VISIONARY HORIZONS, LLC

Cover Page - Item 1 Visionary Horizons, LLC 620 Mabry Hood Road, Suite 301 Knoxville, TN 37932 Phone (865) 675-VHWM (8496) Email Info@VisionaryHorizons.com February 10, 2026 Form ADV Part 2A Brochure Visionary Horizons, LLC dba Visionary Horizons Wealth Management (hereinafter “VH”) is a registered investment adviser. An "investment adviser" means any person who, for compensation, engages in the business of advising others, either directly or through publications or writings, as to the value of securities or as to the advisability of investing in, purchasing, or selling securities, or who, for compensation and as part of a regular business, issues or promulgates analyses or reports concerning securities. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. This brochure provides information about the qualifications and business practices of Visionary Horizons, LLC. If you have any questions about the contents of this brochure, please contact us at (865) 675-VHWM (8496) and/or Info@VisionaryHorizons.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. information about Visionary Horizons, LLC is available on the SEC’s website at Additional www.adviserinfo.sec.gov.  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 2 Material Changes - Item 2 The purpose of this page is to inform you of any material changes since the previous version of this brochure. We review and update our brochure at least annually to make sure that it remains current. On February 10, 2026, we filed our annual updating amendment for fiscal year end 2025. We have updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management of approximately $370,905,975, and non-discretionary assets under management of approximately $25,800,717. We also amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Direct Indexing, Political Risk and Artificial Intelligence ("AI") Risk.  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 3 Table of Contents - Item 3 Contents Cover Page - Item 1 ................................................................................................................................... 1 Material Changes - Item 2 ......................................................................................................................... 2 Table of Contents - Item 3 ........................................................................................................................ 3 Advisory Business - Item 4 ........................................................................................................................ 4 Fees and Compensation - Item 5 .............................................................................................................. 9 Performance-Based Fees and Side-By-Side Management - Item 6 ........................................................ 14 Types of Clients - Item 7.......................................................................................................................... 14 Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 ................................................... 14 Disciplinary Information - Item 9 ............................................................................................................ 18 Other Financial Industry Activities or Affiliations - Item 10 .................................................................... 18 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ........... 19 Brokerage Practices - Item 12 ................................................................................................................. 20 Review of Accounts - Item 13 ................................................................................................................. 26 Client Referrals and Other Compensation - Item 14 .............................................................................. 27 Custody - Item 15 .................................................................................................................................... 28 Investment Discretion - Item 16 ............................................................................................................. 28 Voting Client Securities - Item 17 ........................................................................................................... 29 Financial Information - Item 18 .............................................................................................................. 29 Requirements of State-Registered Advisers - Item 19 ............................................................................ 29 Miscellaneous ......................................................................................................................................... 29  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 4 Advisory Business - Item 4 Visionary Horizons, LLC (hereinafter “VH”) is a registered investment adviser based in Knoxville, Tennessee. VH has been offering advisory services since 2009. Roger E. Kiger is the principal owner of VH. The following paragraphs describe our services and fees. Also, you may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who provides investment advice on behalf of our firm. Where required, such persons are properly licensed or registered as investment adviser representatives. Portfolio Management Services Our firm offers continuous discretionary and non-discretionary portfolio management services to our clients. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in your account without contacting you. These decisions are made based upon your stated investment objectives. Non-discretionary portfolio management service means that we must obtain your approval prior to making any transactions in your account. Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals, and decide how much risk you should take in your investments. The information we gather will help us implement an asset allocation strategy that will be specific to your goals, whether we are actively investing for you or simply providing you with advice. VH mainly uses equity securities, corporate debt securities, municipal debt securities, certificates of deposit, exchange traded funds, mutual funds, U.S. government securities and options in its portfolio management programs. When suitable, we may also use private placements and alternative investments. In some cases, and depending on the needs of the client, portfolio management services will be provided in conjunction with a sub-adviser. The sub-adviser will use proprietary model portfolios developed by the sub-adviser and/or other registered investment advisers to manage all or a portion of the client’s account. In these cases, the sub-adviser will be responsible for investment decisions on accounts delegated to their management. VH will responsible for the supervision of the account, portfolio reallocations and rebalancing, and ongoing client interaction and servicing. We will monitor your portfolio’s performance on a continuous basis and rebalance the portfolio whenever necessary, as changes occur in market conditions, your financial circumstances, or both. Management of Held Away Assets As part of our overall portfolio management services, we provide asset allocation review, rebalancing, and management services for accounts that are not held in custody by the qualified custodian(s)  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 5 recommended by our firm. These services are provided through the account aggregation services of Pontera (formerly FeeX) and Absolute Capital. The service primarily applies to ERISA and non-ERISA plan assets such as 401(k)s and 403(b)s, and other assets that must be held in custody by the plan custodian(s). We regularly review the available investment options in these accounts, monitor them, and periodically rebalance and implement our strategies using different tools as necessary. If you elect to allow our firm to manage your assets through Pontera and/or Absolute Capital, you will be notified via email when VH places trades in your held away account. We recommend that you review the statement(s) you receive from the qualified custodian. Please call our office number, located on the cover page of this brochure, if you have any questions about your statement. • Financial Planning and Consulting Services We offer broad based financial planning and consulting services, including tax planning, insurance planning, estate planning, disability planning, business planning, retirement planning, education planning, and budgeting and cash flow analysis. VH strives to achieve a client’s long-term financial goals by implementing a financial planning process that may include any or all of the following steps: • Assessment of a client’s present financial situation by collecting information regarding net worth and cash flow statements, tax returns, insurance policies, investment portfolios, pension plans, employee benefit statements etc. Identification of a client’s financial and personal goals and objectives. Goals or objectives may include financing a child’s college education or retirement planning. The identified goals or objectives are specific, realistic, and measurable. All goals include time horizons. • Resolution of finance related problems. Obstacles to achieving financial independence are identified so that resolution may occur. Examples of problem areas can include too little or too much insurance coverage, inadequate cash flow or a high tax burden. • Plan Design. A written financial plan is prepared that includes recommendations and solutions • to any financial related problems. Implementation of the financial plan. The financial plan is finalized and agreed upon. The recommendations and solutions are executed to reach the desired goals and objectives. • Evaluation of the financial plan is conducted periodically. The financial planning service provides the option of conducting a periodic review and revision of the plan to ensure that the financial goals are achieved. The client may be required to pay an additional fee to exercise this option. Financial plans are based on your financial situation and the financial information you provide to our firm. If your financial situation, goals, objectives, or needs change, you must notify us promptly. We also provide financial planning services that cover a specific area, such as retirement or estate planning. We offer consultative services where we set an appointment to meet with you for financial planning advice for an hourly fee.  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 6 You may choose to accept or reject our recommendations. If you decide to proceed with our recommendations, you may do so either through our investment advisory services or by using the advisory/brokerage firm of your choice. Selection of Third-Party Investment Advisers VH has entered into agreements with various third-party investment advisers (“TPAs”) for the provision of certain investment advisory services. Factors considered in the selection of a TPA include but are not limited to: i) VH’s preference for a particular third-party adviser; ii) the client’s risk tolerance, goals and objectives, as well as investment experience; and, iii) the TPA’s specialization in specific types of investments. In order to assist clients in the selection of a TPA, an Associated Person of VH will typically gather information from the client about the client’s financial situation, investment objectives, and reasonable restrictions the client wants imposed on the management of the account. Generally, securities transactions will be decided upon and executed by the TPA on a discretionary basis. This means that the manager selected will have the ability to buy and sell securities in your account without obtaining your approval. VH and its Associated Persons will not manage, or obtain discretionary authority over the assets in accounts participating in these programs; however, clients may grant VH the discretionary authority to hire and fire such third party managers. Generally, clients may not impose restrictions on investing in certain securities or types of securities in accounts managed by a TPA. Associated Persons of VH will periodically review reports provided to the client. An Associated Person of VH will contact the client at least annually, or more often as agreed upon with each client, to review the client’s financial situation and objectives, communicate information to the TPA managing the account as necessary, and to assist the client in understanding and evaluating the services provided by the TPA. Clients will be expected to notify VH of any changes in their financial situation, investment objectives, or account restrictions. The TPA may offer wrapped or non-wrapped pricing options. Wrap pricing structures allow the client to pay an all-inclusive fee for management, brokerage, clearance, custody and administrative services. Transaction costs may also be charged for the execution and clearance of advisory transactions directed by such TPA. A complete description of the programs and services provided, the amount of total fees, the payment structure, termination provisions and other aspects of each program are detailed and disclosed in: i) the TPA’s Form ADV Part 2A; ii) the program wrap brochure (if applicable) or other applicable disclosure documents; iii) the disclosure documents of the portfolio manager(s) selected; or, iv) the TPA’s account opening documents. A copy of all relevant disclosure documents of the TPA and of the individual portfolio manager(s) will be provided to anyone invested in these programs/managers.  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 7 Qualified Retirement Plan Advisory Services VH provides consulting and advisory services for employer-sponsored retirement plans in accordance with the Employee Retirement Income Security Act (“ERISA”). When providing these services, VH will act as a fiduciary under ERISA Section 3(21) or Section 3(38) depending on the scope of services negotiated with the client. When delivering ERISA services, we act in good faith and with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. VH is registered as an investment advisor and represents that it is not subject to any disqualification as set forth in Employee Retirement Income Security Act of 1974 (“ERISA”) Section 411. Generally, services provided under the VH’s qualified retirement plan consulting and fiduciary services, include, but are not limited to: • Assisting the Plan Administrator/Plan Sponsor in the development of an Investment Policy Statement (“IPS”) that establishes the investment policies and objectives for the Plan. The Plan Administrator/Plan Sponsor shall have the ultimate responsibility and authority to adopt and amend the Plan’s IPS; • Assisting the Plan Administrator/Plan Sponsor in defining the goals and objectives for the • • • administration of the Plan and in the Plan Administrator/Plan Sponsor’s shaping the IPS to the demographics of the participant census; If selected to provide Section 3(21) investment advisor services, VH will provide non- discretionary investment advice to the Plan Administrator/Plan Sponsor about asset classes and investment alternatives available to the Plan in accordance with the Plan’s investment policies and objectives. By providing non-discretionary investment advice, VH acts in the capacity of an ERISA Section 3(21) fiduciary and does NOT act in the capacity of an ERISA Section 3(38) fiduciary and, further, does not choose investment selections. VH merely provides advice and recommendations to the Plan Trustee(s) regarding Plan investment options. The Plan Administrator/Plan Sponsor shall have the final decision–making authority regarding the initial selection, retention, removal, and addition of Plan investment options. VH will assist the Plan Trustee(s) with the Plan Trustee (s’) selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder; If selected to provide Section 3(38) investment management services, VH will provide discretionary investment management to the Plan Administrator/Plan Sponsor about asset classes and investment alternatives available to the Plan in accordance with the Plan’s investment policies and objectives. By providing discretionary investment management, VH acts in the capacity of an ERISA Section 3(38) fiduciary, thereby making reasonable investment decisions on behalf of the Plan Trustee(s). These reasonable investment decisions shall include the initial selection, retention, removal, and addition of Plan investment options. Any selection of investment options shall be diverse and broad as well as in compliance with ERISA Section 404(c) and the regulations thereunder; If selected to provide Section 3(21) investment advisor services, VH will provide non- discretionary investment advice to the Plan Administrator/Plan Sponsor with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 8 • otherwise fail to make an investment election. The Plan Administrator/Plan Sponsor acknowledges that it is responsible for determining whether the Plan should have a QDIA and deciding upon the type of investment that will serve as a QDIA (e.g., target date, fund, balanced fund, or managed account), as permitted by ERISA Section 404(c)(5) and the regulations promulgated thereunder. Once the Plan Administrator/Plan Sponsor has made that determination, VH will assist the Plan Sponsor in selecting the investments to serve as the QDIA. The Plan Administrator/Plan Sponsor retains the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5); If selected to provide Section 3(38) investment management services, VH will provide discretionary investment management to the Plan Administrator/Plan Sponsor with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who otherwise fail to make an investment election. As a 3(38), VH shall decide upon the type of investment that will serve as a QDIA (e.g., target date, fund, balanced fund, or managed account), as permitted by ERISA Section 404(c)(5) and the regulations promulgated thereunder. Once chosen by VH, then VH shall select the investments to serve as the QDIA. The Plan Administrator/Plan Sponsor retains the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5); • VH will keep the Plan Administrator/Plan Sponsor informed of any search for investment managers/funds to replace or fill asset class gaps in accordance with the IPS. The Plan Administrator/Plan Sponsor shall have the final decision–making authority regarding the initial selection, retention, removal, and addition of investment options, if VH is operating as a Section 3(21) investment advisor; otherwise, as a Section 3(38) investment manager, VH shall have the final decision–making authority regarding the initial selection, retention, removal and addition of investment options; • VH will assist the Plan Trustee(s) in the Plan Trustee(‘s)(s’) monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management, and conformance to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options; and • VH will meet with the Plan Administrator/Plan Sponsor on a professionally reasonable periodic basis, not less than annually but not more frequently than quarterly, to discuss Plan administration reports and Plan operational issues. VH also provides non fiduciary services to the plan. These services include, but are not limited to, Plan Support Services, Recordkeeper & Third-Party Administration Selection and monitoring, Conversion Services, Fiduciary and Non-Fiduciary Planning Services to Plan Participants and certain recordkeeping services. Each Plan’s specific services will vary. However, all services will be outlined in the executed Retirement Plan Service Agreement. Assets Under Management As of December 31, 2025, we manage approximately $370,905,975 on a discretionary basis and $25,800,717 on a non-discretionary basis.  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 9 Fees and Compensation - Item 5 Portfolio Management Services Fees For portfolio management services, VH charges an annual fee based upon a percentage of the market value of assets under management. Fees will be subject to the following fee schedule: Assets Under Management $0 -$99,999 $100,000 -$249,999 $250,000 -$999,999 $1,000,000 -$1,999,999 Accounts over $2,000,000 Annual Fee 1.75% 1.50% 1.30% 1.20% 1.00% Portfolio management fees may be negotiable depending on factors such as the amount of assets under management, range of investments, and complexity of the client’s financial circumstances, among others. Since this fee is negotiable, the exact fee paid by the client will be clearly stated in the investment advisory contract signed by the client and the firm. Fees are billed quarterly, in advance, and are based on the amount of the assets under management on the last day of the previous quarter. VH will either invoice the client directly for payment of fees or fees will be deducted directly from the client’s account through the qualified custodian holding the client’s funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. We may deduct the fee from a designated account to facilitate billing. We recommend that you review the custodial statement(s) to verify the accuracy of fee calculation. Please call our office number, located on the cover page of this brochure, if you have any questions about your statement. For held-away assets managed through Pontera and Absolute Capital, Pontera and Absolute Capital do not offer us the ability to deduct fees from the account. As such, fees for the management of held- away assets will either be paid directly by the client or deducted from another eligible account that we manage for the client at the qualified custodian(s) recommended by our firm. The investment advisory contract between you and VH will stay in effect until either party terminates the contract with a thirty (30) day written notice. VH's quarterly fee will be pro-rated through the date of termination and any remaining balance shall be refunded to the client in a timely manner. Financial Planning and Consulting Services Fees  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 10 VH provides financial planning services for an hourly fee of up to $300. The fee is negotiable based upon the complexity of the client’s goals and objectives, the level of services rendered and the experience and qualifications of the individual preparing the plan. Consulting services are provided for a one-time fee as negotiated. Prior to engaging VH to provide financial planning services, the client will be required to enter into a written investment advisory contract with our firm. The contract will set forth the terms and conditions of the engagement, describe the scope of the services to be provided and the fee that is due from the client. Fees are either payable in advance or upon delivery of the financial plan. VH does not require the prepayment of over $1,200, six or more months in advance. Either party may terminate the investment advisory contract by written notice to the other. In the event the client terminates VH’s consulting services, the balance of VH’s unearned fees (if any) shall be refunded to the client. Third-Party Investment Adviser Fees VH will share in the fee paid to the TPA. The management fee is disclosed in the TPA's disclosure documents. These fees may or may not be negotiable. VH's compensation will differ depending upon the firm’s individual agreement with each TPA. This creates a conflict of interest because VH and its Associated Persons have an incentive to recommend TPAs that provide the firm with a higher payout. Qualified Retirement Plan Advisory Fees Our standard fee includes establishing your Investment Policy Statement, reviewing your plan structure, investment management, investment selection and monitoring, fund changes, participant education and reporting. The fee will be outlined in your Advisory Agreement with us. Our typical fee schedule is as follows: • Percentage of All Plan Assets Up to 1.75% or as negotiated Our fee is paid directly by the individual Plan Sponsors or Plan on a quarterly basis in advance or in arrears. The advisory agreement the Plan Sponsor has with us will outline exactly how the fees are charged and remitted to us. You may also incur fees related to your use of outside service providers including third-party administrators and record keepers. The fee schedule for each outside service provider varies dramatically from service provider to service provider. The service provider’s fees will also vary from plan to plan as each plan’s structure and characteristics are different from the next. We believe our services help plan sponsors and plan fiduciaries meet their fiduciary duty to the plan and its participants. As a part of our services, we review the fees of service providers and the transparency of their fees. We will assist the plan sponsors with a review of service providers  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 11 including the third-party administrator, daily record keeper, and custodian to ensure that their services, along with ours, remain competitive to alternatives that are available. IRA Rollover Considerations As a normal extension of financial advice, we provide education or recommendations related to the rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and retirement plans. The complexity of these choices may lead an investor to seek assistance from us. An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and expenses will increase to the investor as a result because the above- described fees will apply to assets rolled over to an IRA and outlined ongoing services will be extended to these assets. We are fiduciaries under the Investment Advisers Act of 1940. A such, we have to act in your best interests and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. Compensation for the Sale of Securities or Other Investment Products Compensation for the Sale of Securities Certain Executive officers and other Associated Persons of VH are registered representatives of LPL Financial, LLC (“LPL”), a licensed full-service securities broker-dealer and investment adviser under federal and state securities laws. LPL is a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investors Protection Corporation (“SIPC”). In their capacity as registered representatives, these persons will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by these persons in their capacities as registered representatives, is separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are registered representatives have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on your needs. As a matter of general policy, we aggressively discourage activities that put your interests anywhere but first. Additionally, we have instituted compliance procedures and a code of ethics that requires our Associated Persons to uphold their fiduciary duty by acting in the best interest of the Client. Clients of our firm have the option to purchase investment products that we recommend through other brokers and agents that are not affiliated with our firm. LPL has established a forgivable and repayable loan (the “Forgivable Loan”) with certain of our Associated Persons who are also licensed as registered representatives of LPL. This constitutes an  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 12 additional economic benefit. The terms of the Forgivable Loan require these Associated Person(s) to remain affiliated with LPL for a specified period of time in order to qualify for loan forgiveness. The Forgivable Loan incentivizes such Associated Persons to remain affiliated with LPL as registered representatives. The receipt of the Forgivable Loan therefore presents a conflict of interest because these Associated Persons are incentivized to recommend that clients utilize LPL for brokerage and custodial services due to their ongoing affiliation, rather than basing recommendations on a client’s particular needs. Clients are therefore reminded that they are not under any obligation to purchase commissionable securities products through LPL, and that they may purchase such commissionable securities products through other, non-affiliated broker-dealers. Licensed Insurance Agents: Associated Persons of our firm are licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to our clients. Insurance commissions earned by these persons are separate from and in addition to our advisory fees. The sale of insurance instruments and other commissionable products offered by Associated Persons are intended to complement our advisory services. However, this practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. We address this conflict of interest by recommending insurance products only where we, in good faith, believe that it is appropriate for the client’s particular needs and circumstances and only after a full presentation of the recommended insurance product to our client. In addition, we explain the insurance underwriting process to our clients to illustrate how the insurer also reviews the client’s application and disclosures prior to the issuance of a resulting insuring agreement. Clients to whom the firm offers advisory services are informed that they are under no obligation to purchase insurance services. Clients who do choose to purchase insurance services are under no obligation to use our licensed Associated Persons and may use the insurance brokerage firm and agent of their choice. Where fixed annuities are sold, clients should also note that the annuity sales result in substantial up- front commissions and ongoing trails based on the annuity’s total value. In addition, many annuities contain surrender charges and/or restrictions on access to your funds. Payments and withdrawals can have tax consequences. Optional lifetime income benefit riders are used to calculate lifetime payments only and are not available for cash surrender or in a death benefit unless specified in the annuity contract. In some annuity products, fees can apply when using an income rider. Annuity guarantees are based on the financial strength and claims-paying ability of the issuing insurance company. We urge our clients to read all insurance contract disclosures carefully before making a purchase decision. Rates and returns mentioned on any program presented are subject to change without notice. Insurance products are subject to fees and additional expenses. Additional Fees and Expenses All fees paid to VH for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds to their shareholders. These fees and  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 13 expenses are described in each fund's prospectus. These fees generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without the services of VH. In that case, the client would not receive the services provided by VH which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by VH to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact investment management fees within the range disclosed in our Form ADV Part 2A Brochure. As a result, the Associated Person servicing your account may charge more or less for the same service than another Associated Person of our firm. Further, our annual investment management fee may be higher than that charged by other investment advisors offering similar services/programs. Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could exceed the interest paid by the client’s cash or cash equivalent positions. Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply during these periods, and there can be no assurance that investment decisions made by the firm will be profitable or equal any specific performance level(s).  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 14 Performance-Based Fees and Side-By-Side Management - Item 6 Performance based fees are based on a share of capital gains on or capital appreciation of the client’s assets. Our firm and our Associated Persons do not accept performance based fees. Types of Clients - Item 7 We generally offer investment advisory services to individuals, pension and profit sharing plans and participants, trusts, estates, charitable organizations, corporations, and other business entities. We require a minimum of $250,000 to open and maintain an advisory account. At our sole discretion, we may waive this requirement. This requirement can be met by combining two or more accounts owned by you or related family members. Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 In offering asset management services to its clients, VH uses model portfolios. In creating our models, we rely on research we obtain from third party research consultants. The research consultant provides ongoing consulting services related to investment modeling to our firm. Consulting services may include the aid in implementation of investment models and analysis of portfolios or specific securities. Specific investments may be based on risk mitigation, diversification, time horizon, economic cycle, and tax efficiency needs. The following are different methods of analysis that we may use when providing you with investment advice: • Fundamental Analysis – fundamental analysis is a technique that attempts to determine a security’s value by focusing on underlying factors that affect a company's actual business and its future prospects. The term refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements. • Technical Analysis – technical analysis is a technique that relies on the assumption that current market data (such as charts of price, volume, and open interest) can help predict future market trends, at least in the short term. It assumes that market psychology influences trading and can predict when stocks will rise or fall. • Cyclical Analysis – cyclical analysis is a technique that looks at cycles, specifically analyzing the way prices follow certain patterns and trends. • Charting – charting is a technique that attempts to forecast future market moves by studying historical data on charts. We may use one or more of the following investment strategies when advising you on investments:  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 15 • Long Term Purchases – securities held for over a year. • Short Term Purchases – securities held for less than a year. • Trading – securities are sold within 30 days. • Covered Options – covered option is a strategy in which an investor writes an option contract while at the same time owning an equivalent number of shares of the underlying stock. Investing in securities involves risk of loss that clients should be prepared to bear. Clients should fully understand the nature of the contractual relationship(s) into which they are entering and the extent of their exposure to risk. Certain investing strategies may not be suitable for many members of the public. You should carefully consider whether the strategies employed will be appropriate for you in light of your experience, objectives, financial resources and other relevant circumstances. General Investment Risk: All investments come with the risk of loss. Investing may involve substantial risks, including complete possible loss of principal plus other losses and may not be suitable for many members of the public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect against market losses. Different market instruments carry different types and degrees of risk and you should familiarize yourself with the risks involved in the particular market instruments you intend to invest in. Loss of Value: There can be no assurance that a specific investment will achieve its investment objectives and past performance is no guarantee of future results. The value of investments and the income derived may fall as well as rise and investors may not recoup the original amount invested. Investments may also be affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and economic developments, and government, economic or monetary policies. Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their prices fall when interest rates rise. Longer term debt securities are usually more sensitive to interest rate changes. Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may not make required interest payments. An issuer suffering an adverse change in its financial condition could lower the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of a security may also offset the security's liquidity, making it more difficult to sell. Funds investing in lower quality debt securities are more susceptible to these problems and their value may be more volatile. Risks Associated with Investing in Options: Transactions in options carry a high degree of risk. Relatively small market movement can have a large impact, which may work for or against the investor. The placing of certain orders, which are intended to limit losses to certain amounts, may not be effective because market conditions may make it impossible to execute such orders. Selling  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 16 ("writing" or "granting") an option generally entails considerably greater risk than purchasing options. Although the premium received by the seller is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of the purchaser exercising the option and the seller will be obliged either to settle the option in cash or to acquire or deliver the underlying investment. If the option is "covered" by the seller holding a corresponding position in the underlying investment or a future on another option, the risk may be reduced. Environmental, Social, and Governance Investment Criteria Risk: If a portfolio is subject to certain environmental, social and governance (ESG) investment criteria it may avoid purchasing certain securities for ESG reasons when it is otherwise economically advantageous to purchase those securities, or may sell certain securities for ESG reasons when it is otherwise economically advantageous to hold those securities. In general, the application of the portfolio’s ESG investment criteria may affect the portfolio’s exposure to certain issuers, industries, sectors and geographic areas, which may affect the financial performance of the portfolio, positively or negatively, depending on whether these issuers, industries, sectors or geographic areas are in or out of favor. An adviser can vary materially from other advisers with respect to its methodology for constructing ESG portfolios or screens, including with respect to the factors and data that it collects and evaluates as part of its process. As a result, an adviser’s ESG portfolio or screen may materially differ from or contradict the conclusions reached by other ESG advisers concerning the same issuers. Further, ESG criteria are dependent on data and are subject to the risk that such data reported by issuers or received from third-party sources may be subjective, or it may be objective in principle but not verified or reliable. Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices designed to protect networks, systems, computers, programs, and data from cyber-attacks and hacking by other computer users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate; however, unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the processing of transactions, affecting the ability to calculate net asset value or impeding or sabotaging trading. Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In addition, clients could be exposed to additional losses as a result of unauthorized use of their personal information. While our firm has established a business continuity plan and systems designed to prevent cyber-attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified. Similar types of cyber security risks are also present for issuers of securities, investment companies and other investment advisers in which we invest, which could result in material adverse consequences for such entities and may cause a client's investment in such entities to lose value.  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 17 Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety of factors including the global response of regulators and governments to address and mitigate the worldwide effects of such events. Workforce reductions, travel restrictions, governmental responses and policies and macroeconomic factors will negatively impact investment returns. Recommendation of Other Advisers: In the event we recommend a third-party investment adviser to manage all or a portion of your assets, we will primarily rely on investment model portfolios and strategies developed by the third-party investment advisers and their portfolio managers. If there is a significant deviation in characteristics or performance from the stated strategy and/or benchmark, we may recommend changing models or replacing a third-party investment adviser. The primary risks associated with investing with a third party is that while a particular third party may have demonstrated a certain level of success in the past; it may not be able to replicate that success in future markets. In addition, as we do not control the underlying investments in third party model portfolios, there is also a risk that a third party may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. To address this risk, we seek third parties with proven track records that have demonstrated a consistent level of performance and success over time. A third party’s past performance is not a guarantee of future results and certain market and economic risks exist that may adversely affect an account’s performance that could result in capital losses in your account. Please refer to the third-party investment adviser’s advisory agreements, Form ADV Brochure, and associated disclosure documents for details on their specific investment strategies, methods of analysis, and associated risks. Direct Indexing: Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing can provide a more tax efficient means of investing, and allows for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if a client does not take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on specific tax, Environmental, Social, and Governance or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of the account and the number of securities in the index the account seeks to replicate also limit the ability of the account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index and can cause a portfolio to underperform the index, including as a result of customization. Political Risk: Each administration presents its own set of policy risks that could impact investors. One of the policy tools that an administration can implement is the imposition of tariffs, or the threats  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 18 thereof. The scope, implementation, and duration of tariffs can create uncertainty domestically and globally. Industries that rely on imported raw material or that have heavily integrated cross-border manufacturing practices may be most impacted by the imposition of tariffs. However, it is challenging to predict the impact of actual and/or threatened tariffs and impossible to predict future policy decisions. When tariffs are imposed, there is also a higher probability that retaliatory tariffs could be imposed, which could further impact industries and products. Tariffs in general can also permanently alter global supply chains and have far-reaching indirect impacts. Tariffs can hurt economic growth and add to inflation, which can lead to rising interest rates. Artificial Intelligence ("AI") Risk: We may rely on programs and systems that utilize AI, machine learning, probabilistic modeling, and other data science technologies ("AI Tools") when delivering our services. AI Tools are also used to record and transcribe client meetings. Clients should note that AI Tools are highly complex, and are known to have been flawed, hallucinate, reflect biases included in the data on which such tools are trained, be of poor quality, or be otherwise harmful. AI Tools present Cybersecurity Risk. The U.S. and global legal and regulatory environment relating to the use of AI Tools is uncertain and rapidly evolving, and could require changes in the firm’s implementation of AI Tools and increase compliance costs and the risk of non-compliance. Further, the firm may rely on AI Tools developed by third parties, and the firm has limited control over the accuracy and completeness of such AI Tools. Clients who do not want us to record their meetings have the option to opt out at the time of the meeting. Disciplinary Information - Item 9 Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. There is no history of reportable material legal or disciplinary events by our firm or our management persons. Other Financial Industry Activities or Affiliations - Item 10 As disclosed in Item 5 above, certain Executive officers and other Associated Persons of VH are registered representatives of LPL Financial, LLC (“LPL”), a licensed full-service securities broker-dealer and investment adviser under federal and state securities laws. LPL is a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investors Protection Corporation (“SIPC”). In their capacity as registered representatives, these persons will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by these persons in their capacities as registered representatives, is separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 19 registered representatives have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on your needs. As a matter of general policy, we aggressively discourage activities that put your interests anywhere but first. Additionally, we have instituted compliance procedures and a code of ethics that requires our Associated Persons to uphold their fiduciary duty by acting in the best interest of the Client. Clients of our firm have the option to purchase investment products that we recommend through other brokers and agents that are not affiliated with our firm. Certain Associated Persons of VH are also licensed insurance agents and can effect transactions in insurance products and earn compensation for these activities. The firm expects that clients to whom it offers advisory services may also be clients for whom the individuals act as insurance agents. Clients are instructed that the fees paid to the firm for advisory services are separate and distinct from the commissions earned by its Investment Adviser Representatives for placing the client in insurance products. Clients to whom the firm offers advisory services are informed that they are under no obligation to use the firm’s IARs for insurance services and may use the insurance brokerage firm and agent of their choice. Recommendation of Other Advisors We may recommend that you use a TPA as part of our asset allocation and investment strategy, and we will share in the compensation received by the TPA. As a result of such arrangements, we are incentivized to recommend only the investment advisers from whom we receive referral fees as opposed to another investment adviser from whom we do not receive such fees. We conduct periodic due diligence reviews of TPAs and in the event that the TPA not meeting the standards that we believe meet your needs, we will seek other investment advisers that may be a better fit for your specific management needs. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 Description of Our Code of Ethics VH has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The Code focuses primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The Code includes VH’s policies and procedures developed to protect client’s interests in relation to the following topics: ▪ The duty at all times to place the interests of clients first; ▪ The requirement that all personal securities transactions be conducted in such a manner as to be consistent with the code of ethics; ▪ The responsibility to disclose and/or avoid any actual or potential conflict of interest; ▪ The responsibility to avoid the misuse of an employee’s position of trust and responsibility; ▪ The fiduciary principle that information concerning the identity of security holdings and financial circumstances of clients is confidential; and ▪ The principle that independence in the investment decision-making process is paramount.  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 20 A copy of VH’s Code of Ethics is available upon request to Tyler J. McMurray, Member & Chief Compliance Officer of VH, at (865) 675-VHWM (8496). Personal Trading Practices At times VH and/or its Advisory Representatives may take positions in the same securities as clients. This practice creates a conflict of interest with clients. We will not violate our fiduciary responsibilities to our clients. Front running (trading shortly ahead of clients) is prohibited. Should a conflict occur because of materiality, disclosure will be made to the client(s) at the time of trading. Incidental trading not deemed to be a conflict (i.e. a purchase or sale which is minimal in relation to the total outstanding value, and as such would have negligible effect on the market price), would not be disclosed at the time of trading. Brokerage Practices - Item 12 Our firm will not maintain custody of your assets that we manage, although we are deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15— Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer, bank, or trust company, for example. At this time, VH recommends the services of LPL Financial LLC (“LPL”) and Charles Schwab & Co., Inc. (“Schwab”). Both firms are registered broker- dealers and members of FINRA and SIPC. How We Select Brokers/Custodians When considering whether the terms that LPL and Schwab provide are, overall, advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: • Combination of transaction execution services and asset custody services • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payments, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security and stability • Prior service to us and our clients • Services delivered or paid for by LPL and Schwab • Availability of other products and services that benefit us, as discussed below  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 21 Brokerage and Custodial Services Offered by LPL Financial LLC VH recommends that you establish brokerage accounts with LPL to maintain custody of assets and to effect trades. Factors which VH considers in recommending LPL to Clients include their respective financial strength, reputation, execution, pricing, research and service. For VH’s client accounts custodied at LPL, LPL generally is compensated by clients through commissions, trails, or other transaction-based fees for trades that are executed through LPL or that settle into LPL accounts. The commissions and/or transaction fees charged by LPL may be higher or lower than those charged by other Financial Institutions. For IRA accounts, LPL generally charges account maintenance fees. In addition, LPL also charges clients miscellaneous fees and charges, such as account transfer fees. LPL charges VH 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 VH negotiates its advisory fee with clients. VH receives support services and/or products from LPL, many of which assist the VH to better monitor and service program accounts maintained at LPL; however, some of the services and products benefit VH 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: investment-related research software and other technology that provide access to client account data compliance and/or practice management-related publications consulting services computer hardware and/or software • • pricing information and market data • • • • attendance at conferences, meetings, and other educational and/or social events • marketing support • • other products and services used by VH in furtherance of its investment advisory business operations LPL may provide these services and products directly, or may arrange for third party vendors to provide the services or products to Advisor. In the case of third-party vendors, LPL may pay for some or all of the third party’s fees. These support services are provided to VH based on the overall relationship between VH and LPL. It is not the result of soft dollar arrangements or any other express arrangements with LPL that involves the execution of client transactions as a condition to the receipt of services. VH will continue to receive the services regardless of the volume of client transactions executed with LPL. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by the VH to LPL 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 Advisor receives these benefits from LPL, there is a potential conflict of interest. The receipt of these products and services presents a  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 22 financial incentive for Advisor to recommend that its clients use LPL’s custodial platform rather than another custodian’s platform. Clients should also be aware that for accounts where LPL serves as the custodian, VH is limited to offering services and investment vehicles that are approved by LPL, and may be prohibited from offering services and investment vehicles that may be available through other broker-dealers and custodians, some of which may be more suitable for a client’s portfolio than the services and investment vehicles offered through LPL. Clients should understand that not all investment advisers [require, request or recommend] that clients custody their accounts and trade through specific broker-dealers. Clients should also understand that LPL is responsible under FINRA rules for supervising certain business activities of VH and its Dually Registered Persons that are conducted through broker-dealers and custodians other than LPL. LPL charges a fee for its oversight of activities conducted through these other broker-dealers and custodians. This arrangement presents a conflict of interest because VH has a financial incentive to recommend that you maintain your account with LPL rather than with another broker-dealer or custodian to avoid incurring the oversight fee. Benefits Received by VH Personnel LPL makes available to VH various products and services designed to assist VH in managing and administering client accounts. Many of these products and services may be used to service all or a substantial number of VH’s accounts, including accounts not held with LPL. These include software and other technology that provide access to client account data (such as trade confirmation and account statements); facilitate trade execution (and aggregation and allocation of trade orders for multiple client accounts); provide research, pricing information and other market data; facilitate payment of VH’s fees from its clients’ accounts; and assist with back-office functions; recordkeeping and client reporting. LPL also makes available to VH other services intended to help VH manage and further develop its business. Some of these services assist VH to better monitor and service program accounts maintained at LPL, however, many of these services benefit only VH, for example, services that assist VH 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 VH in furtherance of the operation and development of its investment advisory business. Where such services are provided by a third party vendor, LPL will either make a payment to VH to cover the cost of such services, reimburse VH for the cost associated with the services, or pay the third party vendor directly on behalf of VH.  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 23 The products and services described above are provided to VH as part of its overall relationship with LPL. While as a fiduciary VH endeavors to act in its clients’ best interests, the receipt of these benefits creates a conflict of interest because VH’s [requirement, request or recommendation] that clients custody their assets at LPL is based in part on the benefit to VH of the availability of the foregoing products and services and not solely on the nature, cost or quality of custody or brokerage services provided by LPL. VH’s receipt of some of these benefits may be based on the amount of advisory assets custodied on the LPL platform. Brokerage and Custodial Services Offered by Charles Schwab & Co., Inc. We also recommend that our clients use Schwab as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we or you instruct them to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account Agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client Referrals and Other Compensation). You should consider these conflicts of interest when selecting your custodian. We do not open the account for you, although we may assist you in doing so. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by our firm. Even though your account is maintained at Schwab, and we anticipate that most trades will be executed through Schwab, we can still use other brokers to execute trades for your account as described below (see “Your Brokerage and Custody Costs”). Your Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, certain mutual funds and ETFs) do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. In addition to transaction fees, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we will have Schwab execute most trades for your account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 24 (see “How We Select Brokers/Custodians”). By using another broker or dealer you may pay lower transaction costs. Research and Other Soft Dollar Benefits Although the following products and services are not purchased with “soft dollar” credits, we will receive certain economic benefits (soft dollar benefits) from Schwab in the form of access to Schwab’s institutional brokerage and support services at no additional cost or a discounted cost. Below is a detailed description of Schwab’s support services: Products and Services Available to Us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide our clients and us with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Services that Benefit You: Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that Do Not Directly Benefit You: Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements) facilitate trade execution and allocate aggregated trade orders for multiple client accounts facilitate payment of our fees from our clients’ accounts • • provide pricing and other market data • • assist with back-office functions, recordkeeping, and client reporting Services that Generally Benefit Only Us: Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 25 • Consulting on technology and business needs • Consulting on legal and compliance-related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support • Recruiting and custodial search consulting Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment for our personnel. If you did not maintain your account with Schwab, we would be required to pay for those services from our own resources. Our firm understands its duty for best execution and considers all factors in making recommendations to clients. These research services may be useful in servicing all clients and may not be used in connection with any particular account that may have paid compensation to the firm providing such services. While we may not always obtain the lowest commission rate, we believe the rate is reasonable in relation to the value of the brokerage and research services provided. Our Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. Schwab has also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on our behalf once the value of our clients’ assets in accounts at Schwab reaches certain thresholds. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate our recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select Brokers/Custodians”) and not Schwab’s services that benefit only us. As stated previously, individuals associated with VH are licensed as registered representatives of LPL. As a result of this licensing relationship, LPL is responsible for supervising certain activities of VH to the extent VH manages assets at a broker/dealer and custodian other than LPL. LPL charges a fee for this oversight. This presents a conflict of interest in that VH has a financial incentive to recommend that you maintain your account with LPL rather than another custodian in order to avoid the oversight fee. However, to the extent VH recommends you use LPL for such services, it is because VH believes  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 26 that it is in your best interest to do so based on the quality and pricing of the execution, benefits of an integrated platform for brokerage and advisory accounts, and other services provided by LPL. Brokerage for Client Referrals We do not receive client referrals from broker-dealers and custodians in which we have an institutional advisory arrangement. Also, we do not receive other benefits from a broker-dealer in exchange for client referrals. Directed Brokerage The client may direct brokerage to a specified broker/dealer other than the firm recommended by VH. It is up to the client to negotiate the commission rate, as VH will not. The client may not be able to negotiate the most competitive rate. As a result, the client may pay more than the rate available through the broker dealer used by VH. Where the client does not otherwise designate a broker dealer, VH recommends a broker dealer with competitive commission rates. While LPL does not participate in, or influence the formulation of, the investment advice VH provides, certain supervised persons of VH are Dually Registered Persons. Dually Registered Persons are restricted by certain FINRA rules and policies from maintaining client accounts at another custodian or executing client transactions in such client accounts through any broker-dealer or custodian that is not approved by LPL. As a result, the use of other trading platforms must be approved not only by VH, but also by LPL. Trade Aggregation While individual client advice is provided to each account, client trades may be executed as a block trade. Only accounts in the custody of a qualified custodian recommended by VH would have the opportunity to participate in aggregated securities transactions. Trades will be aggregated and executed in the name of VH. No advisory account within the block trade will be favored over any other advisory account, and thus, each account will participate in an aggregated order at the average share price and receive the same commission rate. The aggregation should, on average, reduce slightly the costs of execution, and VH will not aggregate a client's order if in a particular instance VH believes that aggregation would cause the client's cost of execution to be increased. Review of Accounts - Item 13 Portfolio Management Account Reviews VH monitors client accounts on a continuous basis and reviews accounts on a quarterly basis. Accounts are reviewed by the portfolio manager assigned to the account. Additional reviews may be offered in certain circumstances. Triggering factors that may stimulate additional reviews include, but are not limited to, changes in economic conditions, changes in the client’s financial situation or investment objectives, or a client’s request.  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 27 A financial plan is a snapshot in time and no ongoing reviews are conducted. We recommend clients engage us on a periodic basis to update their financial plan. Clients will receive statements directly from their account custodian(s) on at least a quarterly basis. VH provides separate reports on an as needed basis. Client Referrals and Other Compensation - Item 14 Transition Assistance Benefits LPL provides various benefits and payments to Associated Persons who are dually registered with VH and LPL (“Dually Registered Persons”), and are new to the LPL platform, to assist the representative with the costs (including foregone revenues during account transition) associated with transitioning his or her business to the LPL platform (collectively referred to as “Transition Assistance”). Schwab also provides transition assistance to Associated Persons who commit to bringing additional assets to Schwab. The proceeds of such Transition Assistance payments are intended to be used for a variety of purposes, including but not necessarily limited to, providing working capital to assist in funding the Associated Person’s business, satisfying any outstanding debt owed by the Associated Persons to their prior firm, offsetting account transfer fees (ACATs) payable to LPL or Schwab as a result of clients transitioning to LPL’s custodial platform, technology set-up fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees associated with moving accounts. The amount of the Transition Assistance payments are often significant in relation to the overall revenue earned or compensation received by the Associated Persons at their prior firm. Such payments are generally based on the size of the Associated Persons’ business established at his prior firm and/or assets under custody on the LPL or Schwab platforms. The receipt of Transition Assistance by Associated Persons creates conflicts of interest relating to VH’s advisory business because it creates a financial incentive for VH’s representatives to recommend that their clients maintain their accounts with LPL and/or Schwab. In certain instances, the receipt of such benefits is dependent on an Associated Person maintaining their clients’ assets with LPL and/or Schwab and therefore VH has an incentive to recommend that clients maintain their account with LPL and/or Schwab in order to generate such benefits. VH attempts to mitigate these conflicts of interest by evaluating and recommending that clients use the custodian’s services based on the benefits that such services provide to our clients, rather than the Transition Assistance earned by any particular Associated Persons’s. VH considers LPL’s and Schwab’s overall quality of services when recommending that clients maintain accounts with them.  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 28 However, clients should be aware of this conflict and take it into consideration in making a decision whether to custody their assets in a brokerage account at LPL and/or Schwab. LPL also provides other compensation to VH and its Dually Registered Persons, including but not limited to, bonus payments, repayable and forgivable loans, stock awards and other benefits. The receipt of any such compensation creates a financial incentive for your representative to recommend LPL as custodian for the assets in your advisory account. We encourage you to discuss any such conflicts of interest with your representative before making a decision to custody your assets at LPL. Recommendation of Other Advisors We may recommend that you use a TPA or program as part of our asset allocation and investment strategy. In these cases, VH will share in the compensation received by the TPA. The compensation arrangement presents a conflict of interest as our compensation will differ depending upon our individual agreement with each TPA, giving us an incentive to recommend TPAs with whom we have more favorable compensation arrangements. At all times VH and its Associated Persons uphold their fiduciary duty of fair dealing with Clients. You are not required to use the services of any recommended TPA. We and our related persons do not compensate, either directly or indirectly, any person or entity who is not our supervised person for client referrals. Custody - Item 15 VH is deemed to have custody of client funds because of the fee deduction authority granted by the client in the investment advisory contract. Clients will receive account statements at least quarterly from the broker-dealer or other qualified custodian. Clients are urged to review custodial account statements for accuracy. Investment Discretion - Item 16 VH offers Portfolio Management Services on a discretionary and non-discretionary basis. Clients must grant discretionary authority in the executed investment advisory contract. Discretionary authority extends to the type and amount of securities to be bought and sold and do not require advance client approval. However, apart from the ability to deduct advisory fees, VH does not have the ability to withdraw funds or securities from the client’s account. When offering non-discretionary portfolio management services, VH will obtain client approval prior to executing any transactions in the client's account(s).  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 29 If you wish, you may limit our discretionary authority by, for example, setting a limit on the type of securities that can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Please refer to the “Advisory Business” section in this Brochure for more information on our discretionary management services. Voting Client Securities - Item 17 VH does not vote proxies. It is the client's responsibility to vote proxies. Clients will receive proxy materials directly from the custodian. Financial Information - Item 18 We are required in this Item to provide you with certain financial information or disclosures about VH’s, financial condition. VH does not require the prepayment of over $1,200, six or more months in advance. Additionally, VH has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding. Requirements of State-Registered Advisers - Item 19 This section is not applicable because our firm is SEC registered. Miscellaneous Class Action Lawsuits From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. VH has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. It also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, the firm has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where the firm receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials, to the client. Confidentiality  Visionary Horizons, LLC Form ADV Part 2A Brochure Page 30 VH views protecting its customers’ private information as a top priority and, pursuant to the requirements of the Gramm-Leach-Bliley Act, the firm has instituted policies and procedures to ensure that customer information is kept private and secure. VH does not disclose any nonpublic personal information about its customers or former customers to any nonaffiliated third parties, except as permitted by law. In the course of servicing a client account, VH may share some information with its service providers, such as transfer agents, custodians, broker-dealers, accountants, and lawyers. As discussed previously, certain associated persons of VH are registered representatives of LPL. As a result of this relationship, LPL may have access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about VH’s clients, even if client does not establish any account through LPL. If you would like a copy of the LPL privacy policy, please contact please contact Tyler J. McMurray, Member & Chief Compliance Officer of VH, at (865) 675- VHWM (8496). VH restricts internal access to nonpublic personal information about its clients to those employees who need to know that information in order to provide products or services to the client. VH maintains physical and procedural safeguards that comply with state and federal standards to guard a client’s nonpublic personal information and ensure its integrity and confidentiality. As emphasized above, it has always been and will always be the firm’s policy never to sell information about current or former customers or their accounts to anyone. It is also the firm’s policy not to share information unless required to process a transaction, at the request of the client, or as required by law. A copy of the firm’s privacy policy notice will be provided to each client prior to, or contemporaneously with, the execution of the investment advisory contract. If you have any questions on this policy, please contact Tyler J. McMurray, Member & Chief Compliance Officer of VH, at (865) 675-VHWM (8496).