WARNER GROUP LLC

Item 1: Cover Sheet FORM ADV PART 2A INFORMATIONAL BROCHURE Warner Wealth 869 Boston Post Road Madison, CT 06443 (203) 929-2727 June 6, 2025 This brochure provides information about the qualifications and business practices of Warner Group LLC (“Warner Wealth”). If you have any questions about the contents of this brochure, please contact us at (203) 929-2727. 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. Our registration does not imply a certain level of skill or training. Additional information about Warner Group LLC (CRD# 334877) is also available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2: Statement of Material Changes In this Item it is required to discuss any material changes which have been made to the brochure. There are currently no material changes to report. Item 3: Table of Contents Item 1: Cover Sheet .................................................................................................................................... 1 Item 2: Statement of Material Changes ...................................................................................................... 2 Item 3: Table of Contents ........................................................................................................................... 2 Item 4: Advisory Business ......................................................................................................................... 3 Item 5: Fees and Compensation ................................................................................................................. 5 Item 6: Performance-Based Fees ................................................................................................................ 7 Item 7: Types of Clients ............................................................................................................................. 7 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 8 Item 9: Disciplinary Information .............................................................................................................. 11 Item 10: Other Financial Industry Activities and Affiliations .................................................................... 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 12 Item 12: Brokerage Practices ..................................................................................................................... 13 Item 13: Review of Accounts ..................................................................................................................... 16 Item 14: Client Referrals and Other Compensation ................................................................................... 16 Item 15: Custody ........................................................................................................................................ 17 Item 16: Investment Discretion .................................................................................................................. 17 Item 17: Voting Client Securities ............................................................................................................... 18 Item 18: Financial Information .................................................................................................................. 18 2  INFORMATIONAL BROCHURE Warner Wealth Item 4: Advisory Business Warner Group LLC (“Warner Wealth”) is owned by James A. Warner and was founded with the mission of guiding clients through the various aspects of their financial lives. Warner Wealth strives to align client short and long-term goals with the firm’s tools and strategies so clients can move through life, with all its ever-evolving challenges and milestones, with confidence and knowing Warner Wealth is here to serve as a professional resource for clients and their families. Financial Planning Individuals and Families Warner Wealth provides financial planning services to individuals and their families to help them plan and prepare for the future. Planning services include but are not limited to retirement planning, estate planning, high-level tax planning, and protection planning. Warner Wealth meets with clients to establish their current financial situation through discussion and gathering of data such as income, expenses, and current assets to identify client needs for the short-term (1 year), the mid-term (2 to 5 years) and the long-term (5 years or longer). Entrepreneurs Warner Wealth works with entrepreneurs and business owners to plan for the present as well as the future for themselves and their businesses. This type of planning includes, but is not limited to, cash management, employee retirement and benefits, succession planning, restructuring, and business strategy/consulting. Warner Wealth brings knowledge and personal experience to planning topics such as strategic planning, scaling the business and growth strategies. Warner Wealth has a network of professionals such as CPAs and attorneys to assist clients with tax and estate planning and business planning strategies. Clients are under no obligation to use the services of the professionals Warner Wealth refers. Wealth Management Individuals and Families Warner Wealth creates investment strategies for clients and their families designed to fit the client’s unique financial situation including personal risk tolerance, time horizon and goals. The investment strategy takes into account the different needs for each client and is customized to fit those needs. It is important to Warner Wealth to work with the multiple generations, especially the next generation in families to promote financial literacy and incorporate them into the process through active conversations with the goal of providing a broader view of what the investment strategies are trying to accomplish now and in the future. The strategy can incorporate an array of investment products including, but not limited to, mutual funds, stocks, bonds, ETFs, annuities, structured products and 529 plans. The client engages Warner Wealth to provide discretionary investment advisory services. When Warner Wealth is engaged to 3  provide asset management services on a discretionary basis, Warner Wealth will monitor client accounts to ensure that they are meeting asset allocation requirements. On behalf of our clients, if any changes are needed to the investments, Warner Wealth will make those changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. Clients may at any time place restrictions on the types of investments Warner Wealth may use on the client’s behalf, or on the allocations to each security type. Clients will receive written or electronic confirmations from the account custodian after any changes are made to the client account. Clients will also receive statements, at least quarterly, from the account custodian. Entrepreneurs Warner Wealth works with entrepreneurs and business owners to create investment strategies that are designed to optimize business and tax strategies. Warner Wealth will work the client’s accounting professionals to create an investment strategy while looking at all aspects of the business. Warner Wealth believes in a holistic approach where the investment strategy is not just about the investments in the strategy, but it addresses the entrepreneurs life and personal goals, retirement goals and the goals for the business. The client engages Warner Wealth to provide discretionary investment advisory services. When Warner Wealth is engaged to provide asset management services on a discretionary basis, Warner Wealth will monitor client accounts to ensure that they are meeting asset allocation requirements. On behalf of our clients, if any changes are needed to the investments, Warner Wealth will make those changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. Clients may at any time place restrictions on the types of investments Warner Wealth may use on the client’s behalf, or on the allocations to each security type. Clients will receive written or electronic confirmations from the account custodian after any changes are made to the client account. Clients will also receive statements, at least quarterly, from the account custodian. Warner Wealth may provide advisory services through certain programs sponsored by LPL Financial LLC (LPL”), a registered investment adviser and broker-dealer. Below is a brief description of each LPL custodied advisory program available to Warner Wealth. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. Automated Investment Program – Guided Wealth Portfolios Warner Wealth does offer an automated investment program for clients through LPL’s Guided Wealth Portfolios (“GWP”). GWP is an advisor-enhanced digital advice program that offers clients the ability to participate in a centrally managed investment program, which is made available to users and clients through a web-based, interactive account management portal. Clients are required to maintain an active profile in the account management portal to participate in the program. Clients select from one of the following goals for their account: retirement, major purchase, or general investing. Based on information provided by the client, the client is assigned a model portfolio constructed by LPL. Warner Wealth determines the suitability of the Program for the client and an appropriate investment allocation track for the client. Clients authorize LPL on a discretionary basis to purchase and sell securities based upon the model portfolio. Program securities currently include a limited universe of ETFs but may include mutual funds in the future. Clients should review the GWP Program Brochure for more detailed information, available at lpl.com/disclosures.html. 4  A minimum account value of $5,000 is required to enroll in GWP. Optimum Market Portfolios Program (“OMP”) OMP is a professionally managed mutual fund asset allocation program in which LPL and Warner Wealth provide ongoing investment advice and management. Warner Wealth obtains the necessary financial data from the client, assists the client in determining the suitability of the program and assists the client in setting an appropriate investment objective. Warner Wealth selects a model portfolio of mutual funds comprised of Optimum Funds Class I shares, designed by LPL’s Research Department consistent with the client’s stated investment objective. Clients grant LPL discretionary trading authority to sell previously purchased securities and purchase and sell Optimum Funds to track the model portfolio. Clients should review the OMP Program Brochure for more detailed information, available at lpl.com/disclosures.html. LPL generally requires a minimum account value of $1,000 for OMP, but additional contributions may be required for account sizes below $10,000. In certain instances, LPL will permit a lower minimum account size. Retirement Plan Rollovers – No Obligation / Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Warner Wealth recommends that a client roll over their retirement plan assets into an account to be managed by Warner Wealth, such a recommendation creates a conflict of interest if Warner Wealth will earn an advisory fee on the rolled over assets. This conflict is mitigated by ensuring clients understand rollover options and that there is no obligation to roll over retirement plan assets to an account managed by Warner Wealth. Assets Under Management Because this is the initial filing for Warner Wealth there are not assets under management to report. Item 5: Fees and Compensation Fees Charged A. All investment management clients will be required to execute an Investment Advisory Agreement that will describe the type of asset management services to be provided and the fees, among other items. Clients are advised that they may pay fees that are higher or lower than fees they may pay another advisor for the same services and may in fact pay lower fees for comparable services from other sources. Clients are under no obligation at any time to engage or to continue to engage Warner Wealth for investment services. The client can determine to engage Warner Wealth to provide discretionary investment advisory services on a negotiable basis. Warner Wealth’s annual investment advisory fee shall vary (up to 2.0% of the total assets placed under Warner Wealth’s management) and shall be based upon various 5  objective and subjective factors, including, but not limited to, the amount of the assets placed under Warner Wealth’s direct management, the complexity of the engagement, and the level and scope of the overall investment advisory services to be rendered. In some instances, Warner Wealth will “household” a group of accounts for the purpose of determining an appropriate fee (for example, a family). This is not done for every family, but only in limited circumstances where the firm believes it to be appropriate. The values used for calculation of advisory fees are produced by the account custodian(s), and the specific value used is the gross market value as of the last day of the previous quarter. In calculating the market value of a client’s assets, assets allocated to cash or a cash proxy, such as a money market account, will be included in the calculation of assets under management. Warner Wealth does bill on cash and margin. GWP clients are charged an account fee consisting of an LPL program fee of 0.35% and an advisor fee of up to 1.00%. LPL Research currently serves as the sole portfolio strategist and does not charge a fee for its services. OMP accounts are subject to a maximum fee of 2.5%. Account fees for LPL programs are payable quarterly in advance. LPL serves as program sponsor, co- investment adviser and broker-dealer for the LPL advisory programs. Warner Wealth and LPL may share in the account fee and other fees associated with program accounts. Associated persons of Warner Wealth may also be registered representatives of LPL. Warner Wealth receives compensation as a result of a client’s participation in an LPL program. Depending on, among other things, the type and size of the account, type of securities held in the account, changes in its value over time, the ability to negotiate fees or commissions, the historical or expected size or number of transactions, and the number and range of supplementary advisory and client-related services provided to the client, the amount of this compensation may be more or less than what Warner Wealth would receive if the client participated in other programs, whether through LPL or another sponsor, or paid separately for investment advice, brokerage and other services. Clients should consider the level and complexity of the advisory services to be provided when negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with Warner Wealth. Please refer to the relevant LPL Form ADV program brochure for a more detailed discussion of conflicts of interest. Fee Payment B. The fee is paid quarterly in advance and comes due on the last day of the calendar quarter of the stated billing cycle based on the balance on that day. In calculating the market value of a client’s assets, assets allocated to cash or a cash proxy, such as a money market account, will be included in the calculation of assets under management. The calculation of the fee is done by the custodian and once the calculation is made, the custodian will deduct the fee from your account and remit it to Warner Wealth. For advisory accounts custodied at LPL, unless otherwise instructed by Warner Wealth, LPL will deduct Warner Wealth’s fee quarterly in advance; however, for the initial fee deduction, LPL will deduct the Warner Wealth’s fee at the beginning of the quarter following the establishment of the account and will include a prorated fee for the initial quarter in addition to the quarterly Warner Wealth fee for the upcoming quarter. Subsequent fee deductions will be made at the beginning of each quarter based on the value of the account assets as of the close of business on the last business day of the 6  preceding quarter. Additional deposits and withdrawals will be added or subtracted from the assets, which may lead to an adjustment of Warner Wealth’s fee. If LPL is notified by Warner Wealth or the client of the termination or deactivation of the account’s advisory account status at LPL, LPL will process a prorated refund of Warner Wealth’s fees that were prepaid based upon the number of days remaining in the quarter after the notice of termination to LPL. Other Fees C. There are a number of other fees that can be associated with holding and investing in securities. Expenses of a mutual fund or ETF will not be included in management fees, as they are deducted from the value of the shares by the manager. When selecting mutual funds that have multiple share classes for recommendation to clients, Warner Wealth will take into account the internal fees and expenses associated with each share class, and it is Warner Wealth’s policy to choose the lowest-cost share class available, absent circumstances that dictate otherwise. For complete discussion of expenses related to each mutual fund or ETF, you should read a copy of the prospectus issued by that fund. Warner Wealth can provide or direct you to a copy of the prospectus for any fund that we recommend to you. Fees charged by independent third-party managers are also separate and additional to any fees paid to Warner Wealth, and such managers will be authorized to separately debit fees from client accounts. Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and custodial issues. Pro-rata Fees D. If a client becomes a client during a quarter, they will pay a management fee for the number of days left in that quarter. If clients terminate the relationship during a quarter, they will be entitled to a refund of any management fees for the remainder of the quarter they may have prepaid. Once the notice of termination is received, the custodian(s) will assess pro-rated fees for the number of days between the end of the prior billing period and the date of termination to be paid in whatever way clients direct (check, wire). Warner Wealth will cease to perform services, including processing trades and distributions, upon termination. Assets not transferred from terminated accounts within 30 (thirty) days of termination may be “de-linked”, meaning they will no longer be visible to Warner Wealth and will become a retail account with the custodian. Compensation for the Sale of Securities. E. Warner Wealth does not accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees Neither Warner Wealth nor any supervised person of Warner Wealth accepts performance-based fees. Item 7: Types of Clients Clients advised may include individuals, families, trusts, charitable organizations and foundations, and businesses. Warner Wealth does not impose a stated minimum fee or minimum portfolio value for starting or maintaining an investment advisory relationship. 7  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss It is important for you to know and remember that all investments carry risks. Investing in securities involves risk of loss that clients should be prepared to bear. Strategies and Methods of Analysis Warner Wealth utilizes a core and satellite approach to portfolio construction with the objective of providing resilience and flexibility in market downturns while still having exposure to growth. The core is a passive strategy utilizing structured products, mutual funds, and ETFs making up the majority of the client’s household liquid net worth. The satellite portion of the portfolio is focused on growth and is diversified in a thematic manner such as industry sectors, geographical location, and other means where Warner Wealth believes there is opportunity and is evaluated every couple of months to determine if changes are needed given the economic environment at that point in time. Warner Wealth utilizes ETFs and mutual funds in the satellite portion of portfolios. Each client’s portfolio will be invested according to that client’s investment objectives, which are ascertained through the financial planning process or through the discovery process. To accommodate client restrictions mutually agreed upon between the client and Warner Wealth, Warner Wealth will develop a customized portfolio around the restrictions. Clients may have different needs than others within the same investment objectives. Accordingly, not all clients in each investment program will have the exact same allocations used. Warner Wealth may periodically recommend changes to the investment strategies and client portfolios to meet the guidelines of the asset allocation for the program or an individual client’s objectives. It is important to remember that because market conditions can vary greatly, your asset allocation guidelines are not necessarily strict rules. Rather, accounts and portfolios are reviewed individually and may deviate from the guidelines as Warner Wealth believes necessary. When Warner Wealth makes changes to an investment strategy, these changes may not be made simultaneously. Rather, some accounts may be modified before others. This may result in accounts being traded earlier inadvertently having an advantage over accounts traded later. Additionally, as assets are transitioned from a client’s prior advisors to Warner Wealth, clients may hold legacy securities and may place restrictions on individual security types. Legacy securities are those that a client owned prior to or separate from its Warner Wealth portfolio. If a client transitions mutual fund shares to Warner Wealth that are not the lowest-cost share class, and Warner Wealth is not recommending disposing of the security altogether, Warner Wealth will attempt to convert such mutual fund share classes into the lowest-cost share classes the client is eligible for, taking into account any adverse tax consequences associated with such conversion. Use of Artificial Intelligence Warner Wealth utilizes artificial intelligence platforms for the purpose of non-specific research regarding general industry metrics, public filings summaries, and general economic indicators. In addition, Warner Wealth utilizes platforms for the purpose of assisting in creating marketing materials or general communications. Upon client affirmative acknowledgement, Warner Wealth utilizes approved artificial intelligence platforms to assist with meeting notes and action items. Warner Wealth will always evaluate the results of any artificial intelligence use and will not unilaterally accept the output from artificial intelligence platforms for the purpose of determining investment advice. 8  Risk of Loss There are always risks to investing. Clients should be aware that all investments carry various types of risk including the potential loss of principal that clients should be prepared to bear. It is impossible to name all possible types of risks. Among the risks are the following: • Political Risks. Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world. • General Market Risks. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations. • Currency Risk. When investing in another country using another currency, the changes in the value of the currency can change the value of your security value in your portfolio. • Regulatory Risk. Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. • Tax Risks Related to Short Term Trading: Clients should note that Warner Wealth may engage in short-term trading transactions. These transactions may result in short term gains or losses for federal and state tax purposes, which may be taxed at a higher rate than long term strategies. Warner Wealth endeavors to invest client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals regarding the transactions in client accounts. • Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. • Business Risk. This can be thought of as certainty or uncertainty of income. Management comes under business risk. Cyclical companies (like automobile companies) have more business risk because of the less steady income stream. On the other hand, fast food chains tend to have steadier income streams and therefore, less business risk. • Financial Risk. The amount of debt or leverage determines the financial risk of a company. • Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk. • Margin Risk. “Margin” is a tool used to maximize returns on a given investment by using securities in a client account as collateral for a loan from the custodian to the client. The proceeds of that loan are then used to buy more securities. Margin carries a higher degree of risk than investing without margin. • Short Sales. “Short sales” are a way to implement a trade in a security Warner Wealth feels is overvalued. In a “long” trade, the investor is hoping the security increases in price. Thus, in a long trade, the amount of the investor’s loss (without margin) is the amount paid for the security. In a short sale, the investor is hoping the security decreases in price. However, unlike a long trade where the price of the security can only go from the purchase price to zero, in a short sale, the price of the security can go infinitely upwards. Thus, in a short sale, the potential for loss is unlimited and unknown, where the potential for loss in a long trade is limited and knowable. Warner Wealth utilizes short sales only when the client’s risk tolerances permit. • Risks specific to private placements, sub-advisors and other managers. If we invest some of your assets with another advisor, including a private placement, there are additional risks. These include risks that the other manager is not as qualified as we believe them to be, that the investments 9  they use are not as liquid as we would normally use in your portfolio, or that their risk management guidelines are more liberal than we would normally employ. • Information Risk. All investment professionals rely on research in order to make conclusions about investment options. This research is always a mix of both internal (proprietary) and external (provided by third parties) data and analyses. Even an adviser who says they rely solely on proprietary research must still collect data from third parties. This data, or outside research is chosen for its perceived reliability, but there is no guarantee that the data or research will be completely accurate. Failure in data accuracy or research will translate to a compromised ability by the adviser to reach satisfactory investment conclusions. • Small Companies. Some investment opportunities in the marketplace involve smaller issuers. These companies may be starting up or are historically small. While these companies sometimes have potential for outsized returns, they also have the potential for losses because the reasons the company is small are also risks to the company’s future. For example, a company’s management may lack experience, or the company’s capital for growth may be restricted. These small companies also tend to trade less frequently that larger companies, which can add to the risks associated with their securities because the ability to sell them at an appropriate price may be limited compared to the markets as a whole. Not only do these companies have investment risk, if a client is invested in such small companies and requests immediate or short term liquidity, these securities may require a significant discount to value in order to be sold in a shorter time frame. • Concentration Risk. While Warner Wealth selects individual securities, including mutual funds, for client portfolios based on an individualized assessment of each security, this evaluation comes without an overlay of general economic or sector specific issue analysis. This means that a client’s equity portfolio may be concentrated in a specific sector, geography, or sub-sector (among other types of potential concentrations), so that if an unexpected event occurs that affects that specific sector or geography, for example, the client’s equity portfolio may be affected negatively, including significant losses. • Transition risk. As assets are transitioned from a client’s prior advisers to Warner Wealth there may be securities and other investments that do not fit within the asset allocation strategy selected for the client. Accordingly, these investments will need to be sold in order to reposition the portfolio into the asset allocation strategy selected by Warner Wealth. However, this transition process may take some time to accomplish. Some investments may not be unwound for a lengthy period of time for a variety of reasons that may include unwarranted low share prices, restrictions on trading, contractual restrictions on liquidity, or market-related liquidity concerns. In some cases, there may be securities or investments that are never able to be sold. The inability to transition a client's holdings into recommendations of Warner Wealth may adversely affect the client's account values, as Warner Wealth’s recommendations may not be able to be fully implemented. • Restriction Risk. Clients may at all times place reasonable restrictions on the management of their accounts. However, placing these restrictions may make managing the accounts more difficult, thus lowering the potential for returns. • Risks Related to Investment Term & Liquidity. Securities do not follow a straight line up in value. All securities will have periods of time when the current price of the security is not an accurate measure of its value. If you require us to liquidate your portfolio during one of these periods, you will not realize as much value as you would have had the investment had the opportunity to regain its value. Further, some investments are made with the intention of the investment appreciating over an extended period of time. Liquidating these investments prior to their intended time horizon may result in losses. • ESG Risk. ESG is considered upon client request. When investing using ESG considerations, there is no guarantee that Warner Wealth will successfully implement and make investments that create positive environmental, social or governance (“ESG”) impact while enhancing long-term growth and achieving financial returns. Considering ESG qualities when evaluating an investment may result in the selection or exclusion of certain investments based on Warner Wealth’s view of certain ESG- 10  related factors versus the view of a mutual fund portfolio manager’s view. As a result, the integration of ESG-related data carries with it the risk that these investments may underperform investments that do not take ESG-related factors into account and may not meet the same definition of ESG values a client expects. • Structured Products. Structured products are designed to facilitate highly customized risk-return objectives. While structured products come in many different forms, they typically consist of a debt security that is structured to make interest and principal payments based upon various assets, rates or formulas. Many structured products include an embedded derivative component. Structured products may be structured in the form of a security, in which case these products may receive benefits provided under federal securities law, or they may be cast as derivatives, in which case they are offered in the over-the-counter market and are subject to no regulation. Investing in structured products includes significant risks, including valuation, lack of liquidity, price, credit and market risks. The relative lack of liquidity is due to the highly customized nature of the investment and the fact that the full extent of returns from the complex performance features is often not realized until maturity. Another risk with structured products is the credit quality of the issuer. Although the cash flows are derived from other sources, the products themselves are legally considered to be the issuing financial institution's liabilities. The vast majority of structured products are from high-investment-grade issuers only. Also, there is a lack of pricing transparency. There is no uniform standard for pricing, making it harder to compare the net-of-pricing attractiveness of structured product offerings than it is, for instance, to compare the net expense ratios of different mutual funds or commissions among broker-dealers. Item 9: Disciplinary Information In 2017, our Chief Compliance Officer, Ashleigh Swayze, signed a Consent Order with the Connecticut Department of Banking and Insurance. The underlying matter involved a client of Ms. Swayze’s that failed to register as an investment adviser representative in Connecticut. The state felt that Ms. Swayze’s firm should have followed this client’s activities and required her to register, despite not being engaged to do so. Item 10: Other Financial Industry Activities and Affiliations A. Broker-dealer Certain investment adviser representatives of Warner Wealth are also associated with LPL Financial as broker-dealer registered representatives (“Dually Registered Persons”). In their capacity as registered representatives of LPL Financial, certain Dually Registered Persons may earn commissions for the sale of securities or investment products that they recommend for brokerage clients. They do not earn commissions on the sale of securities or investment products recommended or purchased in advisory accounts through Warner Wealth. Clients have the option of purchasing many of the securities and investment products we make available to you through another broker-dealer or investment adviser. However, when purchasing these securities and investment products away from Warner Wealth, you will not receive the benefit of the advice and other services we provide. While LPL Financial does not participate in, or influence the formulation of, the investment advice Warner Wealth provides, certain supervised persons of Warner Wealth 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 11  accounts through any broker-dealer or custodian that is not approved by LPL Financial. As a result, the use of other trading platforms must be approved not only by Warner Wealth, but also by LPL Financial. Clients should also be aware that for accounts where LPL Financial serves as the custodian, Warner Wealth is limited to offering services and investment vehicles that are approved by LPL Financial, 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 Financial. 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 Financial is responsible under FINRA rules for supervising certain business activities of Warner Wealth and its Dually Registered Persons that are conducted through broker-dealers and custodians other than LPL Financial. LPL Financial charges a fee for its oversight of activities conducted through these other broker-dealers and custodians. This arrangement presents a conflict of interest because Warner Wealth has a financial incentive to recommend that you maintain your account with LPL Financial rather than with another broker-dealer or custodian to avoid incurring the oversight fee. If you would like a copy of the LPL Financial privacy policy, please contact Warner Wealth at (203) 929-2727. B. Futures Commission Merchant/Commodity Trading Advisor The principal of Warner Wealth, nor any related persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Relationship with Related Persons James A. Warner is a minority owner in Warner Allred Tax Solutions, LLC, which provides tax and accounting services to individuals and businesses. This is a conflict of interest where the recommendation by Mr. Warner of Warner Allred Tax Solutions, LLC stands to financially benefit Mr. Warner. We attempt to mitigate this conflict by disclosing the common ownership between Warner Wealth and Warner Allred Tax Solutions, LLC to the public, requiring each client that may have a dual relationship to sign a disclosure acknowledging the relationship. Additionally, it is required that all persons associated with Warner Wealth adhere to the firm’s Code of Ethics requiring related persons to put client interests ahead of their own. D. Recommendations of Other Advisers Warner Wealth nor any of its related persons recommend other advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 12  A copy of our Code of Ethics is available upon request. Our Code of Ethics includes A. discussions of our fiduciary duty to clients, political contributions, gifts, entertainment, and trading guidelines. Not applicable. Warner Wealth does not recommend to clients that they invest in any security B. in which Warner Wealth or any principal thereof has any financial interest. On occasion, an employee of Warner Wealth may purchase for his or her own account C. securities which are also recommended for clients. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades are reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. D. On occasion, an employee of Warner Wealth may purchase for his or her own account securities which are also recommended for clients at the same time the clients purchase the securities. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades are reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. Item 12: Brokerage Practices Recommendation of Broker-Dealer A. In appropriate situations, Warner Wealth will generally recommend that clients establish a brokerage account with LPL Financial to maintain custody of clients’ assets and to effect trades for their accounts. LPL Financial provides brokerage and custodial services to independent investment advisory firms, including Warner Wealth. For Warner Wealth’s accounts custodied at LPL Financial, LPL Financial generally is compensated by clients through commissions, trails, or other transaction-based fees for trades that are executed through LPL Financial or that settle into LPL Financial accounts. For IRA accounts, LPL Financial generally charges account maintenance fees. In addition, LPL Financial also charges clients miscellaneous fees and charges, such as account transfer fees. LPL Financial charges Warner Wealth an asset-based administration fee for administrative services provided by LPL Financial. Such administration fees are not directly borne by clients but may be taken into account when Warner Wealth negotiates its advisory fee with clients. Clients should be aware that for accounts where LPL Financial serves as the custodian, Warner Wealth is limited to offering services and investment vehicles that are approved by LPL Financial 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 Financial. Clients should understand that not all investment advisers require that clients custody their accounts and trade through specific broker-dealers. 13  Benefits Received by Warner Wealth Warner Wealth receives support services and/or products from LPL Financial, many of which assist Warner Wealth to better monitor and service program accounts maintained at LPL Financial; however, some of the services and products benefit Warner Wealth and not client accounts. These support services and/or products may be received without cost, at a discount, and/or at a negotiated rate. Such compensation provided to Warner Wealth includes other types of compensation, such as bonuses, awards or other things of value offered by LPL to Warner Wealth, and may include the following: • Payments based on production; • Equity awards from LPL’s parent company, LPL Financial Holdings Inc., consisting of awards of either restricted stock units or stock options to purchase stock, in each case subject to satisfaction of vesting and other conditions; • Reimbursement or credit of fees that Warner Wealth pays to LPL for items such as administrative services or technology fees; • Free or reduced-cost marketing materials; • Payments in connection with the transition of association from another broker-dealer or investment advisor firm to LPL; • Payments in the form of repayable or forgivable loans; • Advances of advisory fees; and/or • Attendance at LPL conferences and events. LPL Financial may provide these services and products directly or may arrange for third party vendors to provide the services or products to Warner Wealth. In the case of third party vendors, LPL Financial may pay for some or all of the third party’s fees. These support services are provided to Warner Wealth based on the overall relationship between Warner Wealth and LPL Financial. It is not the result of soft dollar arrangements or any other express arrangements with LPL Financial that involves the execution of client transactions as a condition to the receipt of services. Warner Wealth will continue to receive the services regardless of the volume of client transactions executed with LPL Financial. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by Warner Wealth 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 Warner Wealth receives these benefits from LPL Financial, there is a potential conflict of interest. The receipt of these products and services presents a financial incentive for Warner Wealth to recommend that its clients use LPL Financial’s custodial platform rather than another custodian’s platform. For a further listing of potential conflicts, please refer to LPL Financial’s Brokerage Compensation and Conflicts Disclosure, available at lpl.com/disclosures.html. Limitations due to LPL Licensing/Registration The individuals that are licensed as registered representatives of LPL Financial are subject to regulations that restrict them from conducting securities transactions away from LPL Financial without written authorization from LPL Financial. Clients should, therefore, be aware that for accounts where LPL Financial serves as the custodian, Warner Wealth is limited to offering services and investment vehicles that are approved by LPL Financial and may be prohibited from offering services and investment vehicles that may be available through other broker-dealers and custodians. 14  LPL and Warner Wealth offer and recommend investment products only from investment sponsors with which LPL has entered into selling and distribution agreements. Other firms may offer products and services not available through LPL, or the same or similar investment products and services at lower cost. In addition, LPL may only offer certain products in a brokerage account, even though there is a version of the product that may be offered at a lower cost through an advisory account, and vice versa. Oversight Fee for Assets Held Away As stated previously, individuals associated with Warner Wealth are licensed as registered representatives of LPL Financial. As a result of this licensing relationship, LPL Financial is responsible for supervising certain activities of Warner Wealth to the extent Warner Wealth manages assets at a broker-dealer and custodian other than LPL Financial. LPL Financial charges a fee of up to 10 basis points to Warner Wealth for this oversight. This presents a conflict of interest in that Warner Wealth has a financial incentive to recommend that you maintain your account with LPL Financial rather than another custodian in order to avoid the oversight fee. However, to the extent Warner Wealth recommends you use LPL Financial for such services, it is because Warner Wealth believes 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 Financial. Aggregating Trades B. Commission costs per client may be lower on a particular trade if all clients in whose accounts the trade is to be made are executed at the same time. This is called aggregating trades. Instead of placing a number of trades for the same security for each account, Warner Wealth will, when appropriate, executed one trade for all accounts and then allocate the trades to each account after execution. If an aggregate trade is not fully executed, the securities will be allocated to client accounts on a pro rata basis, except where doing so would create an unintended adverse consequence (For example, if a pro rata division would result in a client receiving a fraction of a share, or a position in the account of less than 1%.) Any transaction costs associated with the aggregated trade will be allocated equally among all accounts involved including any firm employee accounts. Any exceptions from the pro-rata allocation procedure will be carefully explained and documented. Such exceptions may occur due to varying cash availability across accounts, divergent investment objectives and existing concentrations. Not all trades are aggregated since Warner Wealth has a number of investment advisor representatives who function independent of one another. This means the investment advisor representative decides when trades are conducted on the client accounts for their accounts. Additionally, clients may request a transaction at various times during the trading day in the same security. In this instance Warner Wealth takes direction from the client and will execute the trade when requested by the client. Therefore, different clients of Warner Wealth may receive different execution prices for the same securities transaction. Directed Brokerage Warner Wealth does not allow clients to direct brokerage. “Directing” brokerage means choosing to maintain all or some of their assets with a broker-dealer that is not recommended by Warner Wealth. Warner Wealth may be unable to achieve most favorable execution of client transactions if clients choose to direct brokerage. This may cost clients’ money because without the ability to direct brokerage Warner Wealth may not be able to aggregate orders to reduce transactions costs resulting in higher brokerage commissions and less favorable prices. 15  Transition Assistance LPL also provides various benefits and/or payments to Warner Wealth that are new to the LPL platform to assist them with the costs (including foregone revenues during account transition) associated with transitioning their business to LPL (collectively referred to as “Transition Assistance”). 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 Warner Wealth’s business, satisfying any outstanding debt owed to Warner Wealth ‘s prior firm, offsetting account transfer fees (ACATs) as a result of Warner Wealth’s 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 is often significant in relation to the overall revenue earned or compensation received by Warner Wealth at their prior firm. Such payments are generally based on the size of Warner Wealth’s business established at the prior firm. These payments are generally in the form of payments or loans to Warner Wealth with favorable interest rate terms as compared to other lenders, which are paid by LPL or forgiven by LPL based on years of service with LPL (e.g., if Warner Wealth remains with LPL for 5 years) and/or the scope of business engaged in with LPL. LPL does not verify that any payments made are actually used for such transition costs. The receipt of Transition Assistance creates a conflict of interest in that Warner Wealth has a financial incentive to recommend that a client open and maintain an account with the IAR and LPL for advisory, brokerage and/or custody services, and to recommend switching investment products or services where a client’s current investment options are not available through LPL, in order to receive the Transition Assistance benefit or payment, and in cases of businesses not supported by LPL, to further recommend that a client’s current holdings be reinvested in a program offering LPL does support. LPL and Warner Wealth’s attempt to mitigate these conflicts of interest by evaluating and recommending that clients use LPL’s services based on the benefits that such services provide to clients, rather than the Transition Assistance earned by Warner Wealth. However, clients should be aware of this conflict and take it into consideration in making a decision whether to establish or maintain a relationship with LPL. If LPL makes a loan to Warner Wealth, there is also a conflict of interest because LPL’s interest in collecting on the loan affects its ability to objectively supervise the registered representatives. Item 13: Review of Accounts All accounts and corresponding financial plans will be managed on an ongoing basis, with formal reviews with the client by a representative of Warner Wealth on at least an annual basis. However, it is expected that market conditions, changes in a particular client’s account, or changes to a client’s circumstances will trigger a review of accounts. The annual report in writing provided by Warner Wealth is intended to review asset allocation. All clients will receive statements and confirmations of trades directly from the custodian. Please refer to Item 15 regarding Custody. Item 14: Client Referrals and Other Compensation A. Economic Benefit Provided by Third Parties for Advice Rendered to Client. 16  Broker-Dealers. Please refer to Item 12, where we discuss recommendation of Broker-Dealers. Marketing Support. Some industry sponsors contribute to Warner Wealth for the cost of marketing events for our clients. This could include paying for travel, meals, entertainment and attendance at the marketing event. These events provide our clients with additional opportunities to be educated about services and investments that can be offered by Warner Wealth. These payments provide an incentive for Warner Wealth’s Financial Advisors to recommend investment products whose sponsors provide these additional support payments to us. Warner Wealth imposes an internal review and approval process to ensure that these payments are not unreasonably high (or otherwise inappropriate) under the circumstances. We do not permit payments for marketing events to be made directly to our Financial Advisors. B. Compensation to Non-Advisory Personnel for Client Referrals. Warner Wealth does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody There are two avenues through which Warner Wealth has custody of client funds; by directly debiting its fees from client accounts pursuant to applicable agreements granting such right, and potentially by permitting clients to issue standing letters of authorization (“SLOAs”). SLOAs permit a client to issue one document that directs Warner Wealth to make distributions out of the client’s account(s). Clients will receive statements directly from the account custodian, and copies of all trade confirmations directly from the account custodian. Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by the qualified custodian. Each month, the client will receive a statement from their account custodian showing all transactions in their account, including the fee. We encourage clients to carefully review the statements and confirmations sent to them by their custodian, and to compare the information on reports prepared by Warner Wealth against the information in the statements provided directly from the custodian. Please alert us of any discrepancies. In addition to the account custodian’s custody procedures, clients issuing SLOAs will be requested to confirm, in writing, that the accounts to which funds are distributed are parties unrelated to Warner Wealth or the account custodian. Item 16: Investment Discretion When Warner Wealth is engaged to provide asset management services on a discretionary basis, Warner Wealth will monitor your accounts to ensure that they are meeting your asset allocation requirements. If any changes are needed to your investments or managers, we will make the changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. You may receive at your request written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive statements at least quarterly from your account custodian. Clients engaging Warner Wealth on a discretionary basis will be asked to execute a Limited Power of Attorney (granting Warner Wealth the discretionary authority over the client accounts) as well as an Investment Advisory 17  Agreement that outlines the responsibilities of both the client and Warner Wealth. Item 17: Voting Client Securities Copies of Warner Wealth’s Proxy Voting Policies are available upon request. From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities may be permitted to vote on various types of corporate actions. Examples of these actions include mergers, tender offers, or board elections. Clients are required to vote proxies related to their investments, or to choose not to vote their proxies. Warner Wealth will not accept authority to vote client securities. Clients will receive their proxies directly from the custodian for the client account. Warner Wealth will not give clients advice on how to vote proxies. Item 18: Financial Information Warner Wealth does not require the prepayment of fees more than six (6) months or more in advance and therefore has not provided a balance sheet with this brochure. There are no material financial circumstances or conditions that would reasonably be expected to impair our ability to meet our contractual obligations to our clients. 18