WALSH & ASSOCIATES, LLC

\ Part 2A of Form ADV: Firm Brochure March 2025 Firm Contact: Michael Walsh 2350 Fruitville Rd., Suite 201 Sarasota, FL 34237 www.walshandassociates.com Chief Compliance Officer This Brochure provides information about the quali�ications and business practices of Walsh & Associates, LLC. If you have any questions about the contents of this Brochure, please contact us by telephone at (941) 952-1188 or email michael.walsh@lpl.com. The information in this Brochure has not been approved or veri�ied by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about Walsh & Associates, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #144441. Please note that the use of the term “registered investment adviser” and description of Walsh & Associates, LLC and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our �irm’s associates who advise you for more information on the quali�ications of our �irm and our employees.  Item 2: Material Changes Walsh & Associates, LLC is required to advise clients and prospective clients of any material changes to our Firm Brochure (“Brochure”) from our last annual update, identify those changes on the cover page of our Brochure or on the page immediately following the cover page, or in a separate communication accompanying our Brochure. Since the last annual amendment �iling on March 27, 2024, we have the following material change to disclose: • • Our �irm now re-offers the Optimum Market Portfolios (“OMP”) to our clients. Please see items 4 and 5 or reach out to Walsh & Associates, LLC for any additional information or Joseph P. Walsh, Jr., who is still a questions. majority owner, Joseph Walsh III, Thomas Walsh & Michael Walsh. Please reach out to Walsh & Our �irm has updated the ownership percentages between Associates, LLC for any additional information or questions. ADV Part 2A – Firm Brochure Page 2 of 21 Walsh & Associates, LLC  Table of Contents Item 3: Item 2: Item 3: Item 4: Item 5: Item 6: Item 7: Item 8: Item 9: Item 10: Item 11: Item 12: Item 13: Item 14: Item 15: Item 16: Item 17: Item 18: Material Changes ..................................................................................................................................................... 2 Table of Contents ..................................................................................................................................................... 3 Advisory Business ................................................................................................................................................... 4 Fees & Compensation ............................................................................................................................................. 8 Performance-Based Fees & Side-By-Side Management ........................................................................ 10 Types of Clients & Account Requirements ................................................................................................. 11 Methods of Analysis, Investment Strategies & Risk of Loss ................................................................ 11 Disciplinary Information ................................................................................................................................... 14 Other Financial Industry Activities & Af�iliations .................................................................................. 14 Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 15 Brokerage Practices ........................................................................................................................................... 16 Review of Accounts or Financial Plans ....................................................................................................... 18 Client Referrals & Other Compensation ..................................................................................................... 18 Custody .................................................................................................................................................................... 20 Investment Discretion ....................................................................................................................................... 21 Voting Client Securities ..................................................................................................................................... 21 Financial Information ........................................................................................................................................ 21 ADV Part 2A – Firm Brochure Page 3 of 21 Walsh & Associates, LLC  Advisory Business Item 4: We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our �irm is a limited liability company formed in the State of Florida. Our �irm has been in business since 1996 and acting as an investment adviser since 2011. Our �irm is principally owned by Joseph P. Walsh, Jr., who has been in the �inancial service industry for over 30 years. Joseph Walsh III, Thomas Walsh, and Michael Walsh are all minority owners. The purpose of this Brochure is to disclose the con�licts of interest associated with the investment transactions, compensation and any other matters related to investment decisions made by our �irm or its representatives. As a �iduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing our client. Our �irm has established a service-oriented advisory practice with open lines of communication for many different types of clients to help meet their �inancial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Comprehensive Portfolio Management. Our Comprehensive Portfolio Management service encompasses asset management as well as providing �inancial planning/�inancial consulting to clients. It is designed to assist clients in meeting their �inancial goals through the use of �inancial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone or video conference) with clients in order to understand their current �inancial situation, existing resources, �inancial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds (“ETFs”), mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least annually. We may periodically rebalance or adjust client accounts under our management. If the client experiences any signi�icant changes to his/her �inancial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Legacy Wrap Asset Management. Please refer to our Form ADV Part 2A – Appendix 1 (“Wrap Fee Program Brochure”) for information regarding our Legacy Wrap Asset Management service. Legacy Wrap Comprehensive Portfolio Management. ADV Part 2A – Firm Brochure Page 4 of 21 Walsh & Associates, LLC  Please refer to our Form ADV Part 2A – Appendix 1 (“Wrap Fee Program Brochure”) for information regarding our Legacy Wrap Comprehensive Portfolio Management service. Red Flag Audit. We provide a variety of �inancial planning and consulting services to individuals, families and other clients regarding the management of their �inancial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such �inancial planning services will involve preparing a �inancial plan or rendering a �inancial consultation for clients based on the client’s �inancial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Our written �inancial plans or �inancial consultations rendered to clients usually include general recommendations for a course of activity or speci�ic actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. It should also be noted that we refer clients to an accountant, attorney or other specialist, as necessary for nonadvisory related services. For written �inancial planning engagements, we provide our clients with a written summary of their �inancial situation, observations, and recommendations. For �inancial consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. Retirement Plan Consulting: Our �irm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising may include: • Establishing an Investment Policy Statement – Our �irm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives. • Investment Options – Our �irm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes. ADV Part 2A – Firm Brochure Page 5 of 21 Walsh & Associates, LLC  • Asset Allocation and Portfolio Construction – Our �irm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, �inancial situation and tolerance for risk. • Investment Monitoring – Our �irm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility. • Participant Education – Our �irm will provide opportunities to educate plan participants about their retirement plan offerings, different investment options, and general guidance on allocation strategies. In providing services for retirement plan consulting, our �irm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITs), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee bene�it plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our �irm accepts appointment to provide services to such accounts, our �irm acknowledges its �iduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. Referrals to Third-Party Money Managers: We provide clients with a list of investment advisory services of third-party professional Portfolio Management �irms for the individual management of client accounts. As part of this process, we assist clients in identifying an appropriate third-party money manager. We provide initial due diligence on third-party money managers and ongoing reviews of their management of the client’s account. To assist clients in the selection of a third-party money manager, we typically gather information from the client about their �inancial situation, investment objectives, and reasonable restrictions they can impose on the management of the account, which are often very limited. It is important to note that we do not offer advice on any speci�ic securities or other investments in connection with this service. Investment advice and trading of securities is only offered by or through the third-party money managers to clients. We periodically review third-party money managers’ reports provided to the client, but no less often than on an annual basis. Our associates contact the clients from time to time, as agreed to with the client, in order to review their �inancial situation and objectives; communicate information to third-party money managers as warranted; and assist the client in understanding and evaluating the services provided by the third-party money manager. The client will be ADV Part 2A – Firm Brochure Page 6 of 21 Walsh & Associates, LLC  expected to notify us of any changes in his/her �inancial situation, investment objectives, or account restrictions that could affect their account. The client may also directly contact the third-party money manager managing the account or sponsoring the program. OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds Class I shares. Under OMP, the client will authorize LPL Financial on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. We will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Advisor will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL Financial will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL Financial will also have authority to rebalance the account. A minimum account value of $1,000 is required for OMP. The OMP advisory fees range from 0.00% to 2.50%. We offer individualized investment advice to clients utilizing our Comprehensive Portfolio Management services. Additionally, we offer general investment advice to clients utilizing our Red Flag Audit. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of dif�iculty this would entail in managing the account. Restrictions would be limited to our Comprehensive Portfolio Management service. We do not manage assets through our other services. We offer wrap fee programs to legacy clients as further described in Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”) of our Brochure, however all new accounts are established according to the traditional Comprehensive Portfolio Management services described in this Brochure. Our wrap fee and non-wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, �inancial goals, risk tolerance, etc. We do not manage wrap fee accounts in a different fashion than non-wrap fee accounts. As further described in our Wrap Fee Program Brochure, we receive a portion of the wrap fee for our services. As of December 31, 2024, we manage $660,187,718 all on a discretionary basis. ADV Part 2A – Firm Brochure Page 7 of 21 Walsh & Associates, LLC  Fees & Compensation Item 5: Comprehensive Portfolio Management. Assets Under Management Annual Percentage of Assets Charge Under $1,000,000 1.5% $1,000,000 to $5,000,000 1.0% Over $5,000,000 0.75% Our �irm’s annualized fees are billed on a pro-rata basis quarterly in advance based on the value of the client’s account on the last day of the previous quarter. In the event where a client opens an account halfway through the quarter, the client’s �irst bill will be both in arrears and in advance accordingly. Our �irm bills on cash unless otherwise indicated in writing. Fees are negotiable and will be deducted from the client’s managed account. LPL will make quarterly adjustments for deposits and withdrawals in client accounts. As part of this process, the client is made aware of the following: • LPL Financial (“LPL”) as the client’s custodian sends statements at least quarterly to you showing all disbursements for each account, including the amount of the advisory fees paid to us; • The client provides authorization permitting LPL to deduct these fees; • LPL calculates the advisory fees for all �lat fee schedules and deducts them from the client’s account. Legacy Wrap Asset Management. Please refer to Item 4 of our Wrap Fee Program Brochure for information regarding our Legacy Wrap Asset Management service fees. Legacy Wrap Comprehensive Portfolio Management. Please refer to Item 4 of our Wrap Fee Program Brochure for information regarding our Legacy Wrap Comprehensive Portfolio Management service fees. Red Flag Audit. We charge on a �lat fee basis for our Red Flag Audit service. The total estimated fee as well as the ultimate fee that we charge the client is based on the scope and complexity of our engagement with the client. Flat fees generally range from $1,000 to $10,000. We do not require a retainer of the total �inancial consulting fee. ADV Part 2A – Firm Brochure Page 8 of 21 Walsh & Associates, LLC  Retirement Plan Consulting: Our Retirement Plan Consulting services are billed on a fee based on the percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. Fees based on a percentage of managed Plan assets will not exceed 1.50%. The fee-paying arrangements will be determined on a case-by- case basis and will be detailed in the signed consulting agreement. Referrals to Third-Party Money Managers. We do not charge a client separate fees for referrals to third-party money managers (“TPMM”). We will share in the advisory fee a client pays directly to the TPMM. The advisory fee a client pays to the TPMM is established and payable in accordance with the brochure provided by each TPMM to whom the client is referred. These fees may or may not be negotiable. Our compensation may differ depending upon the individual agreement we have with each TPMM. As such, a con�lict of interest exists where our �irm or persons associated with our �irm has an incentive to recommend one TPMM over another TPMM with whom we have more favorable compensation arrangements or other advisory programs offered by TPMMs with whom we have less or no compensation arrangements. OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds Class I shares. Under OMP, the client will authorize LPL Financial on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. LPL Financial will also have authority to rebalance the account. A minimum account value of $1,000 is required for OMP. The OMP advisory fees range from 0.00% to 2.50%. You may terminate your advisory relationship with the TPMM according to the terms of your agreement with the TPMM. You should review each TPMM's brochure for speci�ic information on how you may terminate your advisory relationship with the TPMM and how you may receive a refund, if applicable. You should contact the TPMM directly for questions regarding your advisory agreement with the TPMM. Non-Wrap fee clients will incur transaction charges for trades executed in their accounts, via individual transaction charges. These transaction fees are separate from our fees and will be disclosed by the �irm that the trades are executed through. LPL Financial offers a trading platform with select exchange traded funds (“ETFs”) that do not charge transaction fees. The no-transaction-fee ETF trading platform is available to clients participating in LPL Financial’s Strategic Wealth Management (“SWM”) program. Clients will be subject to transaction fees charged by LPL for ETFs not included in LPL’s platform and for other types of securities. The limited number of ETFs available on LPL’s no-transaction fee platform may have higher overall expenses than other types of securities and ETFs not included in the platform. Other major custodians ADV Part 2A – Firm Brochure Page 9 of 21 Walsh & Associates, LLC  have eliminated transaction fees for all ETFs and U.S. listed equities, so clients may pay more for investing in the same securities at LPL Financial. Also, clients will pay the following separately incurred expenses, which we do not receive any part of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses). Legacy clients who have already engaged our �irm in this regard. We charge our advisory fees quarterly in advance. In the event that a client wishes to terminate our services, we will refund the unearned portion of our advisory fee to the client. The client needs to contact us in writing and state that they wish to terminate our services. Upon receipt of the client’s letter of termination, we will proceed to close out the client’s account and process a pro-rata refund of unearned advisory fees. In order to sell securities for a commission, our supervised persons are registered representatives of LPL Financial Corporation, member FINRA/SIPC. Our supervised persons may accept compensation for the sale of securities or other investment products, including distribution or service (“trail”) fees from the sale of mutual funds. Clients should be aware that the practice of accepting commissions for the sale of securities: • Presents a con�lict of interest and gives our �irm and/or our supervised persons an incentive to recommend investment products based on the compensation received, rather than on clients’ needs. We generally address commissionable sales con�licts that arise when explaining to clients that commissionable securities sales create an incentive to recommend products based on the compensation we and/or our supervised persons may earn and/or when recommending commissionable mutual funds, explaining that “no-load” funds are also available. • In no way prohibits clients from purchasing investment products recommended by us through other brokers or agents which are not af�iliated with us. • Does not exceed more than 50% of our revenue. Performance-Based Fees & Side-By-Side Management Item 6: We do not accept performance-based fees. ADV Part 2A – Firm Brochure Page 10 of 21 Walsh & Associates, LLC  Types of Clients & Account Requirements Item 7: We have the following types of clients: • • • Trusts, Estates or Charitable Organizations; Individuals and High Net Worth Individuals; Pension and Pro�it-Sharing Plans. Our requirements for opening and maintaining accounts or otherwise engaging us: • • We require a minimum account balance of $500,000 for our Comprehensive Portfolio Management service. This minimum account balance requirement is negotiable. We do not charge a minimum fee for our Comprehensive Portfolio Management service. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss We use the following methods of analysis in formulating our investment advice and/or managing client assets: • Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and �inancial factors (including the overall economy, industry conditions, and the �inancial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and �inancial factors considered in evaluating the stock. • Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, �ixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, �ixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. • Mutual Fund and/or ETF Analysis. ADV Part 2A – Firm Brochure We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is signi�icant overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the Walsh & Associates, LLC Page 11 of 21  future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. • Quantitative Analysis. We use quantitative analysis that may include mathematical analysis in an attempt to identify the impact of interest rate changes on individual securities and portfolios of securities. The results of our quantitative analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions that prove to be incorrect. • Qualitative Analysis . We use qualitative analysis to evaluate individual securities, focusing on non-quanti�iable factors such as quality of management and others not readily subject to measurement, and incorporate that analysis into our security selection process. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. • Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations. Typically, we employ this strategy when we believe the securities to be currently undervalued, and/or we want exposure to a particular asset class over time, regardless of the current projection for this class. • Long-Term Purchases. When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long- term purchase strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be pro�itable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Typically, we employ this sub-strategy when we believe the securities to be well valued; and/or we want exposure to a particular asset class over time, regardless of the current projection for this class. ADV Part 2A – Firm Brochure Page 12 of 21 Walsh & Associates, LLC  • Short-Term Purchases. When utilizing this strategy, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. • Margin Loans: Our �irm may allow or recommend that you to pledge securities from your portfolio as collateral for a loan by using margin in brokerage account. This allows you to own more stock than you would be able to with your available cash. Margin accounts and transactions are risky and not necessarily appropriate for every client. • The potential risks associated with these transactions are (1) You can lose more funds than are deposited into the margin account; (2) the forced sale of securities or other assets in your account; (3) the sale of securities or other assets without contacting you; (4) you may not be entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and (5) custodians charge interest on margin balances which will reduce your returns over time. Cash & Cash Equivalents: Cash and cash equivalents generally refer to either United States dollars or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank Certi�icates of Deposit (“CDs”) and commercial papers. Generally, these assets are considered nonproductive and will be exposed to in�lation risk and considerable opportunity cost risk. Investments in cash and cash equivalents will generally return less than the advisory fee charged by our �irm. Our �irm may recommend cash and cash equivalents as part of our clients’ asset allocation when deemed appropriate and in their best interest. Our �irm considers cash and cash equivalents to be an asset class. Therefore, our �irm assesses an advisory fee on cash and cash equivalents unless indicated otherwise in writing. Fixed Income Portfolio Management Investment Strategies. We believe that a conservative, risk-averse approach to �ixed income management will provide both steady incremental outperformance, and low relative volatility. The disciplined process we employ in an effort to realize this philosophy is generally grounded in four key decisions: • Constraint of portfolio duration within a narrow range relative to the benchmark in order to limit exposure to market and interest rate risk. • Strategic allocations to key sectors to add value relative to the benchmark. • ADV Part 2A – Firm Brochure Proactive management of term structure to add value in different yield curve environments. Walsh & Associates, LLC Page 13 of 21  • Security selection based on rigorous credit and relative value analysis and broad diversi�ication of nongovernment issuers. Within our Fixed Income strategy, we use the following sub-strategies in managing client accounts, provided that such sub-strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: • Duration Constraints. • We adhere to a discipline of generally maintaining duration within a narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio management team rebalances client portfolios to their current duration targets on a periodic basis. The risk of constraining duration is that the client may not participate fully in a large rally in bond prices. Sector Allocation • . We allocate client assets to various sectors of the �ixed income market, federal agency securities, corporate notes, including US Treasury obligations, mortgagebacked securities and others, based on our quantitative and qualitative analysis in order to manage client exposure to a given sector and to provide exposure to sectors we believe have good value. The risk of sector allocation is that clients may not participate fully in an increase in value in any speci�ic sector. Security Selection. We use externally generated credit research to evaluate securities we are considering for purchase. The ultimate decision to purchase or sell a security is based on the �irm’s evaluation of the current price for the security. The risk of security selection is that the methods of analysis employed will not provide accurate measurement of the risk association with each individual security. Please Note: Disciplinary Information Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and client account(s) could enjoy a gain, it is also possible that the stock market may decrease, and their account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the stock market, are appropriately diversi�ied in their investments and ask us any questions they may have. Item 9: There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations We participate in LPL Financial’s hybrid RIA program. As such, our investment adviser representatives are also registered representatives with LPL, in which all brokerage transactions will ADV Part 2A – Firm Brochure Walsh & Associates, LLC Page 14 of 21  be implemented through LPL. Investment adviser representatives are required to implement brokerage trades in this manner as a result of them being registered representatives with LPL. This relationship will be disclosed to all clients prior to any transactions being implemented. As a result of this relationship, we do not recommend directed brokerage trades, negotiate fees or commissions or receive additional incentives from other broker/dealers for trades executed through them. However, clients will be made aware that as registered representatives, the investment adviser representatives receive services including but not limited to: administrative functions including portfolio pricing, account statement generation, fee calculations, back-of�ice support, trade execution and research. Clients are not obligated to implement transactions through the investment adviser representatives in their separate capacities as registered representatives. Clients’ trades will always be implemented based on the goals and objectives of the client and not on the incentives to the representatives for implementing the trades. Our �irm’s management persons will only receive commissions for securities recommendations they make to brokerage clients in non-advisory accounts. Compensation for brokerage commissions of registered representatives of LPL are paid directly to the registered representative by LPL in their individual capacity and separate from Walsh & Associates, LLC. Our advisory representatives may also be licensed to sell insurance products. As such, they may have an incentive to sell and recommend insurance products to advisory clients. When such recommendations or sales are made, a con�lict of interest exists as our representative may earn insurance commissions for the sale of those products. Clients are under no obligation to purchase insurance products recommended to them by our advisory representatives. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading We recognize that the personal investment transactions of members and employees of our �irm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our �irm, it is logical and even desirable that there be common ownership of some securities. Therefore, in order to prevent con�licts of interest, we have in place a set of procedures (including a pre-clearing procedure) with respect to transactions effected by our members, of�icers and employees for their personal accounts 1 . In order to monitor compliance with our personal trading 1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect bene�icial interest in. ADV Part 2A – Firm Brochure Page 15 of 21 Walsh & Associates, LLC  policy, our �irm’s Chief Compliance Of�icer has access to all �irm employee personal accounts through LPL’s ClientWorks system. Furthermore, our �irm has established a Code of Ethics which applies to all of our associated persons. An investment adviser is considered a �iduciary. As a �iduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a �iduciary duty to all clients. Our �iduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or af�iliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our �irm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Neither our �irm nor a related person recommends to clients, or buys or sells for client accounts, securities in which our �irm or a related person has a material �inancial interest. Related persons of our �irm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this con�lict of interest, our related persons will place client interests ahead of their own interests and adhere to our �irm’s Code of Ethics, a copy of which is available upon request. Likewise, related persons of our �irm may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this con�lict of interest, our related persons will place client interests ahead of their own interests and adhere to our �irm’s Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or selling the same securities prior to buying or selling for our clients in the same day. If related persons’ accounts are included in a block trade, our related persons will always trade personal accounts last. Item 12: Brokerage Practices We seek to recommend a custodian/broker who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: • Timeliness of execution ADV Part 2A – Firm Brochure Page 16 of 21 Walsh & Associates, LLC  • Timeliness and accuracy of trade con�irmations • Research services provided • Ability to provide investment ideas • Execution facilitation services provided • Record keeping services provided • Custody services provided • Frequency and correction of trading errors • Ability to access a variety of market venues • Expertise as it relates to speci�ic securities • Financial condition • Business reputation • Quality of services Our �irm has a non-soft-dollar arrangement with LPL Financial under which we receive non-softdollar services such as research and administrative functions including portfolio pricing, account statement generation and fee calculations, which are intended to support our �irm in conducting business and in serving the best interests of our clients. These services do not incentivize us to recommend LPL Financial. Our recommendation of LPL Financial to our clients is based on our clients’ interests in receiving best execution and the level of competitive, professional services LPL Financial provides. ur �irm does not receive client brokerage commissions (or markups or markdowns) to obtain research or other products or services. Our �irm does not receive brokerage for client referrals. We do not allow client-directed brokerage, as trades in our clients’ accounts are executed through LPL Financial, a quali�ied custodian and broker-dealer; neither do we direct client transactions to LPL Financial in return for soft-dollar bene�its. A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a speci�ic broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and ADV Part 2A – Firm Brochure Walsh & Associates, LLC Page 17 of 21  empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive bene�it of the plan. Consequently, our �irm will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive bene�it of the plan. We do not aggregate the purchase or sale of securities for various client accounts but rather review accounts independently and place transactions accordingly. Whether or not securities are purchased or sold at approximately the same time, all client transactions will incur individual transaction fees. Whether or not we aggregate our orders, LPL Financial does bunch orders. The advantage of bunching is that orders are handled in a way that may mitigate market impact, when applicable and possible. If orders are bunched, each client gets the same average execution price. Item 13: Review of Accounts or Financial Plans We review accounts on at least an annual basis for our clients subscribing to our Comprehensive Portfolio Management. The nature of these reviews are to learn whether clients’ accounts are in line with their investment objectives and appropriately positioned based on market conditions and investment policies, if applicable. We do not provide written reports to clients unless asked to do so. Verbal reports to clients take place on at least an annual basis when we contact clients who subscribe to our Comprehensive Portfolio. Only our Financial Advisors will conduct reviews. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Red Flag Audit clients do not receive reviews of their written plans unless they take action to schedule a �inancial consultation with us. We do not provide ongoing services to Red Flag Audit clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Red Flag Audit clients do not receive written or verbal updated reports regarding their �inancial plans unless they separately contract with us for a post-�inancial plan meeting or update to their initial written �inancial plan. Item 14: Client Referrals & Other Compensation Investment or Brokerage Discretion. We provide discretionary portfolio management services where the investment advice provided is custom tailored to meet the needs and investment objectives of each client. Accordingly, we are authorized to perform various functions, at the client’s expense, without further approval from the client. Such functions include the determination of securities to be purchased/sold and the ADV Part 2A – Firm Brochure Page 18 of 21 Walsh & Associates, LLC  amount of securities to be purchased/sold. We do not have discretionary authority over the broker or dealer to be used. Suggestion of Brokers to Clients. We shall recommend LPL Financial. LPL is the broker-dealer with which our representatives are also associated. As a result of the individual association of our representatives with LPL, we are generally required to utilize the brokerage/custodial services of LPL for investment advisory accounts. Our general policies relative to the execution of client securities brokerage transactions are as follows: In seeking “best execution”, the determinative factor is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution. LPL also takes into consideration the full range of a broker-dealer's services including execution capability, commission rates, and responsiveness. Although LPL will seek competitive commission rates, it may not necessarily obtain the lowest possible commission rates for all account transactions. Over-the-Counter (OTC) securities transactions are generally effected based on two (2) separate broker-dealers: (1) a “dealer” or “principal” acting as market maker; and (2) the executing broker-dealer that acts in an agency capacity. Dealers executing principal transactions typically include a mark-up/down, which is included in the offer or bid price of the securities purchased or sold. In addition to the dealer mark-up/down, the client may also incur the transaction fee imposed by the executing broker-dealer. We do not receive any portion of the dealer mark-up/down or the executing broker-dealer transaction fee. Transactions for each client account will be effected independently. We individually review each client’s account and place trades accordingly. Despite being purchased or sold at approximately the same time all clients’ transactions will incur individual transaction fees. Additional Compensation. We may receive from LPL or a mutual fund company, without cost and/or at a discount support services and/or products, to assist us to better monitor and service client accounts maintained at such institutions. Included within the support services we may receive investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by us to assist us in our investment advisory business operations. Our clients do not pay more for investment transactions effected and/or assets maintained at LPL as result of this arrangement. There is no commitment made by us to LPL or any other institution as a result of the above arrangement. ADV Part 2A – Firm Brochure Page 19 of 21 Walsh & Associates, LLC  In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our �irm does not provide cash or non-cash compensation directly or indirectly to unaf�iliated persons for testimonials or endorsements (which include client referrals). Item 15: Custody We do not have custody of client funds or securities. All of our clients receive at least quarterly account statements directly from their custodians. Upon opening an account with a quali�ied custodian on a client's behalf, we promptly notify the client in writing of the quali�ied custodian's contact information. If we decide to also send account statements to clients, such notice and account statements include a legend that recommends that the client compare the account statements received from the quali�ied custodian with those received from our �irm. On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clari�ied that an adviser who has the power to disburse client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As such, our �irm has adopted the following safeguards in conjunction with our custodian: • • • • • • • The client provides an instruction to the quali�ied custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. The client authorizes the investment adviser, in writing, either on the quali�ied custodian’s form or separately, to direct transfers to the third party either on a speci�ied schedule or from time to time. The client’s quali�ied custodian performs appropriate veri�ication of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. The client has the ability to terminate or change the instruction to the client’s quali�ied custodian. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. The client’s quali�ied custodian sends the client, in writing, an initial notice con�irming the instruction and an annual notice recon�irming the instruction ADV Part 2A – Firm Brochure Page 20 of 21 Walsh & Associates, LLC  Item 16: Investment Discretion Clients have the option of providing our �irm with investment discretion on their behalf, pursuant to an executed investment advisory client agreement. By granting investment discretion, we are authorized to execute securities transactions, which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be effected. Limitations may be imposed by the client in the form of speci�ic constraints on any of these areas of discretion with our �irm’s written acknowledgement. Item 17: Voting Client Securities We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our �irm, we will forward them on to the client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Item 18: Financial Information We are not required to provide �inancial information in this Brochure because: • We do not require the prepayment of more than $1,200 in fees and six or more months in advance. • We do not take custody of client funds or securities. • We have never been the subject of a bankruptcy proceeding. • We do not have any �inancial condition that could impact our ability to meet contractual obligations to clients. ADV Part 2A – Firm Brochure Page 21 of 21 Walsh & Associates, LLC 

Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure March 2025 Walsh & Associates Wrap Program Sponsored By: Firm Contact: Michael Walsh Chief Compliance Officer 2350 Fruitville Rd., Suite 201 Sarasota, FL 34237 www.walshandassociates.com This Brochure provides information about the qualifications and business practices of Walsh & Associates, LLC. If you have any questions about the contents of this Brochure, please contact us by telephone at (941) 952-1188 or email michael.walsh@lpl.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. Additional information about Walsh & Associates, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #144441. Please note that the use of the term “registered investment adviser” and description of Walsh & Associates, LLC and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and our employees.  Item 2: Material Changes Walsh & Associates, LLC is required to advise clients of any material changes to our Wrap Brochure (“Wrap Brochure”) from our last annual update, identify those changes on the cover page of our Brochure or on the page immediately following the cover page, or in a separate communication accompanying our Brochure. Since the last annual amendment filing on March 27, 2024, we have the following material changes to disclose: • Our firm has updated the ownership percentages between Joseph P. Walsh, Jr., who is still a majority owner, Joseph Walsh III, Thomas Walsh & Michael Walsh. Please reach out to Walsh & Associates, LLC for any additional information or questions. ADV Part 2A, Appendix 1: Wrap Brochure Page 2 of 15 Walsh & Associates, LLC  Item 3: Table of Contents Item 1: Item 2: Item 3: Item 4: Item 5: Item 6: Item 7: Item 8: Item 9: Cover Page ......................................................................................................................................................... 1 Material Changes ............................................................................................................................................. 2 Table of Contents ............................................................................................................................................ 3 Services, Fees & Compensation ................................................................................................................ 4 Account Requirements & Types of Clients .......................................................................................... 6 Portfolio Manager Selection & Evaluation .......................................................................................... 7 Client Information Provided to Portfolio Manager(s) ................................................................. 11 Client Contact with Portfolio Manager(s) .......................................................................................... 12 Additional Information .............................................................................................................................. 12 ADV Part 2A, Appendix 1: Wrap Brochure Page 3 of 15 Walsh & Associates, LLC  Item 4: Services, Fees & Compensation Our firm manages assets for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing the client. Our firm has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. based on individual transaction charges. We emphasize continuous and regular account supervision. As part of our asset management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds, Variable Annuities and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least annually and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals, and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Assets Under Management Annual Percentage of Assets Charge Under $1,000,000 1.5% Over $1,000,000 1.0% ADV Part 2A, Appendix 1: Wrap Brochure The fee to be assessed to each account will be detailed in the client’s signed advisory agreement, LPL Account Application or LPL Tiered Fee Authorization form. Fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last day Walsh & Associates, LLC Page 4 of 15  of the previous quarter. Our firm bills on cash unless otherwise indicated in writing. Fees are negotiable and will be deducted from the account(s). Please note that fees will be adjusted for deposits and withdrawals made during the quarter. If accounts are opened during the quarter, the pro-rata advisory fees will be deducted during the next regularly scheduled billing cycle. In rare cases, our firm will agree to direct bill clients. As part of this process, Clients understand the following: • • • LPL Financial (“LPL”) as the client’s custodian sends statements at least quarterly, showing all disbursements for each account, including the amount of the advisory fees paid to our firm; Clients provide authorization permitting LPL to deduct these fees; LPL calculates the advisory fees for all fee schedules and deducts them from the client’s account. Our comprehensive portfolio management service encompasses asset management as well as providing financial planning/financial consulting to clients. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone or videoconference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of ETFs, mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least annually. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Assets Under Management Annual Percentage of Assets Charge Under $1,000,000 1.5% Over $1,000,000 1.0% ADV Part 2A, Appendix 1: Wrap Brochure The fee to be assessed to each account will be detailed in the client’s signed advisory agreement, LPL Account Application or LPL Tiered Fee Authorization form. Fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Our firm bills on cash unless otherwise agreed to in writing. Fees are negotiable and will be deducted from the account(s). Please note that fees will be Walsh & Associates, LLC Page 5 of 15  adjusted for deposits and withdrawals made during the quarter. If accounts are opened during the quarter, the pro-rata advisory fees will be deducted during the next regularly scheduled billing cycle. In rare cases, our firm will agree to direct bill clients. As part of this process, Clients understand the following: • • • LPL as the client’s custodian sends statements at least quarterly, showing all disbursements for each account, including the amount of the advisory fees paid to our firm; Clients provide authorization permitting LPL to deduct these fees; LPL calculates the advisory fees for all fee schedules and deducts them from the client’s account. In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or ETF, which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark- ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Our firm does not recommend or offer the wrap program services of other providers. Item 5: Account Requirements & Types of Clients Our requirements for opening and maintaining accounts or otherwise engaging us: • • We require a minimum account balance of $500,000 for our Wrap Asset Management service. This minimum account balance requirement is negotiable. We do not charge a minimum fee for our Wrap Asset Management service. We have the following types of clients: • • • Individuals and High Net Worth Individuals; Trusts, Estates or Charitable Organizations; Pension and Profit-Sharing Plans. ADV Part 2A, Appendix 1: Wrap Brochure Page 6 of 15 Walsh & Associates, LLC  Item 6: Portfolio Manager Selection & Evaluation Our firm utilizes our in-house portfolio managers as well as a selection of outside portfolio managers. In-house accounts are managed by licensed investment adviser representatives (“IAR”s) of our firm. Prior to becoming licensed with our firm, each IAR’s industry experience, licensure, outside business activities, client complaints (if any), disciplinary or regulatory history (if any) and financial well-being will be reviewed. Each IAR will then have a Form U4 and ADV Part 2B on file with our firm. Outside portfolio managers, either individually or firm-wide, are selected based on past performance, investment philosophy, market outlook, experience of associated portfolio managers and executive team, disciplinary, legal and regulatory histories of the firm and its associates, and/or whether compliance procedures are in place to address, at a minimum, insider trading, conflicts of interest, and/or anti-money laundering. Performance returns of wrap portfolios are reviewed at least annually. The nature of these reviews is to learn whether client accounts are in line with their investment objectives and appropriately positioned based on market conditions. If these standards fall below the client objectives, our firm will discuss the review with the portfolio manager for proactive action to realign the investment strategy. See Item 4 for information about our wrap fee advisory program. We offer individualized investment advice to clients utilizing our Wrap Asset Portfolio Management service and Wrap Comprehensive Portfolio Management services. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Restrictions would be limited to our Wrap Asset Management and Wrap Comprehensive Portfolio Management. We do not manage assets through our other services. Our wrap fee and non-wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. We do not manage wrap fee accounts in a different fashion than non-wrap fee accounts. We do not charge performance fees to our clients. ADV Part 2A, Appendix 1: Wrap Brochure Page 7 of 15 Walsh & Associates, LLC  We use the following methods of analysis in formulating our investment advice and/or managing client assets: • Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. • Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. • Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. • Quantitative Analysis. We use quantitative analysis that may include mathematical analysis in an attempt to identify the impact of interest rate changes on individual securities and portfolios of securities. The results of our quantitative analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions that prove to be incorrect. ADV Part 2A, Appendix 1: Wrap Brochure Page 8 of 15 Walsh & Associates, LLC  • Qualitative Analysis . We use qualitative analysis to evaluate individual securities, focusing on non-quantifiable factors such as quality of management and others not readily subject to measurement, and incorporate that analysis into our security selection process. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. • Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly-available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: • Long-Term Purchases. • When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long- term purchase strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Typically, we employ this sub-strategy when we believe the securities to be well valued; and/or we want exposure to a particular asset class over time, regardless of the current projection for this class. Short-Term Purchases. When utilizing this strategy, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. • Margin Loans: Our firm may allow or recommend that you to pledge securities from your portfolio as collateral for a loan by using margin in brokerage account. This allows you to own more stock than you would be able to with your available cash. Margin accounts and transactions are risky and not necessarily appropriate for every client. The potential risks associated with these transactions are (1) You can lose more funds than are deposited into the margin account; (2) the forced sale of securities or other assets in your account; (3) the sale of securities or other assets without contacting you; (4) you may not be entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and (5) custodians charge interest on margin balances which will reduce your returns over time. ADV Part 2A, Appendix 1: Wrap Brochure Page 9 of 15 Walsh & Associates, LLC  • Cash & Cash Equivalents: Cash and cash equivalents generally refer to either United States dollars or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank Certificates of Deposit (“CDs”) and commercial papers. Generally, these assets are considered nonproductive and will be exposed to inflation risk and considerable opportunity cost risk. Investments in cash and cash equivalents will generally return less than the advisory fee charged by our firm. Our firm may recommend cash and cash equivalents as part of our clients’ asset allocation when deemed appropriate and in their best interest. Our firm considers cash and cash equivalents to be an asset class. Therefore, our firm assesses an advisory fee on cash and cash equivalents unless indicated otherwise in writing. We believe that a conservative, risk-averse approach to fixed income management will provide both steady incremental outperformance, and low relative volatility. The disciplined process we employ in an effort to realize this philosophy is generally grounded in four key decisions: • • • • Constraint of portfolio duration within a narrow range relative to the benchmark in order to limit exposure to market and interest rate risk. Strategic allocations to key sectors to add value relative to the benchmark. Proactive management of term structure to add value in different yield curve environments. Security selection based on rigorous credit and relative value analysis and broad diversification of nongovernment issuers. Within our Fixed Income strategy, we use the following sub-strategies in managing client accounts, provided that such sub-strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: • Duration Constraints. • We adhere to a discipline of generally maintaining duration within a narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio management team rebalances client portfolios to their current duration targets on a periodic basis. The risk of constraining duration is that the client may not participate fully in a large rally in bond prices. Sector Allocation . We allocate client assets to various sectors of the fixed income market, including US Treasury obligations, federal agency securities, corporate notes, mortgage- backed securities and others, based on our quantitative and qualitative analysis in order to manage client exposure to a given sector and to provide exposure to sectors we believe ADV Part 2A, Appendix 1: Wrap Brochure Page 10 of 15 Walsh & Associates, LLC  • have good value. The risk of sector allocation is that clients may not participate fully in an increase in value in any specific sector. Security Selection. We use externally generated credit research to evaluate securities we are considering for purchase. The ultimate decision to purchase or sell a security is based on the firm’s evaluation of the current price for the security. The risk of security selection is that the methods of analysis employed will not provide accurate measurement of the risk association with each individual security. • Cash Balances. We generally invest clients’ cash balances in money market funds, FDIC- insured CDs, high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to achieve the highest return on our clients’ cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to asset management, as applicable. Please Note: Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and client account(s) could enjoy a gain, it is also possible that the stock market may decrease, and their account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the stock market, are appropriately diversified in their investments and ask us any questions they may have. We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to the client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Item 7: Client Information Provided to Portfolio Manager(s) Our firm communicates with clients’ portfolio manager(s) on a regular basis as needed to ensure their most current investment goals and objectives are understood by their portfolio manager(s). In most cases, our firm will communicate such information as part of our regular investment management duties. Nevertheless, our firm will also communicate information to their portfolio manager(s) when clients ask us to, when market or economic conditions make it prudent to do so, etc. ADV Part 2A, Appendix 1: Wrap Brochure Page 11 of 15 Walsh & Associates, LLC  Item 8: Client Contact with Portfolio Manager(s) Clients are always free to directly contact their portfolio manager(s) with any questions or concerns they have about their portfolios or other matters. Item 9: Additional Information We have determined that our firm and management have no disciplinary information to disclose. We participate in LPL Financial’s hybrid RIA program. As such, our investment adviser representatives are also registered representatives with LPL, in which all brokerage transactions will be implemented through LPL. Investment adviser representatives are required to implement brokerage trades in this manner as a result of them being registered representatives with LPL. This relationship will be disclosed to all clients prior to any transactions being implemented. As a result of this relationship, we do not recommend directed brokerage trades, negotiate fees or commissions or receive additional incentives from other broker/dealers for trades executed through them. However, clients will be made aware that as registered representatives, the investment adviser representatives receive services including but not limited to: administrative functions including portfolio pricing, account statement generation, fee calculations, back-office support, trade execution and research. Clients are not obligated to implement transactions through the investment adviser representatives in their separate capacities as registered representatives. Clients’ trades will always be implemented based on the goals and objectives of the client and not on the incentives to the representatives for implementing the trades. Our firm’s management persons will only receive commissions for securities recommendations they make to brokerage clients in non-advisory accounts. Compensation for brokerage commissions of registered representatives of LPL are paid directly to the registered representative by LPL in their individual capacity and separate from Walsh & Associates, LLC. Our advisory representatives may also be licensed to sell insurance products. As such, they may have an incentive to sell and recommend insurance products to advisory clients. When such recommendations or sales are made, a conflict of interest exists as our representative may earn insurance commissions for the sale of those products. Clients are under no obligation to purchase insurance products recommended to them by our advisory representatives. ADV Part 2A, Appendix 1: Wrap Brochure Page 12 of 15 Walsh & Associates, LLC  We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, to prevent conflicts of interest, we have in place a set of procedures (including a pre- clearing procedure) with respect to transactions effected by our members, officers and employees 1 . To monitor compliance with our personal trading policy, our firm’s for their personal accounts Chief Compliance Officer has access to all firm employee personal accounts through LPL’s ClientWorks system. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. We review accounts on at least an annual basis for our clients subscribing to our Wrap Asset Portfolio Management and Wrap Comprehensive Portfolio Management services. The nature of these reviews are to learn whether clients’ accounts are in line with their investment objectives and appropriately positioned based on market conditions and investment policies, if applicable. Only our Financial Advisors will conduct reviews. 1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. ADV Part 2A, Appendix 1: Wrap Brochure Page 13 of 15 Walsh & Associates, LLC  We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. We do not provide written reports to clients unless asked to do so. Verbal reports to clients take place on at least an annual basis when we meet with clients who subscribe to our Wrap Asset Management and Wrap Comprehensive Portfolio Management services. We provide discretionary portfolio management services where the investment advice provided is custom tailored to meet the needs and investment objectives of each client. Accordingly, we are authorized to perform various functions, at the client’s expense, without further approval from the client. Such functions include the determination of securities to be purchased/sold and the amount of securities to be purchased/sold. We do not have discretionary authority over the broker or dealer to be used. We shall recommend LPL Financial. LPL is the broker-dealer with which our representatives are also associated. As a result of the individual association of our representatives with LPL, we are generally required to utilize the brokerage/custodial services of LPL for investment advisory accounts. Our general policies relative to the execution of client securities brokerage transactions are as follows: In seeking “best execution”, the determinative factor is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution. LPL also takes into consideration the full range of a broker-dealer's services including execution capability, commission rates, and responsiveness. Although LPL will seek competitive commission rates, it may not necessarily obtain the lowest possible commission rates for all account transactions. Over-the-Counter (OTC) securities transactions are generally effected based on two (2) separate broker-dealers: (1) a “dealer” or “principal” acting as market maker; and (2) the executing broker-dealer that acts in an agency capacity. Dealers executing principal transactions typically include a mark-up/down, which is included in the offer or bid price of the securities purchased or sold. In addition to the dealer mark-up/down, the client may also incur the transaction fee imposed by the executing broker-dealer. We do not receive any portion of the dealer mark-up/down or the executing broker-dealer transaction fee. ADV Part 2A, Appendix 1: Wrap Brochure Page 14 of 15 Walsh & Associates, LLC  Transactions for each client account will be effected independently. We individually review each client’s account and place trades accordingly. Despite being purchased or sold at approximately the same time all clients’ transactions will incur individual transaction fees. We may receive from LPL or a mutual fund company, without cost and/or at a discount support services and/or products, to assist us to better monitor and service client accounts maintained at such institutions. Included within the support services we may receive investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by us to assist us in our investment advisory business operations. Our clients do not pay more for investment transactions effected and/or assets maintained at LPL as result of this arrangement. There is no commitment made by us to LPL or any other institution as a result of the above arrangement. In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). We are not required to provide financial information in this Brochure because: • • • We do not require the prepayment of more than $1,200 in fees and six or more months in advance. We do not take custody of client funds or securities. We have never been the subject of a bankruptcy proceeding. ADV Part 2A, Appendix 1: Wrap Brochure Page 15 of 15 Walsh & Associates, LLC