WAYSTONE ADVISORS LLC

Waystone Advisors LLC Form ADV Part 2A – Disclosure Brochure Effective: February 4, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Waystone Advisors LLC (“Waystone Advisors” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (425) 484-0045 or by email at info@waystoneadvisors.com. Waystone Advisors is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Waystone Advisors to assist you in determining whether to retain the Advisor. Additional information about Waystone Advisors and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 328565. Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone: (425) 484-0045 | Website: https://waystoneadvisors.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Waystone Advisors. For convenience, the Advisor has combined these documents into a single disclosure document. Waystone Advisors believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Waystone Advisors encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the annual amendment filing on February 28, 2025: • The Advisor has changed their primary office address. Please see the cover page & footer for additional information. • The Advisor removed any references to Schwab throughout the brochure. • The Advisor has updated its assets under management. (Item 4.E) Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 328565. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (425) 484-0045 or by email at info@waystoneadvisors.com. Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ……………………………………………………………………………………………………….. 1 Item 2 – Material Changes ..................................................................................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................................................................................... 3 Item 4 – Advisory Services .................................................................................................................................................................................... 4 A. Firm Information ................................................................................................................................................................................................... 4 B. Advisory Services Offered ..................................................................................................................................................................................... 4 C. Client Account Management ................................................................................................................................................................................. 6 D. Wrap Fee Programs ............................................................................................................................................................................................... 6 E. Assets Under Management .................................................................................................................................................................................... 6 Item 5 – Fees and Compensation .......................................................................................................................................................................... 6 A. Fees for Advisory Services .................................................................................................................................................................................... 6 B. Fee Billing ............................................................................................................................................................................................................. 7 C. Other Fees and Expenses ....................................................................................................................................................................................... 8 D. Advance Payment of Fees and Termination ........................................................................................................................................................... 8 E. Compensation for Sales of Securities .................................................................................................................................................................... 9 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................................................................ 9 Item 7 – Types of Clients ....................................................................................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................................................... 9 A. Methods of Analysis .............................................................................................................................................................................................. 9 B. Risk of Loss ......................................................................................................................................................................................................... 10 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 ............................................................. 11 A. Code of Ethics ...................................................................................................................................................................................................... 11 B. Personal Trading with Material Interest ............................................................................................................................................................... 12 C. Personal Trading in Same Securities as Clients ................................................................................................................................................... 12 D. Personal Trading at Same Time as Client ............................................................................................................................................................ 12 Item 12 – Brokerage Practices ............................................................................................................................................................................ 12 A. Recommendation of Custodian[s] ....................................................................................................................................................................... 12 B. Aggregating and Allocating Trades ...................................................................................................................................................................... 13 Item 13 – Review of Accounts ............................................................................................................................................................................ 13 A. Frequency of Reviews ......................................................................................................................................................................................... 13 B. Causes for Reviews ............................................................................................................................................................................................. 13 C. Review Reports ................................................................................................................................................................................................... 13 Item 14 – Client Referrals and Other Compensation ....................................................................................................................................... 13 A. Compensation Received by Waystone Advisors .................................................................................................................................................. 13 B. Compensation for Client Referrals ...................................................................................................................................................................... 14 Item 15 – Custody ................................................................................................................................................................................................. 14 Item 16 – Investment Discretion ......................................................................................................................................................................... 14 Item 17 – Voting Client Securities ...................................................................................................................................................................... 14 Item 18 – Financial Information ......................................................................................................................................................................... 14 Form ADV Part 2B – Brochure Supplement(s)............................................................................................................................. ................ 15 Privacy Policy .............................................................................................................. ............................................ 23 Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 3  Item 4 – Advisory Services A. Firm Information Waystone Advisors LLC (“Waystone Advisors” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Washington. Waystone Advisors was founded in March 2022 and became a registered investment advisor in December 2023. Waystone Advisors is owned and operated by Austin Dean, CFP®, ChFC®, CLU®, RICP® (Chief Executive Officer and Financial Planner). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Waystone Advisors. For information regarding this Disclosure Brochure, please contact Stephanie Hebert-Roscoe (Chief Compliance Officer) at (425) 484-0045. B. Advisory Services Offered Waystone Advisors offers investment advisory services to individuals, high net worth individuals, trusts, estates, and businesses (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Waystone Advisors’ fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Waystone Advisors provides customized investment advisory solutions for its clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Waystone Advisors works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Waystone Advisors will then construct an investment portfolio, consisting of exchange-traded funds (“ETFs”) and/or mutual funds to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, individual bonds, unaffiliated money managers (See “Independent Managers” below), and/or other types of investments, as appropriate, to meet the needs of the Client. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Waystone Advisors’ investment strategies are primarily long-term focused, but the Advisor may buy, sell or reallocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Waystone Advisors will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Waystone Advisors evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Waystone Advisors may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Waystone Advisors may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Waystone Advisors may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 4  At no time will Waystone Advisors accept or maintain custody of a client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Use of Independent Managers – Waystone will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a client’s investment portfolio, based on the Client’s needs and objectives. In such instances, the Client will be required to authorize and enter into an investment management agreement with an Independent Manager that defines the terms in which the Independent Manager will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Client’s investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Use of Turnkey Asset Management Program – Waystone Advisors may periodically recommend and refer Clients to turnkey asset management programs (“TAMPs”) at Waystone Advisors’ discretion. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the TAMP that defines the terms in which the TAMP will provide its services. Waystone Advisors will remain the Client’s primary Advisor and oversee the Client’s investment allocation[s] and overall investment performance. While the TAMP will assume day-to-day investment management of the assets, Waystone Advisors will be responsible for establishing the Client’s investment objectives and recommending a TAMP’s investment strategy to meet those objectives. The Client will be provided with the TAMP’s Form ADV Part 2A (or a brochure that makes the appropriate disclosures). TAMPs may provide back-office administration services to Waystone Advisors, which can include research, trading and rebalancing, and administrative services such as Client account paperwork, Client billing, performance reporting, and investment due diligence. Waystone Advisors may not utilize all services offered by the TAMP. TAMPs typically rebalance Client portfolios according to the specified model or asset allocation selected by Waystone Advisors or according to the TAMP’s models. TAMPs are not responsible for the analysis of Waystone Advisors’ Clients’ financial situations, suitability requirements, asset allocations, or investment restrictions. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services Waystone Advisors will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and/or other areas of a client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 5  Waystone Advisors may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. C. Client Account Management Prior to engaging Waystone Advisors to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – Waystone Advisors, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – Waystone Advisors will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. ● Portfolio Construction – Waystone Advisors will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – Waystone Advisors will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Waystone Advisors does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Waystone Advisors. E. Assets Under Management As of December 31, 2025, Waystone manages $ 179,345,970 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are typically paid quarterly in advance of each calendar quarter. For alternative investments (limited partnerships) investment advisory fees are instead paid monthly or quarterly (“billing period”) at the end of each billing period, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees are based on the following schedule: Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 6  Assets Under Management ($) Annual Rate (%) Up to $1,000,000 0.99% $1,000,001 to $4,000,000 0.85% $4,000,001 above 0.50% The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Waystone Advisors will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Use of Independent Managers As noted in Item 4, the Advisor will implement all or a portion of a client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. Use of TAMPs– As noted in Item 4, the Advisor may periodically recommend and refer Clients to a TAMP. For Client accounts that are managed by a TAMP, the Client’s fee will be deducted from the Client’s account[s] by the TAMP, or Advisor consistent with the fee schedule above. The Advisor does not earn any compensation from TAMPs and will only earn its investment advisory fee as described above. Financial Planning Services Waystone Advisors offers financial planning services either on an hourly basis or a fixed engagement fee. Hourly fees range up to $300 per hour. Fixed fee engagements are based on the expected number of hours to complete the engagement at the Advisor’s hourly rate. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Waystone Advisors at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Waystone Advisors to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 7  Use of Independent Managers For Client accounts implemented through an Independent Manager, the Client’s overall fees may include Waystones investment advisory fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. Financial Planning Services Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Waystone Advisors, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The fees charged by Waystone Advisors are separate and distinct from these custody and execution fees. In addition, all fees paid to Waystone Advisors for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Waystone Advisors, but would not receive the services provided by Waystone Advisors which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Waystone Advisors to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services Waystone Advisors may be compensated for its investment management services in advance of the quarter in which services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the fiveday period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers and TAMP In the event that a client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the Client and that Independent Manager. Waystone will assist the Client with the termination and transition as appropriate. Use of TAMPs – In the event that the Advisor has determined that a TAMP is no longer in the Client’s best interest, the terms for the termination will be set forth in the respective agreements between the TAMP and the Client or the Advisor and the SubAdvisor/TAMP. Financial Planning Services Waystone Advisors may be partially-compensated for its financial planning services upon the execution of a planning agreement. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 8  rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will promptly refund any unearned, prepaid planning fees. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Waystone Advisors does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person may earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by Advisory Persons are separate and in addition to the Advisor’s fees. This practice presents a conflict of interest because as the Advisory Person may have an incentive to recommend insurance products to a client for the purpose of generating commissions rather than solely based on the Client’s needs. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Please see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management Waystone Advisors does not charge performance-based fees for its investment advisory services. The fees charged by Waystone Advisors are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Waystone Advisors does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its clients. Item 7 – Types of Clients Waystone Advisors offers investment advisory services to individuals, high net worth individuals, trusts, estates, and businesses. Waystone Advisors generally does not impose a minimum relationship size. However, certain Independent Managers may impose minimums. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Waystone Advisors primarily employs fundamental analysis in developing investment strategies for its clients. Research and analysis from Waystone Advisors are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criterion consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. As noted above, Waystone Advisors generally employs a long-term investment strategy for its clients, as consistent with their financial goals. Waystone Advisors will typically hold all or a portion of a security for more than a year but may hold for Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 9  shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Waystone Advisors may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Waystone Advisors will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a client’s account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a client’s account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bidask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 10  set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Waystone Advisors or its management persons. Waystone Advisors values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 328565. Item 10 – Other Financial Industry Activities and Affiliations Except as noted below, Waystone Advisors does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its client’s accounts. Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person’s role with Main Advisory. As an insurance professional, the Advisory Person may receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by an Advisory Person. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a client’s investment portfolio with one or more Independent Managers. The Advisor does not receive any compensation, nor does this present a material conflict of interest. The Advisor will only earn its wealth management fee as described in Item 5.A. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Waystone Advisors has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Waystone Advisors (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Waystone Advisors and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Waystone Advisors’ Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (425) 484-0045 or via email at info@waystoneadvisors.com. Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 11  B. Personal Trading with Material Interest Waystone Advisors allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Waystone Advisors does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. Waystone Advisors does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Waystone Advisors allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material nonpublic information. This risk is mitigated by Waystone Advisors requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Waystone Advisors allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Waystone Advisors, or any Supervised Person of Waystone Advisors, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Waystone Advisors does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Waystone Advisors to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Waystone Advisors does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Waystone Advisors does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Waystone Advisors. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Waystone Advisors may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Waystone Advisors will generally recommend that Clients establish their account[s] at Assetmark Trust Company, (“Assetmark”), Fidelity Clearing & Custody Solutions and other divisions of Fidelity Investments, Inc. (“Fidelity”). Assetmark and Fidelity will serve as the Client’s “qualified custodian”. Following are additional details regarding the brokerage practices of the Advisor: Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into 1. an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Waystone Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 12  Advisors does not participate in soft dollar programs sponsored or offered by any broker dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. Brokerage Referrals - Waystone Advisors does not receive any compensation from any third party in connection with 2. the recommendation for establishing an account. 3. Directed Brokerage – Waystone Advisors has established a relationship with Assetmark and Fidelity to provide brokerage and custodial services for client accounts. We require clients to use this broker-dealer for all transactions and do not permit clients to select their own broker-dealer. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Waystone Advisors will execute its transactions through the Custodian as authorized by the Client. Waystone Advisors may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of Waystone Advisors and periodically by the CCO. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Waystone Advisors if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Waystone Advisors Waystone Advisors is a fee-based advisory firm, that is compensated solely by its clients and not from any investment product. Waystone Advisors does not receive commissions or other compensation from product sponsors, broker-dealers or any unrelated third party. Waystone Advisors may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 13  accountants, estate planners) to provide certain financial services necessary to meet the goals of its clients. Likewise, Waystone Advisors may receive non-compensated referrals of new Clients from various third-parties. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody Waystone Advisors does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Waystone Advisors exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Waystone Advisors to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Waystone Advisors to ensure accuracy, as the Custodian does not perform this review. Money Movement Authorization - For instances where Clients authorize Waystone Advisors to move funds between their accounts, Waystone Advisors and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Item 16 – Investment Discretion Waystone Advisors generally has discretion over the selection and number of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Waystone Advisors. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Waystone Advisors will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Waystone Advisors does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Waystone Advisors, nor its management, have any adverse financial situations that would reasonably impair the ability of Waystone Advisors to meet all obligations to its clients. Neither Waystone Advisors, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Waystone Advisors is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 14  Waystone Advisors LLC 9210 218th Ave NE, Redmond WA 98053 Phone : (425) 484-0045 | Website: https://waystoneadvisors.com Page 15