WEALTH ADVISORS NETWORK, INC.

Item 1 – Cover Page Wealth Advisors Network, Inc. CRD #113836 201 Foundation Place Ste. 100 Hastings, NE 68901 402-463-6769 August 1, 2025 www.wealthadvisorsnetwork.net www.laurelvalleyadvisors.com This Brochure provides information about the qualifications and business practices of Wealth Advisors Network, Inc. (WAN) as required by Part 2A of Form ADV. Form ADV is the form we file to register and be licensed to do business as investment advisers and comply with federal and/or state securities laws. The information presented is responsive according to the sequential “Items” of the form. Please contact our Chief Compliance Officer, Jeni Charron at (402) 463-6769, if you have questions about the contents of this Brochure. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Wealth Advisors Network, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. We are a Registered Investment Adviser. Our registration as an Investment Adviser does not imply any level of skill or training. The oral and written communications we provide to you, including this Brochure, is information you i  use to evaluate us (and other advisers) which are factors in your decision to hire us or to continue to maintain a mutually beneficial relationship. Our last Annual Update of our Brochure was dated November 21, 2024 Since then, we have made the following material changes: Item 2 – Material Changes – We no longer have a Buffalo, NY location. ii  Item 3 -Table of Contents Item 1 – Cover Page ...................................................................................................... i Item 2 – Material Changes ........................................................................................... ii Item 3 - Table of Contents ........................................................................................... iii Item 4 – Advisory Business .......................................................................................... 1 Item 5 – Fees and Compensation ................................................................................. 6 Item 6 – Performance-Based Fees and Side-By-Side Management .............................. 11 Item 7 – Types of Clients ............................................................................................ 11 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................... 11 Item 9 – Disciplinary Information ............................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations ..................................... 13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................................................................................................... 13 Item 12 – Brokerage Practices .................................................................................... 14 Item 13 – Review of Accounts ..................................................................................... 15 Item 14 – Client Referrals and Other Compensation .................................................. 16 Item 15 – Custody ...................................................................................................... 17 Item 16 – Investment Discretion ................................................................................ 17 Item 17 – Voting Client Securities (i.e., Proxy Voting) ................................................. 17 Item 18 – Financial Information ................................................................................. 17 iii  Item 4 – Advisory Business Wealth Advisors Network, Inc. (WAN) was established in 1997 to provide comprehensive wealth care services. Another d/b/a, Laurel Valley Advisors in 2020. The majority owner of WAN is Jeff S. Anderson. Many of our adviser representatives (IARs”) are registered representatives of Cambridge Investment Research, Inc. (CIR), a registered broker/dealer and member of FINRA/SIPC, are licensed to sell insurance and are also certified public accountants (CPAs) with Contryman Associates, P.C. (CAPC), or other CPA firms. WAN is headquartered in Hastings, Nebraska and has offices throughout Nebraska, in Greeley, CO, and Johnstown, PA (d/b/a Laurel Valley Advisors [LVA]). Wealth Advisors Network may also use their d/b/a Contryman Wealth Advisors. Drawing on other institutional resources, such as Cambridge Investment Research, we develop and implement customized investment strategies for individuals, high net worth individuals, charitable organizations, trusts and closely held businesses. Our independence allows us the ability to utilize a variety of investment approaches including money market funds, unit investment trusts (UIT) , institutional funds, certificates of deposit, stocks, corporate debt, commercial paper, U.S. government securities, municipal securities, mutual funds, closed-end funds, exchange traded funds (ETFs), mortgage related and other asset backed securities, Real Estate Investment Trusts (REITS), Business Development Corporations (BDCs), Direct Participation Programs (DPPs) and separate account managers. Our main service and goal is to provide sound, quality investment services. The rest of our business is comprised of furnishing advice to clients on financial matters that may not involve securities, including income planning and asset preservation, insurance, general business planning, retirement planning, succession planning, and estate planning. Our IARs are either employees of WAN or are independent contractors of WAN. The services offered by the adviser representatives may overlap with their respective accounting firm services. We offer a variety of financial planning and investment advisory services to our clients. Depending on the program or options our clients have selected, the investment services may be provided on a discretionary basis or non-discretionary basis. Through CIR, we make available to client’s investment programs that use managers whose investment style and expertise may be appropriate for the specific needs of certain clients. Fidelity Clearing & Custody Solutions (FCCS) maintains custody of most funds and securities, and we will never have direct access to client funds and securities. We work hard to fully explain the options available to our clients and advise them to carefully examine the various investment programs and underlying options available, particularly the fee structure. We are aware that services provided under some, or all of the options may be available from other providers for lesser or higher fees. We are a community-based firm positioned to provide high quality local service and value, with immediate availability and accessibility. You will have the assurance that qualified professionals are considering your entire financial picture and know 1  that your financial plan has been designed and customized to meet your specific needs. Our independent in-depth research and advice are provided by advisers with breadth of knowledge evidenced by years of experience and training. This allows us to provide you with the best of both worlds: local availability and value with the depth of a national firm. Your Financial Professional can provide investment advice to you regarding your retirement plan account or individual retirement account (“IRA”). In doing so, your Financial Professional must act as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Fiduciary responsibility requires that Financial Professionals put your interests ahead of their own. In acting in your best interest your Financial Professional will adhere to consumer protection standards that require compensation not to be excessive based on the market value of the particular services, rights and benefits delivered to you. Recommendations made by your Financial Professional regarding rollover options, from a retirement plan to another plan or IRA, from an IRA to a plan, from an IRA to another IRA or from one account type to another (e.g., commission-based to fee- based), will require your Financial Professional to document the reasons for the recommendation and specify why the recommendation is in your best interest. The way that your Financial Professional and Cambridge make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put our financial interests ahead of yours when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees, and investments;  Follow policies and procedures designed to ensure that we give advice that is in your best interest;  Charge no more than is reasonable for services; and  Give you basic information about conflicts of interest. You should discuss with your Financial Professional the costs and benefits of each Investment management service and then select the one that you believe best supports your investment goals and style and provides the most cost-effective means of executing your investment strategy. WAN has actively managed recommended portfolios that we make available to our advisers for use although they are not required to use them. We have a recommended portfolio for accounts over $150,000 and one for accounts under 2  $150,000. In the under $150,000 portfolio, we attempt to use ETFs and Mutual Funds with no ticket charges to reduce the expense of smaller trades. CMAP Program In our CMAP Program, our IAR’s determine the appropriate mix of assets for the client based on the results of the Risk Profile Questionnaire or agreed upon portfolio parameters. Investments can include, but are not limited to, money market funds, UITs, institutional funds, certificates of deposit, stocks, corporate debt, commercial paper, U.S. government securities, municipal securities, mutual funds, ETFs, mortgage related, and other asset backed securities, REITS, BDCs and DPPs. WAN has developed recommended portfolios based on risk tolerance that it may use but is not required to use. For non-discretionary accounts, the IAR will monitor market conditions and the portfolio and will obtain client approval for repositioning the assets. For discretionary accounts, the IAR will monitor market conditions and the portfolio and will reposition the assets when needed. Our investment strategies utilize primarily mutual funds (both index and actively managed), as well as ETFs and, in some instances, individual stocks and bonds. As registered representatives, through CIR, our IARs can sell securities to any client for commissions. However, we do not engage in securities transactions where our IAR would receive a commission when we have already charged an advisory management fee. Any fees or other compensation received by the IARs in their separate capacities as registered representatives will be received to the extent permitted by applicable law. Fee Based Pension Platform For pension, profit sharing and 401(k) Plan clients that have individual accounts with participants exercising control over assets in their own account, we may, at the request of the Plan trustees, conduct educational investment meetings designed for Plan participants. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA. WealthPort Advisor-Directed Wrap Program WAN participates, under a co-advisory relationship with Cambridge Investment Research Advisors, Inc. (CIRA), in fee-based services sponsored through CIRA’s WealthPort Wrap Programs. CIR serves as the introducing broker‐dealer for accounts in the WealthPort Advisor-Directed Wrap Program and clears securities transactions on a fully disclosed basis through FCCS. The following information provides a brief summary of WealthPort Advisor-Directed Wrap Program. A full and complete description of this Program is provided in the WealthPort Wrap Brochure. All investors participating in WealthPort Advisor-Directed Wrap Program will be provided with and should review the WealthPort Wrap Brochure prior to investing. In the WealthPort Advisor-Directed Wrap Program, your IAR provides investment management services, defined as managed on a discretionary trading basis. Through the Program, your IAR is responsible for determining investment recommendations and implementing transactions. Your IAR actively manages your 3  account(s) in accordance with your individual needs, objectives, and risk tolerance. WAN serves as portfolio manager for those clients that have established a WealthPort Advisor-Directed Wrap account giving continuous investment advice to you and making investments based on your individual needs. CMAP Program versus WealthPort Advisor-Directed Wrap Program IARs provide asset management services through both a traditional management program and a wrap fee program. Under our traditional CMAP management program, we charge an investment advisory fee for advisory services. Clients will also incur annual custodial fees and ticket charges for each transaction by our introducing broker/dealer, when applicable. Under the WealthPort Advisor-Directed Wrap Program, advisory services, custodial fees and transaction services are provided for one fee to the client. From a management perspective, there is not a fundamental difference in the way our IARs manage wrap fee accounts versus traditional management accounts. The significant difference is the way in which transaction services are paid. Financial Planning and Consulting Our IARs may provide advisory services in the form of financial planning or consulting services. Financial planning and/or consulting services do not involve the active management of client accounts. Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is to find ways to help the client understand their overall financial situation and help the client set financial objectives. Consulting services include consulting clients in the management of their money, investment options and asset reallocation. Consulting services can be narrow in scope and not take into consideration all areas of a client’s financial situation. Referral of Third-Party Money Managers We sometimes offer advisory services by referring clients to a third-party money manager offering asset management and other investment advisory services. We perform a due diligence review on these third-party money managers that looks at management continuity, management tenure, disciplinary history, performance history, financial condition, conflicts, costs, and operations. The third-party money managers are responsible for continuously monitoring client accounts and making trades, or directing us to make trades, in client accounts when necessary. As a result of the referral, we are paid a portion of the fee charged and collected by the third-party money managers in the form of promoter fees. Each solicitation arrangement is performed pursuant to a written solicitation agreement and is in compliance with SEC Rule 206(4)-3 and applicable state securities rules and regulations. 4  Under this service, we assist you with identifying your risk tolerance and investment objectives. We recommend third-party money managers in relation to your stated investment objectives and risk tolerance, and you may select a recommended third- party money manager or model portfolio based upon your needs. You must enter into an agreement directly with the third-party money manager who provides your designated account with asset management services. We are available to answer questions that you may have regarding your account and act as the communication conduit between you and the third-party money manager. The third-party money manager may take discretionary authority to determine the securities to be purchased and sold for your account. We do not have any trading authority with respect to your designated account managed by the third-party money manager. Although we review the performance of numerous third-party money managers, we enter into only a select number of relationships with third-party money managers that have agreed to pay us a portion of the overall fee charged to our clients. Therefore, we have a conflict of interest in that we will only recommend third-party money managers that will agree to compensate us for referrals of our clients. Clients are advised that there may be other third-party money managers not recommended by our firm that are suitable for the client and that may be more or less costly than arrangements recommended by our firm. No guarantees can be made that a client’s financial goals or objectives will be achieved by a third-party money manager recommended by our firm. Further, no guarantees of performance can ever be offered by our firm. Because of these compensation arrangements, a conflict of interest exists in connection with the IARs recommending particular investments for a client's account. Clients have sole discretion whether to implement any or all of the IAR’s recommendations (except where discretion has been given by the client to the IAR). Use of Sub-Advisors For some Clients we may engage other investment advisors (“Sub-Advisors”) to assist us in managing their account under an Investment Sub-Advisory Agreement with such Sub-Advisors. This sometimes occurs when the Client decides to transfer the management of their portfolios to us from another investment advisor and as part of the transition to us, we and the Client decide it is in our and the Client’s best interest to permit the former investment advisor to continue to manage the accounts as a Sub-Advisor. In other cases, due to the nature and complexity of a client’s portfolio, we and the Client may decide to engage a Sub-Advisor to manage the portion of the Client’s portfolio that presents complexities that we do not have experience dealing with. In establishing Investment Sub-Advisory Agreements with such Sub-Advisers, we perform a due diligence review that looks at management continuity, management 5  tenure, experience, disciplinary history, performance history, financial condition, conflicts, costs, and operations. If engaged, the Sub-Advisor will continuously monitor the Client assets in the accounts assigned to them. As a result, when a Sub- Advisor is engaged, we and the broker/dealer (such as CIR) holding the assets will ask Clients to execute a Privacy Waiver and Consent to Disclose Account Information to expressly permit the broker dealer and us to provide the Sub-Advisor real time access to the Client’s account information and holdings. Such Sub-Advisors have no discretionary authority to select broker/dealers or directly place trades for the Client but will advise us to make trades in Client accounts when necessary. We reserve the right to follow or reject any trade direction from the Sub-Advisor. The Investment Sub-Advisory Agreement is between us and the Sub- Advisor and as part of our expense in managing the account we pay the Sub-Advisor directly for managing the Client assets from the fees we receive from the Client. Unless the Client otherwise agrees, the Client will pay no additional compensation for our use of Sub-Advisors. Client Assets Managed As of September 30, 2024, we manage client assets on a discretionary basis in an amount equal to approximately $283,437,106and client assets on a non- discretionary basis in an amount equal to approximately $13,578,233. Business Continuity Plan WAN has established a Business Continuity Plan (BCP). The BCP describes how WAN will respond to significant business disruptions and provide investors with alternative contact information in the event of a significant business disruption. The BCP Summary can be found at www.wealthadvisosnetwork.net. Item 5 – Fees and Compensation CMAP Fees for Investment Advisory services payable to us are based on the amount of assets under management (AUM), including cash balances deposited in a Federal Deposit Insured Corporation (“FDIC”) insured multi bank program and/or Money Market positions. The annual fee for this program ranges from .55% (55 basis points) up to 1.5% (150 basis points). These fees can be paid through a variety of options determined by you and your Adviser. The exact fee arrangement should be expressed in Appendix A of the Financial Planning and Investment Management Services Agreement. The fee arrangements include: Flat percentage: Less than $249,999 $250,000 - $499,999 $500,000 - $999,999 $1,000,000 - $1,999,999 1.50% 1.45% 1.35% 1.10% 6  $2,000,000 - $2,999,999 $3,000,000 - $3,999,999 $4,000,000 - $4,999,999 $5,000,000 - $5,999,999 $6,000,000 - $6,999,999 $7,000,000 - $7,999,999 $8,000,000 - $9,999,999 Over $10,000,000 1.00% .90% .80% .75% .70% .65% .60% .55% The formula used for calculating the fee is market value multiplied by Client fee percentage as defined in Exhibit A of WAN’s Financial Planning and Investment Management Services Agreement, multiplied by the number of days in the billing cycle divided by the number of days in the year. Flat Hourly Fee – This is a set hourly fee for services provided. Fees typically range from $100-$500 depending on the complexity and nature of the engagement, as well as the level of expertise required by adviser of the respective engagement. Flat Fee – This is a set fee charged for services provided. Fees are charged in advance or in arrears depending upon the agreement between us and your IAR. The frequency of the calculation and payment of fees is determined when you establish or update your account agreement and is documented in Appendix A of the Financial Planning and Investment Management Services Agreement. We reserve the right to calculate fees either based on the market value of the account(s) on the last day of the previous month or quarter if fees are billed in advance or on the last day of the month or quarter in which services were rendered if fees are billed in arrears. You should discuss with your IAR the fee calculation formula in effect at the time you establish your account. Additional deposits of funds are subject to a fee when deposited. The fee for additional deposits is pro-rated for the remainder of the reporting period. The fee is determined on an account-by-account basis. You should discuss with your IAR if or when this fee will apply to your account(s). Fees are typically deducted directly from your CMAP account. You can also decide to have the fee deducted from an alternate CMAP account held at the same custodian. Generally, fees from a non-qualified account must be debited from a non-qualified account on a platform approved for fee debiting. You must provide the custodian with written authorization to have fees deducted from the account and paid to us. The custodian will send you statements, at least quarterly, showing all disbursements for the account including the amount of the advisory fee, if deducted directly from the account. It is our and your responsibility to verify the accuracy of fee calculations. The qualified custodian will not determine whether the fee has been properly calculated. 7  Varying mutual fund share classes are used in your account. We and your IAR will make every attempt to use the most cost-effective share class available. This may not always be the least expensive share class but because of other factors we may feel it is the most suitable. You should discuss the factors of direct and indirect expenses borne as a result of the mutual fund fees. As WAN has chosen CIR/FCCS as their broker-dealer and clearing firm, we are limited to CIR’s preferred share class of choice which may not be the cheapest share class. Your IAR determines whether or not the transaction ticket fees charged by the broker-dealer and/or custodian are charged to you. If we choose to absorb the ticket charge, a conflict of interest is created due to the increased expense that we may incur. CIR is a participant in NFS’ Institutional FundsNetwork® (IFN) ticket charge program. This program offers select mutual funds to be purchased by you with no transaction fees (“NTF Shares”). NFS receives revenue directly from the mutual fund companies that support the IFN program. Through formal agreements, the broker- dealer receives revenue for assets that are held within the IFN program. The NTF Shares can be more expensive for you over time because of the higher ongoing internal operating expenses, such as 12b-1 fees. You pay a higher transaction charge for transaction fee funds; however, the transaction fee funds can be less expensive to you over time because of lower ongoing operation expenses. You and your IAR should discuss and understand these additional indirect expenses borne as a result of the mutual fund fees. Restrictions apply in certain situations. Even though these payments are not shared with your IAR, the receipt of these additional payments creates a conflict of interest because of the increased compensation to the broker-dealer. A platform fee is charged to us by CIR broker-dealer for services provided in association with the CMAP and WealthPort platforms. The platform fee is generally not more than 5.5 basis points for CMAP and not more than 20bps for WealthPort. The platform fee charged could create a conflict of interest. We could charge a higher advisory fee in order to offset the platform fee or choose to utilize another custodian or program that would have lower, or no platform fees charged to the adviser. On a client-by-client basis, we offer the consolidation of accounts maintained within a household for purposes of calculating fees. When appropriate, certain assets, e.g., alternatively held investments, B and C shares, will be excluded from the calculation. WealthPort Wrap Cambridge Investment Research Advisors, Inc. (CIRA), an affiliate of CIR, sponsors a wrap fee program known as WealthPort Advisor-Directed Wrap. WAN and CIRA are co-advisors in this program. WealthPort Advisor-Directed Wrap may be recommended to clients. A full and complete description of the WealthPort Advisor- Directed Wrap Program is provided in the WealthPort Wrap Brochure. All investors 8  participating in the WealthPort Wrap Program will be provided with and should review the WealthPort Wrap Brochure prior to investing. Negotiation of Fees The fee schedules set forth above are guidelines and all fees are negotiable. The actual fee for each client is based on factors such as the client’s financial situation and circumstances, the amount of assets under management and the time required to manage the account. The exact fee for our services will be discussed and agreed upon and be included in a written agreement for services prior to services being provided. Third-Party Money Managers Third-party money managers generally have account minimum requirements that will vary among third-party money managers. Account minimums are generally higher on fixed income accounts than for equity-based accounts. A complete description of the third-party money manager’s services, fee schedules and account minimums will be disclosed in the third-party money manager’s disclosure brochure which will be provided to you prior to or at the time an agreement for services is executed and the account is established. The actual fee charged to you will vary depending on the third-party money manager. All fees are calculated and collected by the third-party money manager who will be responsible for delivering our portion of the fee paid by you to us. Under this program, you may incur additional charges including but not limited to, mutual fund sales loads, 12b-1 fees and surrender charges and IRA and qualified retirement plan fees. We have a conflict of interest by only offering those third-party money managers that have agreed to pay a portion of their advisory fee to us. Product Sponsor Reimbursement From time to time, we enter into specific arrangements with product sponsors in which the product sponsor will reimburse us for meeting expenses when we provide training meetings. For our IARs, while we and our IARs endeavor at all times to put the interests of their clients first as part of our fiduciary duty to clients, you should be aware that the receipt of meeting expense reimbursement creates a conflict of interest that might influence an IARs choice of investments. Additional Fees and Expenses Investment advisory fees charged by us are separate and distinct from the fees and expenses charged by investment company securities that are recommended to you. A description of these fees and expenses are available in each investment company’s security prospectus. While not an exhaustive list, an example of these fees and expenses are mutual fund sales loads, surrender charges, variable annuity fees and surrender charges and IRA and qualified retirement plan fees. In addition, certain mutual fund companies, as outlined it the fund’s prospectus, pay 12b-1 fees and sub-TA fees. These fees come from fund assets, therefore, indirectly from client 9  assets. With your managed account, 12b-1 (marketing and distribution) fees and trail fees earned will be credited back to your account at the clearing firm whenever possible. When 12b-1 fees and trails are not credited to your account, the investment advisory fee will be lowered, or offset by that amount. The following transaction costs may apply:  Transaction fees; o Equity, ETF and closed end funds – no more than $18.00 per trade o Mutual Funds – No more than $12.00 per trade (may be waived by fund company) A $10 surcharge applies to certain funds.  Fixed Income – no more than $39.50 per transaction  Exchange fees;  Custodial fees; fees are disclosed in disclosure documents on custodian application;  SEC fees;  Advisory fees and administrative fees charged by Mutual Funds (MF), and Exchange Traded Funds (ETFs)  Advisory fees charged by sub-advisers (if any are used for your account);  Custodial Fees;  Odd-Lot differentials;  Transfer taxes;  Wire transfer and electronic fund processing fees; Billing: If a client has more than one portfolio with each program under our services, we may elect at our sole discretion to aggregate the client’s portfolios for the purposes of computing management fees. If the account does not contain sufficient funds to pay Advisory Fees, we have limited authority to sell or redeem securities in sufficient amounts to pay the Advisory Fees. Although fees are collected directly from the account, the client will receive an invoice. Clients have the right to cancel their agreement with us at any time by notifying us in writing. We also may cancel this agreement at any time with thirty days prior written notice to you. If services are terminated within five business days of executing the agreement, services will be terminated without penalty and all pre- paid fees will be refunded to the client. If services are terminated after the initial five-day period, unearned fees will be prorated and refunded to the client except if terminated in the last 15 days of a calendar quarter. Refund of Fees for Withdrawals 10  We will refund you, on a discretionary basis and as facts and circumstances warrant, when a material withdrawal in the client’s account occurs within the first 45 days of the quarter. A material withdrawal is defined as the higher of 25% of a client’s assets or $25,000. The refund will be prorated based on the remaining days in the quarter. Item 6 – Performance-Based Fees and Side-By-Side Management We do not charge performance based advisory fees on a share of the capital appreciation in the client’s account. Item 7 – Types of Clients We provide our services to a number of Clients: Individuals, including high net worth individuals and business owners   Trusts, estates and charitable organizations  Corporations or other business entities  Pension and profit-sharing plans  Certain schools, government entities, and nonprofit organizations Minimum Account Size WAN has a $25,000 minimum balance requirement for new accounts in order to manage a portfolio for the WAN CMAP Program. WAN may choose to waive these minimums at its sole discretion as circumstances dictate. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Analysis Security analysis techniques used will vary depending on the needs of the client and the advice requested in a given situation and any or one of the following techniques may be used: charting, fundamental analysis, risk vs. return analysis, sentiment analysis, technical analysis, and cyclical trends and business cycles. Then, using modeling and research software, we filter for available ETFs, load and no-load funds or individual stocks and bonds that meet our predetermined parameters (that may change over time based on portfolio goals) such as the Sharpe ratio, expenses, returns, past performance, size, rank among peers, price-to-earnings ratios (P/E's), asset class, industry, sector, financial strength, etc. We also will look at past style drift and manager tenure to help estimate consistency in future performance when mutual funds or money market managers are utilized. Various tools will be used for research including prospectuses, charting software, market news, fund websites, and information concerning geopolitical events, government fiscal and monetary conditions, economic conditions, applicable world news, and various analyst provide information that may become available that are useful and legal. 11  Investment Strategies WAN’s investment philosophy is based on the principles of diversification, relative value versus risk, and active portfolio management. Diversification is a portfolio strategy designed to reduce exposure to risk by combining a variety of investments, such as money market funds, UITs, institutional funds, certificates of deposit, stocks, corporate debt, commercial paper, U.S. government securities, municipal securities, mutual funds, ETFs, mortgage related and other asset backed securities, REITS, BDCs and DPPs. In addition, Modern Portfolio Theory teaches that a long-term investment strategy should not necessarily avoid “risky” investments. Modern Portfolio Theory also states that no investments are “always” imprudent. Rather, research demonstrates that investment returns correlate strongly with risk and that it is only by accepting “risk” into the portfolio and satisfactorily diversifying the portfolio of investments that the owner can truly grow, preserve, and protect against taxes and inflation in his or her portfolio. Because risk and return are linked, we believe our main task is not to avoid risk but to manage it prudently based on current market conditions: in other words, to define risk and return objectives reasonably suited to the client account and to evaluate and make decisions respecting asset classes and individual securities in the context of the portfolio in whole. Risk of Loss All investments in securities include a risk of loss of your principal (invested amount) and any profits that have not been realized (securities not yet sold that reflect gains). As you know, stock and bond markets fluctuate substantially over time. In addition, as past global and domestic economic events have indicated, performance of any investment is not guaranteed. You should understand and be prepared to face losses and be able to bear them. If you cannot, then our services are probably not appropriate for you. While we believe that our strategies will provide opportunities for growth in account value and provide some protection from loss, we cannot assure that our approaches will work. As a result, there is a risk of loss of the value of the assets we manage that may be out of our control. We will do our very best with the management of your assets; however, we cannot guarantee any level of performance or that you will not experience losses. Item 9 – Disciplinary Information Neither WAN, nor any IAR or any management person associated with us have been found liable in an arbitration claim alleging damages in excess of $2500 involving any investment related activity or found liable of criminal action or civil action in a domestic, foreign, or military court of competent jurisdiction, administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority, or a self-regulatory organization proceeding. 12  Item 10 – Other Financial Industry Activities and Affiliations WAN is also a licensed insurance agency. Some of our IAR’s that are licensed to sell insurance, spend a portion of their time on analysis of existing policies for clients, and when needed, researching, and recommending insurance products to clients. Most of our IARs are also registered representatives of CIR, a registered broker- dealer, Member FINRA/SIPC. Clients are under no obligation to purchase or sell securities through our IARs that are registered representatives of CIR. Commissions may be higher or lower at CIR than at other broker-dealers. Advisory representatives have a conflict of interest in having clients purchase securities and or insurance related products through CIR in that the higher their production with CIR, the greater the opportunity to obtain a higher payout on commissions earned. Further, advisory representatives are restricted to only offering those products and services that have been reviewed and approved for offering to the public through CIR for execution. The commissions will be outlined in the product’s prospectus or offering document or described in detail before the product is sold. Under no circumstances will clients be charged both a commission and fees when securities are purchased. Advisory representatives may be certified public accountants with accounting firms and may also offer various accounting services for a fee. Clients are advised that fees for accounting services may be in addition to fees paid for advisory services. The clients to whom WAN provides advisory services frequently are the same as to whom accounting firms the IARs are associated with, provide accounting services. Third-Party Money Managers We have developed several programs, previously described in Item 5 of this disclosure brochure, designed to allow us to recommend and select third-party money managers for you. Once you select the third-party money manager to manage all or a portion of your assets, the third-party money manager will pay us a portion of the fees you are charged. Please refer to Items 4 and 5 for full details regarding the programs, fees, conflicts of interest and material arrangements when WAN selects other third-party money managers. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading We have imposed restrictions upon our advisers, or any person associated with us in connection with the purchase or sale, directly or indirectly, for their own account or accounts controlled by them, of securities recommended to or purchased for clients. We maintain strict guidelines and a Code of Ethics for all our employees designed to assure that we, or people associated with us, may not benefit, directly, or indirectly, from transactions made for the accounts of clients and that no other conflict of interest exists. Please refer to the WAN Code of Ethics for trading practices. 13  IARs are prohibited from investing in Initial Public Offerings (IPO's) unless pre- approved and disclosed. IAR's, our officers, and our employees are not allowed to trade ahead of clients when purchasing like securities (as defined in Section 2(a) (36) of the Investment Company Act of 1940). A copy of our “Code of Ethics” is available upon request. For Discretionary accounts, no Advisory Person shall purchase or sell, for his or her own account, any Security considered to be purchased or sold for client accounts until after all client purchases or sales in the same security have been completed. In the case of a block trade, the Advisory Person(s) may be included. This prohibition applies to all clients for which the Advisory Person knows or should have known, at the time of Advisory Persons purchase, that the purchase or sale should apply to the specific client account. For non-discretionary accounts, Advisers will make available, investment selections that we use in discretionary accounts, at their discretion as applicable to each client. Prohibition on Use of Insider Information We have also adopted policies and procedures to prevent the misuse of “insider” information (material, non-public information). A copy of WAN’s Code of Ethics is available to our clients and prospective clients upon request. Item 12 – Brokerage Practices General Considerations – selecting / recommending brokers for Client transactions and commission charges We generally request our clients to direct us to use CIR and its clearing firm, FCCS, as the broker-dealer and custodian for advisory accounts. Clients may choose another broker/dealer or Investment Advisor and not all advisors require their clients to direct brokerage. CIR or FCCS transmits customer orders for execution to various exchanges or market centers based on a number of factors. These include size of order, trading characteristics of the security, favorable execution prices (including the opportunity for price improvement), access to reliable market data, availability of efficient automated transaction processing and reduced execution costs through price concessions from the market centers, therefore receiving favorable execution. Certain market centers may execute orders at prices superior to the publicly quoted market price in accordance with their rules or practices. We receive a best execution analysis quarterly to review execution within spread, price improvement, and execution speed. Research and Other Soft Dollar Benefits We do not use soft dollars arrangements. 14  Trade Aggregation Transactions implemented for client accounts are generally affected independently, unless an IAR (in his or her sole discretion) decides to purchase or sell the same securities for several clients at the same time. This process is referred to as aggregating orders, batch trading or block trading and is used by an IAR when they believe such action may prove advantageous to clients. When IARs aggregate client orders, the allocation of securities among client accounts will be done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among the IAR’s clients in proportion to the purchase and sale orders placed for each client account on any given day. When an IAR determines to aggregate client orders for the purchase or sale of securities, including securities in which one or more of our associated persons may invest, the IAR will do so in accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. It should be noted; we do not allow IARs to receive any additional compensation or remuneration as a result of aggregation. Because we do not require our IARs aggregate trades, not all trades are aggregated even when there is an opportunity to do so. When trades are not aggregated, clients may not enjoy the effects of lower commission per share costs that often occur as a result of aggregating trades. As a result, clients may pay a higher transaction cost than could be received elsewhere. Item 13 – Review of Accounts Account Reviews and Reviewers Managed accounts are reviewed at least annually. Account reviews will verify investment strategy and objectives are consistent with positions held in your portfolio. Reviews are conducted by the Chief Compliance Officer of WAN and your advisor, with reviews performed in accordance with your investment goals and objectives. While account reviews are conducted at least annually, we modify portfolio positions throughout the year and make changes when we feel they are appropriate. Accounts established and maintained with other third-party money managers are reviewed at least annually, usually when statements and/or reports are received from the third-party money manager. These reviews are conducted by the IAR of record and the CCO. When financial planning services are provided, we will generally not monitor or review the plans unless agreed upon between the IAR and client to do so. 15  Statements and Reports For our asset management services, you are provided with transaction confirmation notices and regular monthly or quarterly account statements directly from the qualified custodian and written quarterly performance reports from us that include performance for fee-based accounts. Whether reports by a third-party money manager are provided to you will depend upon the policies of the third-party money manager. Financial planning clients do not receive any report other than the written plan originally contracted for and provided by WAN. You are encouraged to compare any reports or statements provided by us, a sub- adviser or third-party money manager against the account statements delivered from the qualified custodian. When you have questions about your account statement, you should contact us and the qualified custodian preparing the statement. Item 14 – Client Referrals and Other Compensation Our IARs and other associated persons may also be separately employed as employees, officers, CPAs or may be owners of the accounting firms they are associated with. Clients may be referred by WAN to those accounting firms; however, WAN clients are under no obligation to use the services of the accounting firm. Employees of the CPA firms that are not WAN IARs may refer accounting clients to WAN for investment advisory services and receive referral fees from WAN in the event that the referral chooses to engage WAN and IARs that may or may not be associated with the accounting firm. We and/or our IARs may also receive client referrals from other parties (usually attorneys, CPAs, or other professionals) for which they receive referral fees. The foregoing relationships and affiliations may result in conflicts of interest that may affect the independent judgment of us or our IARs. Material conflicts of interest will be disclosed to clients in writing and all efforts will be made to put the interest of the client first. Referral fees are set from time to time by WAN and are typically calculated as a percentage of the advisory fees paid to WAN or a set time frame, which could be indefinite. Referral fees are not paid in addition to the investment advisory fee paid by the client. Referral fees are paid by WAN and are an expense paid by WAN from its overall revenue and profits. Proper licensing, if required by the states in which the person receiving the referral fee, will be maintained by the promoter and full disclosure will be made to the client in writing. We have received payments from CIR in connection with the transition of an Investment Adviser Representative of another broker-dealer/Registered Investment 16  Adviser. These payments are intended to assist with the costs associated with the transition such as staff and termination fees. This presents a potential conflict of interest in that an IAR has a financial incentive to recommend that a client engage with the IAR and/or CIR for financial services in order for the grant to be received. However, an IAR may only recommend a broker-dealer/Registered Investment Adviser or service that he or she believes is suitable for you. WAN has systems in place to review suitability for the accounts we manage. Item 15 – Custody We do not have custody of our client’s assets. Item 16 – Investment Discretion Clients may grant us sole and absolute discretion in the management of their portfolio in the CMAP and WealthPort Wrap Platforms by granting us the authority in the Financial Planning and Investment Management Services Agreement. The client may put limitations on their discretionary authority with us (e.g., “Do not sell a particular security.” or “Don’t invest in companies that invest in third world countries”, etc.). We believe that accounts can be managed more efficiently and effectively by being discretionary therefore most of our clients have chosen this option. Item 17 – Voting Client Securities (i.e., Proxy Voting) Neither we nor our IARs will vote or give advice about how to vote proxies for securities held in client accounts. Clients will receive their proxies or other solicitations directly from their custodian or a transfer agent. If you have questions regarding proxies, you may contact us at (402) 463-6769. Item 18 – Financial Information This item is not applicable to our Disclosure Brochure. WAN does not allow, require, or solicit prepayment of more than $1200 in fees per client, six months or more in advance. Therefore, WAN is not required to include a balance sheet for its more recent fiscal year. WAN is not subject to a financial condition that is reasonable likely to impair our ability to meet contractual commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time. 17