Overview

Assets Under Management: $115 million
Headquarters: CARLSBAD, CA
High-Net-Worth Clients: 38
Average Client Assets: $1.6 million

Frequently Asked Questions

WEALTH COMPASS FINANCIAL, INC. charges 1.50% on the first $0 million, 1.25% on the next $1 million, 1.00% on the next $3 million, 0.75% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #290139), WEALTH COMPASS FINANCIAL, INC. is subject to fiduciary duty under federal law.

WEALTH COMPASS FINANCIAL, INC. is headquartered in CARLSBAD, CA.

WEALTH COMPASS FINANCIAL, INC. serves 38 high-net-worth clients according to their SEC filing dated April 27, 2026. View client details ↓

According to their SEC Form ADV, WEALTH COMPASS FINANCIAL, INC. offers portfolio management for individuals and selection of other advisors. View all service details ↓

WEALTH COMPASS FINANCIAL, INC. manages $115 million in client assets according to their SEC filing dated April 27, 2026.

According to their SEC Form ADV, WEALTH COMPASS FINANCIAL, INC. serves high-net-worth individuals. View client details ↓

Services Offered

Services: Portfolio Management for Individuals, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (2026 04 27 WEALTH COMPASS FINANCIAL FORM ADV PART 2A DISCLOSURE BROCHURE)

MinMaxMarginal Fee Rate
$0 $500,000 1.50%
$500,001 $1,000,000 1.25%
$1,000,001 $3,000,000 1.00%
$3,000,001 and above 0.75%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $13,750 1.38%
$5 million $48,750 0.98%
$10 million $86,250 0.86%
$50 million $386,250 0.77%
$100 million $761,250 0.76%

Clients

Number of High-Net-Worth Clients: 38
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 52.80%
Average Client Assets: $1.6 million
Total Client Accounts: 568
Discretionary Accounts: 567
Non-Discretionary Accounts: 1
Minimum Account Size: None

Regulatory Filings

CRD Number: 290139
Filing ID: 2099377
Last Filing Date: 2026-04-27 15:36:19

Form ADV Documents

Primary Brochure: 2026 04 27 WEALTH COMPASS FINANCIAL FORM ADV PART 2A DISCLOSURE BROCHURE (2026-04-27)

View Document Text
Wealth Compass Financial, Inc. CRD number: 290139 Form ADV Part 2A Disclosure Brochure Version Date: 4/27/2026 This brochure provides information about the qualifications and business practices of Wealth Compass Financial, Inc. If you have any questions about the contents of this brochure, please contact us at (760) 509-4000 or by email at: info@wealthcompass.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration does not imply a certain level of skill or training. Additional information about Wealth Compass Financial, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. 5860 Owens Ave. #100 Carlsbad, CA 92008 (760) 509-4000 info@wealthcompass.com i Item 2: Material Changes Wealth Compass Financial, Inc. (“WCF” or “Firm”) is an RIA registered with the U.S. Securities and Exchange Commission, located in Carlsbad, California. The Material Changes section of this Brochure is intended to point out any material changes that have been made to our business and to this Disclosure Brochure since our prior Brochure, and to provide you with a summary of those changes. This Brochure will be updated at least annually, or when material changes occur since the previous release of the Brochure. Material Changes since the last Brochure Update This Brochure is dated 4/27/2026. WCF is required to advise you of any material changes made to their business since their prior Brochure dated 3/19/2026. Since our prior Brochure we have moved our main business office. We formerly operated from 5860 Owens Ave. Suite 150, and have moved our firm to Suite 100 of the same building on 4/27/2026. Full Brochure Available In lieu of sending a notice of material changes, WCF chooses to send the entire Form ADV Part 2 Disclosure Brochure to its clients. This Firm Brochure being delivered is the updated and complete brochure for the Firm. Copies are available at no cost and are also available here: https://adviserinfo.sec.gov/firm/summary/290139. 1 Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes .................................................................................................................................. 1 Material Changes since the last Brochure Update .................................................................................... 1 Full Brochure Available ................................................................................................................................ 1 Item 3: Table of Contents .................................................................................................................................. 2 Item 4: Advisory Business ................................................................................................................................ 4 A. Description of the Advisory Firm........................................................................................................... 4 B. Types of Advisory Services ...................................................................................................................... 4 C. Client Tailored Services and Client Imposed Restrictions .................................................................. 5 D. Wrap Fee Programs .................................................................................................................................. 5 E. Assets Under Management ...................................................................................................................... 6 Item 5: Fees and Compensation ....................................................................................................................... 7 A. Fee Schedule .............................................................................................................................................. 7 B. Payment of Fees ......................................................................................................................................... 7 C. Client Responsibility for Third Party Fees ............................................................................................ 7 D. Prepayment of Fees .................................................................................................................................. 8 E. Outside Compensation for the Sale of Securities to Clients ................................................................ 8 Item 6: Performance-Based Fees and Side-By-Side Management ............................................................... 8 Item 7: Types of Clients ..................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .......................................................... 9 A. Methods of Analysis and Investment Strategies ............................................................................ 9 B. Material Risks Involved ..................................................................................................................... 9 C. Risks of Specific Securities Utilized .................................................................................................. 9 Item 9: Disciplinary Information ................................................................................................................... 11 A. Criminal or Civil Actions ................................................................................................................. 11 B. Administrative Proceedings ............................................................................................................ 11 Self-regulatory Organization (SRO) Proceedings ........................................................................ 11 C. Item 10: Other Financial Industry Activities and Affiliations ................................................................... 11 A. Registration as a Broker/Dealer or Broker/Dealer Representative .......................................... 11 2 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a B. Commodity Trading Advisor .................................................................................................................... 11 C. Registration Relationships Material to this Advisory Business and Conflicts of Interests .... 11 D. Selection of Other Advisers or Managers and How This Adviser is Compensated ............... 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 12 A. Code of Ethics .................................................................................................................................... 12 B. Recommendations Involving Material Financial Interests ......................................................... 12 C. Investing Personal Money in the Same Securities as Clients ...................................................... 12 D. Trading Securities At/Around the Same Time as Clients’ Securities ....................................... 13 Item 12: Brokerage Practices ........................................................................................................................... 13 A. Factors Used to Select Custodians and/or Broker/Dealers ....................................................... 13 1. Research and Other Soft-Dollar Benefits ................................................................................... 13 2. Brokerage for Client Referrals ..................................................................................................... 14 3. Clients Directing Which Broker/Dealer/Custodian to Use ................................................... 14 B. Aggregating (Block) Trading for Multiple Client Accounts ....................................................... 14 Item 13: Review of Accounts .......................................................................................................................... 14 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ........................ 14 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ..................................... 14 C. Content and Frequency of Regular Reports Provided to Clients ............................................... 15 Item 14: Client Referrals and Other Compensation .................................................................................... 15 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients B. Compensation to Non – Advisory Personnel for Client Referrals ............................................. 16 Item 15: Custody .............................................................................................................................................. 16 Item 16: Investment Discretion ...................................................................................................................... 17 Item 17: Voting Client Securities (Proxy Voting) ......................................................................................... 17 Item 18: Financial Information ....................................................................................................................... 17 Business Continuity Plan Client Notice .................................................................................................... 18 Client Privacy Policy Notice ....................................................................................................................... 19 Form ADV Part 2B – Individual Disclosure Brochure for Steven T. Nuckols.......................................... 22 Form ADV Part 2B – Individual Disclosure Brochure for Tod L. Lenhoff ............................................... 25 3 Item 4: Advisory Business A. Description of the Advisory Firm Wealth Compass Financial, Inc. (“WCF”) is a corporation organized in the State of Georgia, located in Carlsbad, CA. WCF is an investment adviser registered with the U.S. Securities and Exchange Commission, and notice filed in the state of California. The firm was formed in September 2017, and the principal owner is Steven Nuckols. WCF’s main office is located at 5860 Owens Avenue, Ste: 100, Carlsbad, CA 92008. WCF may also see clients and prospective clients at the offices of WCF’s affiliated Tax and Accounting firm located at 940 Canterbury Place, Suite 100, Escondido, CA 92025, BY APPOINTMENT ONLY. B. Types of Advisory Services Portfolio Management Services WCF offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. WCF creates an Investment Policy Statement (“IPS”) for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy Asset allocation Asset selection • • • Personal investment policy Selection of other advisers Regular portfolio monitoring WCF evaluates the current investments of each client with respect to their risk tolerance levels and investment time horizon. WCF will request discretionary authority from clients to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement (“IPS”) and given to each client. WCF seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of WCF’s economic, investment or other financial interests. To meet its fiduciary obligations, WCF attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, WCF’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is WCF’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. When appropriate and when WCF believes it is in the clients’ best interest, WCF may recommend other carefully chosen advisers (Third-Party Money Managers) to professionally allocate and manage your account. 4 Financial Planning WCF believes that financial planning is a necessary step in portfolio management and provides this service as a standard part of its portfolio management to its clients at no additional fee. Financial planning may include, but is not limited to investment planning, life insurance and long-term care, tax considerations and concerns, retirement planning, college planning (as applicable), and debt /credit review and planning. In our standard client engagement, WCF will furnish a written disclosure in its report or summary indicating: a. whether the investment adviser, or an affiliate or associated person of the investment adviser, will receive commissions from the sale of insurance or real estate or will receive fees or other compensation from the sale of securities or other products or services recommended in the financial planning process or otherwise have a conflict of interest. b. the client is under no obligation to act on the investment adviser's or associated person's recommendation(s). c. if the client elects to act on any of the recommendations, the client is under no obligation to affect the transaction through the investment adviser or the associated person when such person is employed as an agent with a licensed broker-dealer or is licensed as a broker- dealer or through any associate or affiliate of such person. Services Limited to Specific Types of Investments WCF generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities (through individually licensed insurance agents), equities, ETFs, and non-U.S. securities. WCF may use other securities as well to help diversify a portfolio when appropriate. C. Client Tailored Services and Client Imposed Restrictions WCF offers the same suite of services to all its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement (“IPS”) which outlines each client’s current suitability, investment objectives, and financial situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent WCF from properly servicing the client account, or if the restrictions would require WCF to deviate from its standard suite of services, WCF reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. WCF 5 is not a wrap fee program sponsor or wrap program portfolio manager but may recommend carefully selected wrap fee program models to clients when appropriate. E. Assets Under Management WCF has the following calculated regulatory assets under management (“RAUM”) as of our last fiscal year end of December 31, 2025: Discretionary Assets: Total AUM: Non-discretionary Assets: $ 115,254,613 $ 146,699 $ 115,401,312 6 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $1 - $500,000 1.50% $500,001 - $1,000,000 1.25% $1,000,001 - $3,000,000 1.00% $3,000,001 – And Up 0.75% Advisory fees are expressed as an annual percentage rate. Advisory fees are calculated in a straight tier schedule (shown above) using the average daily value of the assets in the account for the monthly billing period and divided by twelve (12) to determine the monthly charge. Fees are due monthly in arrears. Comparable services may be available at lower cost from other providers. These fees are generally negotiable, and the final fee schedule is attached as “Exhibit I – Fee Agreement” of the Investment Advisory Contract. Clients may terminate the Investment Advisory Contract at any time with five (5) days’ written notice and will only be billed for those days under our management. Because WCF bills fees in arrears, no additional fees will be charged to you after termination of services. Financial Planning General Financial Planning is provided to WCF clients paying for portfolio management as a complimentary process to establish client goals and needs at no additional cost. There is no need to engage WCF for separate financial planning services to receive those services, as explained in Item 4: Advisory Business. WCF does not charge clients additional fees for financial planning services. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization monthly in arrears. Billing occurs on the 8th of the month. Fees are automatically withdrawn approximately one week later. C. Client Responsibility for Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by WCF. Please see Item 12 of this brochure regarding broker-dealers and custodians. 7 D. Prepayment of Fees WCF collects fees in arrears and therefore, there are no prepayment of advisory fees and refunds do not apply to advisory account clients. E. Outside Compensation for the Sale of Securities to Clients WCF’s sole business is as a Registered Investment Adviser. WCF and its management people do not have any other financial industry activities or affiliations. However, WCF supervised persons also possess California insurance licenses and are therefore licensed to offer and sell insurance products to California residents that they believe may benefit from them in the overall financial planning process. In doing so, WCF’s supervised people can receive a commission directly from the insurance company when a policy is sold. Even though this would transpire outside of their investment advisory role with WCF, this presents a conflict of interest since the insurance agent – investment professional would have an incentive to recommend insurance products to individuals for a commission. WCF addresses this conflict by this disclosure and advises clients that they always have the option to purchase insurance through other insurance agents, even if it was recommended by a WCF insurance agent – investment professional. WCF will not charge clients an investment management fee for any commission-based investment that has resulted in a commission, such as insurance products. If a WCF Supervised Person - investment professional receives a commission for an insurance policy sale, clients will not also be billed through WCF for managing the same policy. Neither WCF nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management WCF does not accept performance-based fees or other fees based on a share of capital gains or capital appreciation of the assets of a client. Item 7: Types of Clients WCF generally offers advisory services to the following types of clients: ❖ ❖ ❖ Individuals High-Net-Worth Individuals Pension and Profit-Sharing Plans There is no account minimum for any of WCF’s services. 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis WCF’s methods of analysis include Modern portfolio theory. Modern portfolio theory is a theory of investment that attempts to maximize the expected portfolio return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Investment Strategies WCF generally uses long-term trading strategies. However, recommendations are based on the individual client’s stated objectives, risk tolerance, and other important factors described in the client’s Investment Policy Statement (“IPS”). B. Material Risks Involved Methods of Analysis Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. 9 Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirements or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. 10 Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report under this item. B. Administrative Proceedings There are no administrative proceedings to report under this item. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report under this item. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither WCF nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither WCF nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Steven Nuckols is an independent licensed insurance agent in the State of California, and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. WCF always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of WCF in connection with such individual's activities outside of WCF. Clients will not be billed advisory fees for commissionable product sales by WCF supervised persons. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections 11 WCF may utilize the services of a Sub-Adviser to manage Clients’ investment portfolios. Sub- Advisers will maintain the models or investment strategies agreed upon between Sub-Adviser and WCF. Sub-Advisers execute all trades on behalf of WCF Client accounts. WCF will be responsible for the overall direct relationship with the Client. WCF retains the authority to terminate the Sub-Adviser relationship at WCF’s discretion. WCF ensures that before selecting other advisers for Client that the other advisers are properly licensed or registered as an investment advisor. In addition to the authority granted to WCF Clients will grant WCF full discretionary authority and authorizes WCF to select and appoint one or more independent investment advisers to provide investment advisory services to Client without prior consultation with or the prior consent of Client. Such Advisers shall have all of the same authority relating to the management of Client’s investment accounts as is granted to WCF in the Agreement. This practice represents a conflict of interest as WCF may select Sub-Advisers who charge a higher or lower fee for their services than other Sub-Advisers. This conflict is mitigated by disclosures, procedures, and by the fact that WCF has a fiduciary duty of care to place the best interest of the Client first and will adhere to their code of ethics. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics WCF has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. WCF's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests WCF does not recommend that clients buy or sell any security in which a related person to WCF or WCF has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, investment adviser representatives of WCF may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for investment adviser representatives of WCF to buy or sell the same securities before or after recommending the same securities to clients resulting in investment adviser representatives profiting from the recommendations they provide to clients. Such transactions create a conflict of interest. WCF will always document any transactions that could be construed as conflicts of interest and will never 12 engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, investment adviser representatives of WCF may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of WCF to buy or sell securities before or after recommending securities to clients resulting in investment adviser representatives profiting from the recommendations they provide to clients. Such transactions create a conflict of interest; however, WCF will never engage in trading that operates to the client’s disadvantage if investment adviser representatives of WCF buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on WCF’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and WCF may also consider the market expertise and research access provided by the broker-dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in WCF's research efforts. WCF will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. WCF will require clients to use Charles Schwab Institutional (“Schwab”) or Fidelity Investments (“Fidelity”), both FINRA (www.finra.org) and SIPC (www.sipc.org) members and SEC registered Broker-Dealers. 1. Research and Other Soft-Dollar Benefits While WCF has no formal soft dollar program in which soft dollars are used to pay for third party services, WCF may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). WCF may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and WCF does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. WCF benefits by not having to produce or pay for research, products, or services, and WCF will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware 13 that WCF’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals WCF receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use WCF will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If WCF buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, WCF would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. WCF would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for WCF's advisory services provided on an ongoing basis are reviewed at least quarterly by Steven Nuckols, President, regarding clients’ respective investment policies, stated objectives, and risk tolerance levels. Financial planning services are generally provided to all clients to identify their financial situation as a one-time initial service when a client signs an advisory services agreement with WCF and as clients’ needs and financial situations change. The review and planning process is completed by Steven Nuckols. WCF’s financial planning services are complimentary to new clients and will generally conclude upon delivery of the initial financial planning report. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts 14 Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). Reviews will generally occur annually and will also be provided upon request. C. Content and Frequency of Regular Reports Provided to Clients Each client of WCF's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the account custodian. WCF will also provide a separate written statement to the client at least quarterly. Clients are urged to compare the WCF-prepared report to the statements provided by the account custodian. If a discrepancy is identified, clients are urged to contact us. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) WCF does not receive any economic benefit, directly or indirectly from any third party for advice rendered to WCF's clients. With respect to Schwab and Fidelity, WCF receives access to their institutional trading and custody services, which are typically not available to retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at the custodian. Schwab’s and Fidelity’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For WCF client accounts maintained in its custody, Schwab and Fidelity generally do not charge separately for custody services but are compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through them, or that settle into their accounts. Schwab and Fidelity also make available to WCF other products and services that benefit WCF but may not benefit its clients’ accounts. These benefits may include national, regional or WCF specific educational events organized and/or sponsored by them. Other potential benefits may include occasional business entertainment of personnel of WCF, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist WCF in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated 15 trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of WCF’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of WCF’s accounts. Schwab and Fidelity also make available to WCF other services intended to help WCF manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance, and marketing. In addition, they may make available, arrange and/or pay vendors for these types of services rendered to WCF by independent third parties. Schwab and Fidelity may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to WCF. WCF is independently owned and operated and is not affiliated with Schwab or Fidelity. B. Compensation to Non – Advisory Personnel for Client Referrals WCF may enter into written referral arrangements with third parties to act as “solicitors”, “promoters”, or “endorsers” for WCF's investment management services. These referral relationships will be fully disclosed to each Client to the extent required by applicable law. WCF will ensure each solicitor, promoter and/or endorser is exempt, notice filed or properly registered in all appropriate jurisdictions. WCF does not currently have any such written agreements. However, based on the tax and accounting services offered by WCF’s affiliated firm, Wealth Compass Tax and Accounting, and WCF’s affiliated insurance agency, Wealth Compass Insurance Services, clients of any of these individual firms may refer clients to the others based on Client needs or requests without exchanging fees or compensation for such referrals. Clients always have the option to refuse WCF’s advice, or the advice of WCF’s affiliated tax and accounting firm, Wealth Compass Tax and Accounting, and affiliated insurance agency, Wealth Compass Insurance Services. Item 15: Custody WCF does not maintain custody of client funds at any time. However, when advisory fees are deducted directly from client accounts at client's custodian, WCF will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements directly from the account custodian/broker-dealer (Schwab or Fidelity) and they should carefully review those statements for accuracy. 16 Item 16: Investment Discretion WCF accepts discretionary authority to manage securities accounts on behalf of clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, WCF generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Clients may limit our discretionary authority in the management of their account(s) by indicating any limitations in the client advisory contract. Item 17: Voting Client Securities (Proxy Voting) WCF will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security they own, or from the account custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet WCF neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither WCF nor its management has any financial condition that is likely to reasonably impair WCF’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years Neither WCF nor its owner has been the subject of a bankruptcy petition. 17 Business Continuity Plan Client Notice The Firm maintains a written business continuity plan to safeguard client data and information from data breaches and varying levels of other unforeseen circumstances related to management persons. The Plan includes a response and notification plan if a breach occurs involving the exposure of client private information. The Plan covers natural disasters such as earthquakes, hurricanes, tornados, flooding, wildfires, and pandemics, among other natural disasters. The Plan also covers man-made disasters such as fires, bomb threats, nuclear emergencies, chemical events, biological events, railway accidents, cyber or ransomware events, and aircraft accidents, as well as loss of utilities such as electrical power, loss of water pressure, T-1 communications line outages, and Internet outages. Electronic files are backed up daily and archived offsite, as well as being archived in a cloud-based data bank. An alternate office is identified to support ongoing operations in the event the main office is unavailable. Our alternative office is at WCF’s affiliated Tax and Accounting firm located at 940 Canterbury Place, Suite 100, Escondido, CA 92025. It is our intention to contact all clients within five days of a disaster that disrupts our operations, services, and/or dictates moving our office to an alternate location. WCF has sufficient members of the advisory and operations team to continue operations and business in the event of a loss of key personnel member. 18 Client Privacy Policy Notice Your relationship with WCF is based on trust and confidence. To fulfill its responsibilities to you, WCF requires that you provide current and accurate financial and personal information. You deserve to expect that WCF will protect the information you have provided in a manner that is safe, secure, and professional. WCF and its employees are committed to protecting your privacy and to safeguarding that information. Your Privacy WCF requires that you provide current and accurate financial and personal information so that we may make the best possible choices for your circumstances. We will protect the information you have provided in a manner that is safe, secure, and professional. We recognize the importance of protecting our clients’ privacy. We have policies to maintain the confidentiality and security of your non-public personal information. The following is designed to help you understand what information we collect from you and how we use that information to serve you. Information Security WCF maintains an information security program to reduce the risk that your personal, private, non-public, and confidential information may be breached. WCF is committed to maintaining the confidentiality, integrity and security of our clients’ personal information that is entrusted to us. During regular business hours, access to client records is monitored so that only those with approved entitlements may access the information. During hours in which the company is not in operation, client records are secured. We maintain a secure office to ensure that your cloud-based personal information is not placed at unreasonable risk. We employ a firewall barrier, secure data encryption techniques and multi- factor authentication procedures in our computer environment. Information We Collect To fulfill our responsibilities to you in providing you with wealth management services, WCF requires that you provide current and accurate financial and personal nonpublic information for which we base our recommendations on. In the normal course of business, we collect client data in checklists, forms, in written notations, in documentation provided to us by our clients for evaluation, planning, investing or other related consulting services, and data about client transactions with us, such as types of investments and account status. We also create internal lists of such data. The categories of non-public information that we collect from you may include information about your personal finances, information about your health to the extent that it is needed for the 19 financial planning process, information about transactions between you and third parties, and information from consumer reporting agencies, e.g., credit reports. We use this information to help you plan, invest, and work towards your personal financial goals. Safeguarding Customer Documents We have physical, electronic, and procedural security safeguards to protect and secure the information we collect. We restrict access to nonpublic personal information about our clients to those employees and agents who need to know that information to provide products and services to our clients. During regular business hours, access to client records is monitored so that only those with approved entitlements may access the files. During hours in which the company is not in operation, the client records will be secured. No individual who is not so authorized shall obtain or seek to obtain personal and financial client information. No individual with authorization to access personal and financial client information shall share that information in any manner without the specific consent of a firm principal. Failure to observe WCF procedures regarding client and consumer privacy will result in disciplinary action and may include termination. Although we make good-faith efforts to maintain the security of your personal information, we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration or that our security measures will prevent unauthorized persons and bad actors from accessing or obtaining this information. Notification in the Event of a Data Breach WCF has adopted an incident response program in the event of a data breach event. If your non- public information is breached by an unauthorized party, we will comply with applicable laws in notifying you of the breach as soon as possible, within 30 days of discovery. This includes critical third parties we do business with that may experience a breach affecting information  about you that could be used to harm you.  Sharing Non‐Public Personal and Financial Information WCF will not share such information with any affiliated or non-affiliated third party except:  When necessary to complete a transaction in a client account, such as with the clearing firm or account custodians;  When required to maintain or service a client account;  To resolve client disputes or inquiries;  With persons acting in a fiduciary or representative capacity on behalf of the client;  With rating agencies, persons assessing compliance with industry standards, or to the  attorneys, accountants and auditors of the firm; In connection with a sale or merger of WCF’s business; 20  To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;  To comply with federal, state or local laws, rules and other applicable legal   requirements; In connection with a written agreement to provide investment management or advisory services when the information is released for the sole purpose of providing the products or services covered by the agreement; In any circumstances with the client’s instruction or consent; or  Pursuant to any other exceptions enumerated in the California Consumer Information Privacy Act. Updating Your Personal Information and Privacy Preferences You have the right to access and correct or change any personal information that you provide to us at any time. If you believe that an error has been made in accordance with the information collected from you, we will correct such errors upon adequate verification of the error and the identity of the person seeking the correction. Contact your IAR or send us an email or letter. Any changes to the information that you have provided may affect the recommendations we make to you, the management of your account, or the delivery of other services and information to you. We will respond to your request within thirty days. Personally identifiable information (“PII”) about you will be maintained while you are a client, and for the required period thereafter that records are required to be maintained by federal and state securities laws. After that time, information will be securely destroyed. Opt‐Out Provisions It is a policy of WCF to not share non-public personal and financial information with affiliated or unaffiliated third parties except under the circumstances noted above. Since sharing under the circumstances noted above is necessary to service client accounts or is mandated by law, there are no allowances made for clients to “opt out”. If you decide to close your account(s) or become an inactive client, we will continue to adhere to the privacy policies and practices described in this notice. We reserve the right to change this policy at any time, and you will be notified if any changes do occur. We are required by law to deliver this Privacy Notice to you annually, in writing. If you have any questions after reading this Privacy Policy, please contact us at (760) 509-4000. 21 This ADV Part 2B Brochure Supplement provides information about Steven T. Nuckols that supplements the Wealth Compass Financial, Inc. ADV Part 2A Disclosure Brochure. You should have received a copy of that Disclosure Brochure. Please contact Steven Nuckols if you did not receive Wealth Compass Financial, Inc.’s ADV Part 2A Disclosure Brochure, or if you have any questions about the contents of this supplement. Additional information about Steven Nuckols (CRD# 6320555) is also available on the SEC’s website at www.adviserinfo.sec.gov. Wealth Compass Financial, Inc. Form ADV Part 2B – Individual Disclosure Brochure for Steven T. Nuckols Personal CRD Number: 6320555 President, Founder, and Investment Adviser Representative Wealth Compass Financial, Inc. 5860 Owens Ave #100 (760) 509-4000 snuckols@wealthcompass.com Updated: 3/19/2026 22 Item 2: Educational Background and Business Experience Steven T. Nuckols Name: Born: 1990 Education: B.A. Russian, Brigham Young University - 2014 Business Background: 09/2017 - Present President, Founder & CCO Wealth Compass Financial, Inc. 03/2021 – Present Founder, Insurance Agent Wealth Compass Insurance Services 01/2024 – Present Founder, Owner Wealth Compass Tax and Accounting 02/2017 – 08/2017 Unemployed 10/2016 - 01/2017 Advisor Assistant Blankinship and Foster 06/2015 - 09/2016 Financial Planner Gunderson Capital Management 05/2014 - 05/2015 Financial Representative Northwestern Mutual Item 3: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business. Additional information regarding Steven Nuckols’ registration as an investment adviser representative may be found by accessing the SEC’s public disclosure website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Steven Nuckols is an independent licensed insurance agent, and from time to time will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. When he sells an insurance product, Mr. Nuckols receives a commission. This presents a conflict of interest because it creates an incentive to recommend investment products based on the compensation received, rather than on the needs of clients. WCF always acts in the best interests of the client, including the sale of 23 commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of WCF in connection with such individual's activities outside of WCF. Item 5: Additional Compensation Steven Nuckols does not receive any economic benefit from any person, company, or organization, other than Wealth Compass Financial, Inc. in exchange for providing clients investment advisory services through Wealth Compass Financial, Inc. Mr. Nuckols receives compensation or other benefits through his CA insurance license through Wealth Compass Insurance Services when he sells an insurance policy or product, as disclosed in Item 4. Mr. Nuckols also receives net income of business revenue as owner and officer of Wealth Compass Tax & Accounting, which provides tax services. Mr. Nuckols is not a tax professional or an accountant, and does not provide tax advice or services. Mr. Nuckols may also receive compensation or benefits through his affiliation with Advisors Excel, LLC (and/or its affiliated companies). Such additional compensation and benefits generally consist of cash bonus payments and reward trips based on insurance product sales performance. Item 6: Supervision As the President and Chief Compliance Officer of Wealth Compass Financial, Inc., Steven Nuckols supervises all activities of the firm. Mr. Nuckols' contact information is on the cover page of this disclosure document. Mr. Nuckols adheres to applicable regulatory requirements, together with the firm’s compliance policies and procedures, its outlined code of ethics and conduct standards. 24 This ADV Part 2B Brochure Supplement provides information about Tod Leighton Lenhoff that supplements the Wealth Compass Financial, Inc. ADV Part 2A Disclosure Brochure. You should have received a copy of that Disclosure Brochure. Please contact Steven Nuckols if you did not receive Wealth Compass Financial, Inc.’s ADV Part 2A Disclosure Brochure, or if you have any questions about the contents of this supplement. Additional information about Tod Lenhoff (CRD# 3255143) is also available on the SEC’s website at www.adviserinfo.sec.gov. Wealth Compass Financial, Inc. Form ADV Part 2B – Individual Disclosure Brochure for Tod L. Lenhoff Personal CRD Number: 3255143 Wealth Compass Financial, Inc. 5860 Owens Ave #100 (760) 509-4000 tlenhoff@wealthcompass.com Updated: 3/19/2026 25 Item 2: Educational Background and Business Experience Tod L. Lenhoff Name: Born: 1960 Education: B.A. Business, Cal State Northridge – 1982 Professional Designations: CPA (Certified Public Accountant) Business Background: 06/2021 - Present Wealth Manager / Investment Adviser Representative Wealth Compass Financial, Inc. 03/2021 – Present Insurance Agent Wealth Compass Insurance Services 12/2016 – 06/2021 Investment Advisor Representative AE Wealth Management, LLC 07/2002 - 03/2021 President Lenhoff Senior Planning, Inc 07/2002 - 03/2021 President/Insurance Agent Lenhoff Financial Group 12/2016 - 11/2017 Registered Representative Madison Avenue Securities, LLC 10/2014 - 12/2016 Registered Representative GF Investment Services LLC 10/2014 - 12/2016 Investment Advisor Representative Global Financial Private Capital, LLC Item 3: Disciplinary Information Tod L. Lenhoff has no civil, criminal, administrative or regulatory events to report. Additional information regarding Mr. Lenhoff’s registration as an investment adviser may be found by accessing the SEC’s public disclosure website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Lenhoff is licensed in California as an insurance agent with Wealth Compass Insurance Services to offer insurance and annuities, and may offer life insurance and annuity products to people that may also be clients of Wealth Compass Financial, Inc. When he sells an insurance or annuity product, Mr. Lenhoff may receive a commission directly from Wealth Compass 26 Insurance Services. This presents a conflict of interest because it creates an incentive to recommend insurance products based on the compensation received, rather than on the needs of clients. Wealth Compass Financial, Inc. addresses this conflict with disclosures and compliance and supervisory policies and procedures, which require all investment advisory recommendations to be made in the best interest of our clients. Clients are under no obligation to purchase any product or service. But when doing so, you are not obligated to purchase through Mr. Lenhoff, but may choose another insurance agent or agency, even when acting upon Mr. Lenhoff’s recommendation(s). Mr. Lenhoff is a Certified Public Accountant (CPA) in good standing. However, Mr. Lenhoff does not operate a tax business or receive compensation for any tax advice. Item 5: Additional Compensation Tod Lenhoff does not receive any economic benefit from any person, company, or organization other than Wealth Compass Financial, Inc. in exchange for providing clients advisory services through Wealth Compass Financial, Inc. Mr. Lenhoff may receive compensation or benefits through his insurance licensing from Wealth Compass Insurance Services. Item 6: Supervision Wealth Compass Financial’s CCO, Steven Nuckols, supervises all activities of the firm. Tod Lenhoff adheres to applicable regulatory requirements, together with all policies and procedures outlined in the firm’s code of ethics and compliance policies and procedures manual. Clients may contact Mr. Nuckols at (760) 509-4000 with any questions regarding supervision or compliance procedures. 27