accounts, in accordance with the selected model portfolio provided by LPL’s Research Department or a third-party investment advisor. A minimum account value of $50,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Vertex Partners will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Vertex Partners will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit a lower minimum account size. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. Vertex Partners will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. Vertex Partners will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department, a third-party portfolio strategist and/or Vertex Partners, through its investment adviser representative, may act as a portfolio strategist responsible for selecting the mutual funds or ETFs within a Page | 10 Wrap Fee Program Brochure Vertex Planning Partners, LLC model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted. Strategic Wealth Management Program (“SWM”) Vertex Partners provides its wrapped services pursuant to this brochure through the SWM Program which allows Vertex Partners to direct and manage specified client assets at LPL. Fees for Participation in the Program Vertex Partners offers services on a fee basis, which includes fixed fees, as well as fees based upon assets under management. Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offers securities brokerage services and/or insurance products under a separate commission-based arrangement. Financial Planning and Consulting Fees Vertex Partners charges a fixed and/or hourly fee for providing financial planning and consulting services under a stand-alone engagement. These fees are negotiable, but range from $500 to $15,000 depending upon the scope and complexity of the services and the professional rendering the financial planning and/or the consulting services. The fee can be for a defined project, such as the delivery of a plan, or for ongoing services. If the client engages the Firm for additional investment advisory services, Vertex Partners can offset all or a portion of its fees for those services based upon the amount paid for the financial planning and/or consulting services. The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory Agreement. For project-based services Vertex Partners requires one-half of the fee (estimated hourly or fixed) payable upon execution of the Advisory Agreement. The outstanding balance is due upon delivery of the financial plan or completion of the agreed upon services. Ongoing services are charged as described in the investment management section, below. The Firm does not, however, take receipt of $1,200 or more in prepaid fees, six or more months in advance of services rendered. Investment Management Fees Vertex Partners offers investment management services for an annual fee based on the amount of assets under the Firm’s management. This management fee varies between 30 and 200 basis points (0.30% – 2.00%), depending upon the size and composition of a client’s portfolio, the type and amount of services Page | 11 Wrap Fee Program Brochure Vertex Planning Partners, LLC rendered and the individual(s) providing the services. The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by Vertex Partners on the last day of the previous quarter as determined by a party independent from the Firm (including the client’s custodian or another third-party). If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), Vertex Partners can negotiate a fee rate that differs from the range set forth above. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Vertex Partners for additional services for compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the recommendations. Any LPL Program referenced above is subject to maximum fees, depending on which program is used. Retirement Plan Consulting Fees Vertex Partners charges as fixed project-based fee to provide clients with retirement plan consulting services. Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor, as memorialized in the Agreement. These fees vary, based on the scope of the services to be rendered, and ranges up to $15,000 per annum on a fixed fee basis depending upon services provided, the person providing the services, and the amount of assets to be advised on. Fee Comparison A portion of the fees paid to Vertex Partners are used to cover the securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios, as well as the fees charged by the Independent Managers engaged to provide services under the Program. Services provided through the Program may cost clients more or less than purchasing these services separately. The number of transactions made in clients’ accounts, as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Fees paid for the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Because the Firm pays for the brokerage fees (even if the brokerage fees are based on assets on the platform and not transaction- based), the Firm has an incentive to engage in less transactions, or transactions that cost less to the Firm, including the use of mutual funds that do not have transaction charges, but have higher expenses to the client. Page | 12 Wrap Fee Program Brochure Vertex Planning Partners, LLC The Firm reviews the frequency and type of investments made in client accounts to act in the client’s best interest. Fee Discretion Vertex Partners may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention, pro bono activities, or competitive purposes. Other Charges In addition to the advisory fees paid to Vertex Partners, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions. These additional charges may include fees charged by the Independent Managers, reporting charges, margin costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund Program Fees and other fund expenses), fees and commission for assets not held with LPL (such as 401(k) or 529 plan assets), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees. In addition, LPL charges certain account and service fees that are not included in Vertex Partners’ Program Fees. Those can include (1) account maintenance fees such as custody, trade confirmation processing, corporate actions, and transfer fees; (2) cash management fees such as cash sweep, checking, and wire fees; and (3) investment specific fees such as those for administration of alternative investments or for foreign securities. Clients can see the Fee Schedules in the LPL account documents for more information. These fees are not charged by Vertex Partners nor does Vertex Partners share in any of these fees. A conflict of interest exists where the Firm avoids expenses by trading through a different Financial Institution or purchases securities that cost the client more, but don’t result in an expense to the Firm. Although clients do not pay a transaction charge for transactions in a SWM account, clients should be aware that Vertex Partners pays LPL transaction charges for those transactions. The transaction charges paid by Vertex Partners vary based on the type of transaction (e.g., mutual fund, equity or ETF) and for mutual funds based on whether or not the mutual fund pays 12b-1 fees and/or recordkeeping fees to LPL. Because Vertex Partners pays the transaction charges in SWM accounts, there is a conflict of interest in cases where the mutual fund is offered at both $0 and $26.50. Clients should understand that this results in an incentive for the Firm to choose a cheaper option or trade less frequently in an SWM account. In many instances, LPL makes available mutual funds in an SWM account that offer various classes of shares, including shares designated as Class A Shares and shares designed for advisory programs, which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share classes (“Platform Shares”). The Platform Share class offered for a particular mutual fund in SWM in many cases will not be the least expensive share class that the mutual fund makes available, Page | 13 Wrap Fee Program Brochure Vertex Planning Partners, LLC and was selected by LPL in certain cases because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund. Client should understand that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through SWM. In other instances, a mutual fund may offer only Class A Shares, but another similar mutual fund may be available that offers Platform Shares. Class A Shares typically pay LPL a 12b- 1 fee for providing shareholder services, distribution, and marketing expenses (“brokerage-related services”) to the mutual funds. Platform Shares generally are not subject to 12b-1 fees. As a result of the different expenses of the mutual fund share classes, it is generally more expensive for a client to own Class A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time, and keep more of his or her investment returns than an investor who holds Class A Shares of the same fund. Vertex Partners has a financial incentive to recommend Class A Shares in cases where both Class A and Platform Shares are available. This is a conflict of interest which might incline Vertex Partners, consciously or unconsciously, to render advice that is not disinterested. Although the client will not be charged a transaction charge for transactions, Vertex Partners pays LPL a per transaction charge for mutual fund purchases and sales in the account. Vertex Partners generally does not pay transaction charges for Class A Share mutual fund transactions accounts, but generally does pay transaction charges for Platform Share mutual fund transactions. The cost to Vertex Partners of transaction charges generally may be a factor Advisor considers when deciding which securities to select and whether or not to place transactions in the account. The lack of transaction charges to Vertex Partners for Class A Share purchases and sales, together with the fact that Platform Shares generally are less expensive for a client to own, presents a significant conflict of interest between Vertex Partners and the client. In short, it costs Vertex Partners less to recommend and select Class A share mutual funds than Platform shares, but Platform shares will generally outperform Class A mutual fund shares on the basis of internal cost structure alone. Clients should understand this conflict and consider the additional indirect expenses borne as a result of the mutual fund fees. Independent Manager fees are not included in the Program Fee and will be charged separately. In addition, certain Independent Managers do not provide services under a wrap relationship so clients will pay brokerage fees (including commissions) on those accounts. Additional LPL Disclosures LPL serves as program sponsor, investment advisor and broker-dealer for most of the LPL advisory programs. Vertex Partners receives compensation as a result of a client’s participation in an LPL program. Depending on, among other things, the type and size of the account, type of securities held in the account, changes in its value over time, the ability to negotiate fees or commissions, the historical or expected size Page | 14 Wrap Fee Program Brochure Vertex Planning Partners, LLC or number of transactions, and the number and range of supplementary advisory and client-related services provided to the client, the amount of this compensation may be more or less than what Vertex Partners would receive if the client participated in other programs, whether through LPL or another sponsor, or paid separately for investment advice, brokerage and other services. The account fee may be higher than the fees charged by other investment advisors for similar services. Clients should consider the level and complexity of the advisory services to be provided when negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with Vertex Partners. With regard to accounts utilizing third-party portfolio managers under aggregate, all-in-one account fee structures, because the portion of the account fee retained by Vertex Partners varies depending on the portfolio strategist fee associated with a portfolio, Vertex Partners has a financial incentive to select one portfolio instead of another portfolio. Please refer to the relevant LPL Form ADV program brochure for a more detailed discussion of conflicts of interest. Direct Fee Debit Clients provide Vertex Partners and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to Vertex Partners. Alternatively, clients may elect to have Vertex Partners send a separate invoice for direct payment for financial planning or consulting services. In certain circumstances, the Firm will take its fee as well as charge the client and debit the client’s account on behalf of third-party Independent Managers, including but not limited to Vestmark, Vise, and AQR, and remit the Independent Manager’s fee to that manager. Account Additions and Withdrawals Clients can make additions to and withdrawals from their account at any time, subject to Vertex Partners’ right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients can withdraw account assets on notice to Vertex Partners, subject to the usual and customary securities settlement procedures. However, the Firm designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Vertex Partners may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Page | 15 Wrap Fee Program Brochure Vertex Planning Partners, LLC Use of Margin Vertex Partners can be authorized by clients to use margin in the management of the client’s investment portfolio. In these cases the fee payable will be assessed gross of margin such that the market value of the client’s account and corresponding fee payable by the client to Vertex Partners will be increased. Where investment management fees are assessed gross of margin, a conflict of interest exists as the Firm has an incentive to use margin to increase its fees. Commissions and Sales Charges for Recommendations of Securities Clients can engage certain persons associated with Vertex Partners (but not the Firm directly) to render securities brokerage services under a separate commission-based arrangement. Clients are under no obligation to engage such persons and may choose brokers or agents not affiliated with Vertex Partners. Under this arrangement, the Firm’s Supervised Persons, in their individual capacities as registered representatives of LPL Financial (“LPL”), can provide securities brokerage services and implement securities transactions under a separate commission based arrangement. Supervised Persons are entitled to a portion of the brokerage commissions paid to LPL, as well as a share of any ongoing distribution or service (trail) fees from the sale of mutual funds. Vertex Partners can also recommend no-load or load-waived funds, where no sales charges are assessed, but where the Supervised Person receives other forms of compensation. Prior to effecting any transactions, clients are required to enter into a separate account agreement with LPL. A conflict of interest exists to the extent that a Supervised Person of Vertex Partners recommends the purchase or sale of securities through a brokerage relationship where that Supervised Persons receives commissions or other additional compensation as a result of that recommendation (the “Brokerage Relationship”). Because the Supervised Persons receive compensation in connection with the sale of securities in the Brokerage Relationship, a conflict of interest exists as such Supervised Persons, have an incentive to recommend more expensive securities or services to clients where such Supervised Persons earn more compensation with respect to the sale of such securities through the Brokerage Relationship rather than through an advisory relationship with the Firm. The Firm has procedures in place to ensure that any recommendations made by such Supervised Persons to engage in the Brokerage Relationship are in the best interest of that client. Clients should understand that the investments made in the Brokerage Relationship are not receiving advisory services from the Firm. Therefore, the Firm does not have a fiduciary duty over the Brokerage Relationship recommendations. Additional LPL Disclosures LPL serves as program sponsor, investment advisor and broker-dealer for most of the LPL advisory programs. Page | 16 Wrap Fee Program Brochure Vertex Planning Partners, LLC Vertex Partners receives compensation as a result of a client’s participation in an LPL program. Depending on, among other things, the type and size of the account, type of securities held in the account, changes in its value over time, the ability to negotiate fees or commissions, the historical or expected size or number of transactions, and the number and range of supplementary advisory and client-related services provided to the client, the amount of this compensation may be more or less than what Vertex Partners would receive if the client participated in other programs, whether through LPL or another sponsor, or paid separately for investment advice, brokerage and other services. Clients should consider the level and complexity of the advisory services to be provided when negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with Vertex Partners. With regard to accounts utilizing third-party portfolio managers under aggregate, all-in-one account fee structures, because the portion of the account fee retained by Vertex Partners varies depending on the portfolio strategist fee associated with a portfolio, Vertex Partners has a financial incentive to select one portfolio instead of another portfolio. Please refer to the relevant LPL Form ADV program brochure for a more detailed discussion of conflicts of interest. Compensation for Recommending the Program Vertex Partners has no internal arrangements in place whereby persons recommending the Program are entitled to receive additional compensation as a result of clients’ participation. A person recommending the Program will not earn more compensation than he or she would otherwise receive if a client elected another investment management program. Item 5. Account Requirements and Types of Clients Vertex Partners offers services to individuals, trusts, estates, charitable organizations, corporations and other business entities, and retirement and profit sharing plans. While the Firm does not have a stated minimum fee or account size, certain LPL programs and Independent Managers will impose minimums. Item 6. Portfolio Manager Selection and Evaluation Clients’ investment portfolios are managed either directly by Vertex Partners or through the use of certain Independent Managers, as referenced above. Side-By-Side Management Vertex Partners does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Page | 17 Wrap Fee Program Brochure Vertex Planning Partners, LLC Methods of Analysis and Investment Strategies Vertex Partners believes the foundation of proper investment management stems from the understanding of client goals and objectives prior to making any investment recommendation. When recommending a portfolio strategy, Vertex Partners recognizes the importance of asset allocation and diversification, but also considers the principles of behavioral finance and the impact of investor psychology and biases. Vertex Partners maintains a series of portfolios that are recommended to clients as appropriate to the client’s preference, risk tolerance, and risk capacity. Each portfolio’s risk, return, and liquidity are in large part a function of the asset classes that are included in the portfolio. Vertex Partners utilizes third party strategies along with internally constructed model portfolios. The Firm’s models typically will employee both active and passive management strategies, as well as invest via Mutual Funds, Exchange-Traded Funds, Independent Managers, as well as Interval Funds. For clients in higher tax brackets, Vertex Partners may utilize individual equities and municipal bonds. Technology allows Vertex Partners to generate rebalancing reviews for all clients based upon predetermined tolerance bands and each individual client’s unique needs. Vertex Partners considers the tax ramifications and trading costs before rebalancing. In taxable accounts, it may make sense to do only a partial rebalance or retain non-model holdings based on the client’s personal tax consequences. Third Party Investment Strategies Vertex Partners researches investment managers and strategist and provides client access to these strategies through our portfolio management and trading technology. The due diligence process incorporates qualitative review of the investment team, their philosophy and process. This analysis is complemented with quantitate analysis of the manager’s past performance and portfolio risks. VPP monitors and maintains updated information on the investment managers and funds through routine due diligence efforts. Model Management Vertex Partners model management is designed to maximize operational efficiencies for the Firm’s clients and advisors, and provide portfolio customization. It centralizes the delivery and manufacturing of proprietary and third-party model portfolios across asset classes. Vertex Partners relies on proprietary and vended applications to assist in the ongoing management of these strategies. Risk of Loss The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved with respect to the Firm’s investment management activities. Clients should consult with their legal, tax, and other advisors before engaging the Firm to provide investment management services on their behalf. Page | 18 Wrap Fee Program Brochure Vertex Planning Partners, LLC Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of Vertex Partners’ recommendations and/or investment decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. In addition, investments may be adversely affected by financial markets and economic conditions throughout the world. There can be no assurance that Vertex Partners will be able to predict these price movements accurately or capitalize on any such assumptions. Volatility Risks The prices and values of investments can be highly volatile, and are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, the financial condition of the issuers of such assets, changing supply and demand relationships, and programs and policies of governments. Cash Management Risks The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of investments, during which time an advisory account may be prevented from achieving its investment objective. Equity-Related Securities and Instruments The Firm (through the Independent Managers recommended) may take long positions in common stocks of U.S. and non-U.S. issuers traded on national securities exchanges and over-the-counter markets. The value of equity securities varies in response to many factors. These factors include, without limitation, factors specific to an issuer and factors specific to the industry in which the issuer participates. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments, and the stock prices of such companies may suffer a decline in response. In addition, equity securities are subject to stock risk, which is the risk that stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced periods of substantial price volatility in the past and may do so again in the future. In addition, investments in small-capitalization, midcapitalization and financially distressed companies may be subject to more abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers often face greater business risks. Fixed Income Securities While the Firm emphasizes risk-averse management and capital preservation in its fixed-income bond portfolios, clients who invest in this product can lose money, including losing a portion of their original investment. The prices of the securities in our portfolios fluctuate. The Firm does not guarantee any particular level of performance. Below is a representative list of the types of risks clients should consider before investing in this product. Page | 19 Wrap Fee Program Brochure Vertex Planning Partners, LLC • Interest rate risk. Prices of bonds tend to move in the opposite direction to interest rate changes. Typically, a rise in interest rates will negatively affect bond prices. The longer the duration and average maturity of a portfolio, the greater the likely reaction to interest rate moves. • Credit (or default) risk. A bond’s price will generally fall if the issuer fails to make a scheduled interest or principal payment, if the credit rating of the security is downgraded, or if the perceived creditworthiness of the issuer deteriorates. • Liquidity risk. Sectors of the bond market can experience a sudden downturn in trading activity. When there is little or no trading activity in a security, it can be difficult to sell the security at or near its perceived value. In such a market, bond prices may fall. • Call risk. Some bonds give the issuer the option to call or redeem the bond before the maturity date. If an issuer calls a bond when interest rates are declining, the proceeds may have to be reinvested at a lower yield. During periods of market illiquidity or rising rates, prices of callable securities may be subject to increased volatility. • Prepayment risk. When interest rates fall, the principal of mortgage-backed securities may be prepaid. These prepayments can reduce the portfolio’s yield because proceeds may have to be reinvested at a lower yield. • Extension risk. When interest rates rise or there is a lack of refinancing opportunities, prepayments of mortgage-backed securities or callable bonds may be less than expected. This would lengthen the portfolio’s duration and average maturity and increase its sensitivity to rising rates and its potential for price declines. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at Page | 20 Wrap Fee Program Brochure Vertex Planning Partners, LLC least once daily for index-based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Use of Independent Managers As stated above, Vertex Partners selects certain Independent Managers to manage a portion of its clients’ assets. In these situations, Vertex Partners continues to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, Vertex Partners does not have the ability to supervise the Independent Managers on a day-to-day basis. Management through Similarly Managed “Model” Accounts Vertex Partners manages certain accounts through the use of similarly managed “model” portfolios, whereby the Firm allocates all or a portion of its clients’ assets among various mutual funds and/or securities on a discretionary basis using one or more of its proprietary investment strategies. In managing assets through the use of models, the Firm remains in compliance with the safe harbor provisions of Rule 3a-4 of the Investment Company Act of 1940. The strategy used to manage a model portfolio may involve an above average portfolio turnover that could negatively impact clients’ net after tax gains. While the Firm seeks to ensure that clients’ assets are managed in a manner consistent with their individual financial situations and investment objectives, securities transactions effected pursuant to a model investment strategy are usually done without regard to a client’s individual tax ramifications. Clients should contact the Firm if they experience a change in their financial situation or if they want to impose reasonable restrictions on the management of their accounts. Use of Margin While the use of margin borrowing for investments can substantially improve returns, it may also increase overall portfolio risk. Margin transactions are generally effected using capital borrowed from a Financial Institution, which is secured by a client’s holdings. Under certain circumstances, a lending Financial Institution may demand an increase in the underlying collateral. If the client is unable to provide the additional collateral, the Financial Institution may liquidate account assets to satisfy the client’s outstanding obligations, which could have extremely adverse consequences. In addition, fluctuations in the amount of a client’s borrowings and the corresponding interest rates may have a significant effect on the profitability and stability of a client’s portfolio. For certain clients, the Firm utilizes AQR Flex separately managed account strategies, some of which employ significant leverage using margin and, in some cases, portfolio margin at the custodian. These strategies generally seek to maintain a leveraged “gross” exposure through long and short positions in equity Page | 21 Wrap Fee Program Brochure Vertex Planning Partners, LLC securities and related instruments while targeting a specified beta and tracking error to an equity benchmark. However, actual leverage and risk exposures may deviate from these targets due to market conditions, the composition or margin-ability of funding securities, client-imposed restrictions, or other factors. Since these strategies rely on margin, and portfolio margin where applicable, adverse market movements can lead to amplified losses, margin calls, and potential forced liquidation of securities by the custodian, which may occur at unfavorable prices and have adverse tax consequences for the client. Where an “overlay” implementation is used, a portion of the account may function as a collateral sleeve that is not managed by AQR but is pledged to support the AQR-managed long/short positions, exposing the client to the risk that declines in the value or margin-ability of the collateral sleeve may impair AQR’s ability to maintain the strategy and increase the likelihood of margin calls or forced de-leveraging. Currency Risks An advisory account that holds investments denominated in currencies other than the currency in which the advisory account is denominated may be adversely affected by the volatility of currency exchange rates. Interest Rate Risks Interests rates may fluctuate significantly, causing price volatility with respect to securities or instruments held by clients. Use of Structured Products Structured products involve derivatives and a higher degree of risk factors that may not be suitable for all investors. Such risks include risk of adverse or unanticipated market developments, issuer credit quality risk, risk of counterparty or issuer default, risk of lack of uniform standard pricing, risk of adverse events involving any underlying reference obligations, entity or other measure, risk of high volatility, and risk of illiquidity/ little to no secondary market. In certain transactions, investors may lose their entire investment, i.e., incur an unlimited loss. Voting of Client Securities Vertex Partners does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are custodied and may contact the Firm at the contact information on the cover of this brochure with questions about any such issuer solicitations. Item 7. Client Information Provided to Portfolio Managers In this Item, Vertex Partners is required to describe the type and frequency of the information it communicates to the Independent Managers, if any, managing its clients’ investment portfolios. Clients participating in the Program generally grant Vertex Partners the authority to discuss certain non-public information with the Independent Managers engaged to manage their accounts. Depending upon the Page | 22 Wrap Fee Program Brochure Vertex Planning Partners, LLC specific arrangement, the Firm may be authorized to disclose various personal information including, without limitation: names, phone numbers, addresses, social security numbers, tax identification numbers and account numbers. Vertex Partners may also share certain information related to its clients’ financial positions and investment objectives in an effort to ensure that the Independent Managers’ investment decisions remain aligned with its clients’ best interests. This information is communicated on an initial and ongoing basis, or as otherwise necessary to the management of its clients’ portfolios. Item 8. Client Contact with Portfolio Managers In this Item, Vertex Partners is required to describe any restrictions on clients’ ability to contact and consult with the portfolio managers managing their investment portfolios. There are no restrictions on clients’ ability to correspond with Vertex Partners. Clients can generally contact the Independent Managers managing their portfolios through Vertex Partners by providing the Firm with written request and identification of the questions or issues to be discussed with the Independent Managers. After receiving the client’s written request, Vertex Partners, at its sole discretion, may contact the Independent Managers for the client or arrange for the Independent Managers and the client to communicate directly. Item 9. Additional Information Disciplinary Information Vertex Partners has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. Other Financial Industry Activities and Affiliations This item requires investment advisers to disclose certain financial industry activities and affiliations. Registered Representatives of a Broker-Dealer Certain of the Firm’s Supervised Persons are registered representatives of LPL and provide clients with securities brokerage services under a separate commission-based arrangement. This arrangement is described at length in Item 5. Licensed Insurance Agents A number of the Firm’s Supervised Persons are licensed insurance agents and offer certain insurance products on a fully-disclosed commissionable basis. This can be done individually or as agents of another insurance agency, including LPL. A conflict of interest exists to the extent that Vertex Partners recommends the purchase of insurance products where its Supervised Persons are entitled to insurance commissions or other additional compensation. The Firm has procedures in place whereby it seeks to ensure that all Page | 23 Wrap Fee Program Brochure Vertex Planning Partners, LLC recommendations are made in its clients’ best interest regardless of any such affiliations. Accounting/CPA Firm Affiliation Certain of the Firm’s Supervised Persons are owners and affiliated with Vertex Accounting Partners, LLC. From time to time, they may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. The Firm always acts in the best interest of the client and clients always have the right to decide whether or not to utilize the services of any Firm representative in such individual’s outside capacities. Fees from Independent Managers As discussed above, Vertex Partners recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain Independent Managers. In certain circumstances the Firm’s compensation is included in the advisory fee charged by such Independent Managers. There is a conflict of interest to choose such Independent Managers; however, Vertex Partners evaluates Independent Managers objectively and not based on the amount of compensation it may receive from a particular Independent Manager. Code of Ethics Vertex Partners has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Vertex Partners’ Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of Vertex Partners’ personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless: • the transaction has been completed; • the transaction for the Supervised Person is completed as part of a batch trade with clients; or Page | 24 Wrap Fee Program Brochure Vertex Planning Partners, LLC • a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by money market funds; and iv) shares issued by other unaffiliated open-end mutual funds. Clients and prospective clients may contact Vertex Partners to request a copy of its Code of Ethics by contacting the Firm at the phone number on the cover page of this brochure. Account Reviews Vertex Partners monitors client portfolios on a continuous and ongoing basis and regular account reviews are conducted on at least an annual basis. Such reviews are conducted by the client’s investment adviser representative(s) as well as cash reviews and drift reports by the Firm. All investment advisory clients are encouraged to discuss their needs, goals and objectives with Vertex Partners and to keep the Firm informed of any changes thereto. Account Statements and General Reports Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from Vertex Partners and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from Vertex Partners or an outside service provider. Client Referrals The Firm does not currently provide compensation to any third-party solicitors for client referrals. Receipt of Economic Benefit and Brokerage Practices Vertex Partners recommends that clients utilize the custody, brokerage and clearing services of LPL and/or Charles Schwab & Co., Inc. (“Schwab” and together with LPL, "Custodians") for investment management accounts. The final decision to custody assets with the Custodians is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. Because of the relationship between the Firm and LPL, the Firm may require clients to engage LPL for the brokerage and clearing services. The Custodians are generally compensated by clients through commissions, trails, or other transaction- based fees for trades that are executed through the Custodians or that settle into Custodians’ accounts. For Page | 25 Wrap Fee Program Brochure Vertex Planning Partners, LLC IRA accounts, LPL generally charges account maintenance fees. In addition, the Custodians can also charge clients miscellaneous fees and charges, such as account transfer fees. LPL charges Vertex Partners an asset- based administration fee for administrative services provided by LPL. Such administration fees are not directly borne by clients, but may be taken into account when Vertex Partners negotiates its advisory fee with clients. For a description of fees and charges that are not included in the Firm’s fees under the Program, see the “Other Charges” section in Item 4, above. Factors which Vertex Partners considers in recommending the Custodians or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. The Firm’s recommendation of Custodians complies with the Firm’s duty to obtain “best execution.” In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because Vertex Partners does not have to produce or pay for the products or services. Vertex Partners periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Vertex Partners receives support services and/or products from Custodians, many of which assist the Firm to better monitor and service program accounts maintained at Custodians; however, some of the services and products benefit Vertex Partners and not client accounts. These support services and/or products may be received without cost, at a discount, and/or at a negotiated rate, and may include the following from one or more of Custodians: • investment-related research • pricing information and market data • software and other technology that provide access to client account data • compliance and/or practice management-related publications • consulting services • attendance at conferences, meetings, and other educational and/or social events • marketing support • computer hardware and/or software • other products and services used by the Firm in furtherance of its investment advisory business operations Page | 26 Wrap Fee Program Brochure Vertex Planning Partners, LLC Custodians may provide these services and products directly, or may arrange for third party vendors to provide the services or products to Vertex Partners. In the case of third party vendors, Custodians may pay for some or all of the third party’s fees. These support services are provided to Vertex Partners based on the overall relationship between Vertex Partners and Custodians. It is not the result of soft dollar arrangements or any other express arrangements with Custodians that involves the execution of client transactions as a condition to the receipt of services. Vertex Partners will continue to receive the services regardless of the volume of client transactions executed with Custodians. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by the Vertex Partners to Custodians or any other entity to invest any specific amount or percentage of client assets in any specific securities as a result of the arrangement. However, because Vertex Partners receives these benefits from Custodians, there is a conflict of interest. The receipt of these products and services presents a financial incentive for Vertex Partners to recommend that its clients use Custodians’ custodial platform rather than another custodian’s platform. Custodians also make available to Vertex Partners other services intended to help the Firm manage and further develop its business. Some of these services assist Vertex Partners to better monitor and service program accounts maintained at Custodians, however, many of these services benefit only Vertex Partners, for example, services that assist the Firm in growing its business. These support services and/or products may be provided without cost, at a discount, and/or at a negotiated rate, and include practice management- related publications; consulting services; attendance at conferences and seminars, meetings, and other educational and/or social events; marketing support; and other products and services used by Vertex Partners in furtherance of the operation and development of its investment advisory business. The products and services described above are provided to Vertex Partners as part of its overall relationship with Custodians. While as a fiduciary Vertex Partners endeavors to act in its clients’ best interests, the receipt of these benefits creates a conflict of interest because the Firm’s recommendation that clients custody their assets at LPL is based in part on the benefits received and not solely on the nature, cost or quality of custody or brokerage services provided by Custodians. Vertex Partners’ receipt of some of these benefits may be based on the amount of advisory assets custodied on the Custodians’ platforms. Charles Schwab & Co. Inc. Disclosures There is no direct link between Vertex Partners’ participation in Schwab’s institutional customer program and the investment advice it gives to its clients, although Vertex Partners receives economic benefits through its participation in the program that are typically not available to Schwab retail investors. Additionally, Vertex Partners may receive the following benefits from Schwab through its registered investment adviser division: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its Registered Investment Adviser participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and access to an electronic communication network for client order entry and account information. The Firm also has the ability deduct advisory fees directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual Page | 27 Wrap Fee Program Brochure Vertex Planning Partners, LLC funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to the Firm by third party vendors. Schwab may fund business consulting and professional services received by Vertex Partners’ related persons. Some of the products and services made available by Schwab through the program may benefit Vertex Partners but not its client. These products or services may assist Vertex Partners in managing and administering client accounts, including accounts not maintained at Schwab. Other services made available by Schwab are intended to help Vertex Partners manage and further develop its business enterprise. The benefits received by Vertex Partners’ participation in the program do not depend on the amount of brokerage transactions directed to Schwab. Loans and Other Benefits Received by the Firm or Supervised Persons from LPL The Firm receives other benefits from LPL. Some of the benefits are available to any investment adviser utilizing LPL services. Others may only be available due to the Firm’s relationship with LPL LPL has and will provide forgivable loans to certain Supervised Persons of the Firm. The loan payments repayable by the Supervised Persons are forgiven over time so there is an incentive for the Firm to maintain its relationship with LPL as custodian for advisory clients as well as the Supervised Persons maintaining their registered representative status in their individual capacity. LPL will also provide the Firm with financing in order to purchase other advisory businesses or recruit investment adviser representatives. The receipt of the loans and financing creates conflicts of interest relating to Vertex Partners’ advisory business because it creates a financial incentive for the Firm and its Supervised Persons to recommend clients maintain their advisory or brokerage accounts with LPL. Vertex Partners seeks to mitigate these conflicts of interest by evaluating LPL's services to determine that the recommendation to use LPL is based on the benefits that such services provide to clients, rather than the benefits received by the Firm or its Supervised Person. As set forth above, the Firm periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution, including its recommendation of LPL. However, clients should be aware of this conflict and take it into consideration in making a decision whether to custody their assets with LPL through Vertex Partners, or open a brokerage account with a Supervised Person as a registered representative at LPL. Commissions or Sales Charges for Recommendations of Securities As discussed above, certain Supervised Persons in their respective individual capacities are registered representatives of LPL. These Supervised Persons are subject to FINRA Rule 3280 which restricts registered representatives from conducting securities transactions away from their broker-dealer unless the registered representatives give prior notice of such transactions to LPL and, in most circumstances, LPL provides written consent. Therefore, clients are advised that certain Supervised Persons are restricted to conducting securities transactions through LPL if they have not secured written consent from LPL to execute securities transactions though a different broker-dealer. Absent such written consent or separation Page | 28 Wrap Fee Program Brochure Vertex Planning Partners, LLC from LPL, these Supervised Persons are generally prohibited from executing securities transactions through any broker-dealer other than LPL under its internal supervisory policies. In addition, LPL is responsible for supervising certain activities of Vertex Partners to the extent Vertex Partners manages assets at a broker/dealer and custodian other than LPL. LPL charges a fee to Vertex Partners for this oversight. This presents a conflict of interest in that Vertex Partners has a financial incentive to recommend that clients maintain their accounts with LPL rather than another custodian in order to avoid the oversight fee. The Firm is cognizant of its duty to obtain best execution and has implemented policies and procedures reasonably designed in such pursuit. LPL may have access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about Vertex Partners’ clients, even if client does not establish any account through LPL. Trade Aggregation Transactions for each client will be effected independently, unless Vertex Partners decides to purchase or sell the same securities for several clients at approximately the same time. Vertex Partners may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among Vertex Partners’ clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which Vertex Partners’ Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Vertex Partners does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Page | 29 Wrap Fee Program Brochure Vertex Planning Partners, LLC Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Custody Vertex Partners is deemed to have custody of client funds and securities because the Firm is given the ability to debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained at one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such qualified custodians will send account statements to clients at least once per calendar quarter that typically detail any transactions in such account for the relevant period. In addition, as discussed in Item 13, Vertex Partners will also send, or otherwise make available, periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from Vertex Partners. Any other custody disclosures can be found in the Firm’s Form ADV Part 1. Vertex Partners also has custody due to clients giving the Firm limited power of attorney in a standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February 21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii) client will authorize the Firm to direct transfers to the specific third party; iii) the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have no authority or ability to designate or change the identity or any information about the third party; vi) the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the SLOA instructions. Financial Information Vertex Partners is not required to disclose any financial information due to the following: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. Page | 30