WEALTH INTELLIGENCE, LLC

Item 1 – Cover Page Wealth Intelligence, LLC Firm Brochure January 26, 2026 This brochure provides information about the qualifications and business practices of Wealth Intelligence, (hereinafter referred to as “Wealth Intelligence” or “our firm”). If you have any questions about the contents of this brochure, please contact us at (706) 5741- 2100 or by email at: info@wealthintel.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Wealth Intelligence is available on the SEC’s website at www.adviserinfo.sec.gov. Wealth Intelligence’s CRD number is 333253. Columbus Office 2900 Warm Springs Rd. Columbus, Georgia, 31904 (470) 745-5030 Zebulon Office 9840 U.S. Highway 19 North P.O. Box 352 Zebulon, GA 30295-3176 1  Item 2 – Material Changes This section summarizes the material changes that have been made to this Form ADV Part 2A (“Firm Brochure”) for Wealth Intelligence since our last annual amendment. Since the last annual amendment filed on February 14, 2025, the following material changes have been made: • Our regulatory assets under management have been updated to reflect values as of December 31, 2025 (see Item 4). • Christopher Payne has assumed the role of Chief Compliance Officer. • Our firm has begun participating in the Schwab Client Benefits Program, which is described in more detail in Item 12 of this Brochure. We may update this Brochure at other times during the year if additional material changes occur. If the changes are material, we will provide you with a summary of those material changes and/or an updated Brochure as required. 2  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................................ 1 Item 2 – Material Changes ................................................................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................................... 3 Item 4 – Advisory Business ................................................................................................................................................ 4 Item 5 – Fees and Compensation ................................................................................................................................... 10 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................. 16 Item 7 – Types of Clients .................................................................................................................................................... 16 Item 8 – Methods of Analysis, Investment Strategies, & Risk of Loss............................................................. 16 Item 9 – Disciplinary Information ................................................................................................................................. 22 Item 10 – Other Financial Industry Activities, Affiliates, and Conflicts of Interests ................................ 23 Item 11 – Code of Ethics..................................................................................................................................................... 24 Item 12 – Brokerage Practices ........................................................................................................................................ 25 Item 13 – Review of Accounts ......................................................................................................................................... 27 Item 14 – Client Referrals and Other Compensation ............................................................................................. 29 Item 15 – Custody ................................................................................................................................................................. 29 Item 16 – Investment Discretion .................................................................................................................................... 30 Item 17 – Voting Client Securities .................................................................................................................................. 31 Item 18 – Financial Information ..................................................................................................................................... 32 3  Item 4 – Advisory Business Wealth Intelligence is an integrated wealth management firm that provides investment advisory and related services primarily to individuals and families, including multi- generational families. As part of those relationships, we also advise on the entities and assets they own or control, such as closely held businesses, family farms, trusts, estates, private foundations, and other family investment or charitable entities. Wealth Intelligence is solely owned and controlled by Bryan Oglesby. We filed our initial application to register as an investment adviser in September 2024, and our registration was approved on October 18, 2024. Our advisory services are organized around four primary service types, which can be provided on a stand-alone basis or bundled together as part of a broader wealth management relationship. When these services are combined into a comprehensive relationship, they are referred to as our Wealth Management Advisory Services Program (or “WMAS Program”), as described in Schedule B of the Wealth Intelligence Advisory Services Agreement. • Financial Planning Services – one-time or ongoing financial planning and consulting for individuals and families, including advice on accounts we do not manage directly (such as 401(k) and other employer retirement plan accounts). • Investment Advisory Services – ongoing portfolio management and investment advisory services for accounts held with an independent custodian, typically on a discretionary basis. • Business Consulting Services – advisory and consulting services for business owners and closely held businesses, often coordinated with the owner’s personal financial and estate planning. • Family Office Services – customized family office services for ultra-high-net-worth and multi-generational families, often combined with our financial planning and investment advisory services. We generally manage client investment accounts on a discretionary basis, meaning we make day-to-day investment decisions and place trades for you without asking your approval for each transaction, consistent with your goals, risk tolerance, and any reasonable restrictions you provide. Clients may engage us for more than one of these services at the same time (for example, financial planning together with investment advisory services, or investment advisory services together with family office services). The subsections below describe each of these services in more detail. 4  Wealth Management Advisory Services Program (“WMAS”) Our Wealth Management Advisory Services Program (“WMAS”) is our core, full-service wealth management offering. Under WMAS, we typically combine our four primary service types—investment advisory (portfolio management), financial planning, business consulting, and family office services—into an integrated relationship for you and, where applicable, your family and related entities. The specific components and scope of services for each WMAS relationship are described in your Advisory Services Agreement and related schedules. For WMAS clients, we provide ongoing financial, estate planning, and consulting services. We help you and your “Covered Client Parties” (as defined in your Advisory Services Agreement) understand your overall financial picture, review key documents (such as existing estate planning, insurance, and investment materials), and develop a coordinated plan and investment strategy based on your goals and risk tolerance. We revisit your situation periodically—typically at least annually, and more often as needed—to update your plan, identify action items, and coordinate with your other professional advisors. WMAS clients also generally have access to tax planning and coordination support. We help you and your independent tax professionals understand how your investments and planning strategies may affect your tax situation, and we coordinate with them on tax reporting and compliance matters. At your request and with appropriate authorizations in place, we may help arrange for payment of estimated and final tax liabilities directly from your accounts. We do not provide tax or accounting advice; those services are provided by independent professionals you engage. As part of insurance and risk management, we assist you in evaluating your overall risk management and insurance needs (such as life, disability, long-term care, and property and casualty coverage), reviewing existing policies, and coordinating with insurance professionals. Insurance products may be made available through our affiliated insurance firm, Oglesby Strategic Services (“OSS”), as well as through unaffiliated insurance companies and agents, as described in Item 10 of this Brochure. Where trusts are part of your planning, we can help you define criteria for an appropriate trustee, evaluate potential individual or institutional trustees, and coordinate with the chosen trustee on your planning and investment needs. In some cases, an individual associated with our firm may agree to serve as trustee, which can create additional conflicts of interest and may result in our being deemed to have custody of those assets, as described in Items 10 and 15 of this Brochure. At your request, we may also assist with lifestyle management and cash-flow support, which can include connecting you with independent third-party providers for services such as bill payment, expense tracking, and personalized cash-flow reporting. These services are typically provided by third-party firms, and any fees they charge are separate from, and in addition to, the advisory fees you pay to us. 5  Finally, WMAS clients may receive philanthropic and charitable planning support. We can help you design and monitor giving strategies, advise on the use of private foundations, donor-advised funds, or charitable trusts, and coordinate with your legal and tax advisors on related administrative and tax matters. Any specific legal or tax advice in this area is provided by your independent professionals, and we help integrate their recommendations into your broader financial and investment plan. More detailed information about our services, fees, and conflicts of interest appears in Items 4, 5, 10, and 11 of this Brochure. Additional information about Wealth Intelligence is available at the SEC’s public website for investment advisers. You can find us at www.adviserinfo.sec.gov by searching our CRD number: 333253. Financial Planning Services We provide financial planning services on a stand-alone or ongoing basis for individuals and families. Financial planning may be limited in scope (for example, focused only on retirement or education planning) or comprehensive, depending on your needs. Our financial planning services generally include: • Personal consultation and preparation of a personalized financial plan • Analysis of your financial status, investment objectives, risk tolerance, and personal situation • Review of your income, expenses, assets, liabilities, and cash flows • Recommendations regarding savings, investments, retirement planning, estate planning considerations, insurance needs, and other financial goals • Consulting and recommendations for accounts we do not manage directly, such as 401(k) plans and other “held-away” accounts In certain cases, and at your request, we may also assist with the execution of specific transactions related to your financial plan (for example, reallocating investments in a held- away retirement plan), subject to the capabilities and rules of the relevant provider. For clients who engage us for ongoing investment advisory services, financial planning services are typically provided at no additional charge and are included as part of the client’s investment advisory fee. In some cases—such as particularly complex planning engagements or stand-alone planning services—financial planning may instead be provided on an hourly, flat-fee, or periodic-fee basis, as appropriate and as described in your advisory agreement and in Item 5 of this Brochure. In all cases, you will be informed in advance of the financial planning fee (or the basis on which it will be determined) before you agree to the service. Legal and Tax Matters. Wealth Intelligence does not provide legal or accounting advice. Many aspects of financial planning, however, involve basic and more complex legal and tax considerations. We will help identify those issues and assist you to the extent appropriate 6  as part of the planning process. Any specific tax or legal advice is provided by independent professionals engaged by you. We work with those professionals, as needed, to help coordinate and integrate their work with your overall financial plan and investment strategy. Investment Advisory Services Under our investment advisory services, we provide ongoing investment advisory and portfolio management services for accounts held with an independent custodian. These services are often combined with financial planning, business consulting, and family office services as part of our Wealth Management Advisory Services Program but may also be provided on a stand-alone basis. We generally manage client investment accounts on a discretionary basis, meaning we make day-to-day investment decisions and place trades for you without asking your approval for each transaction, consistent with your goals, risk tolerance, and any reasonable restrictions you provide. As part of this service, we work with you to understand your objectives, time horizon, liquidity needs, and overall financial circumstances, and then design and implement an investment strategy for your accounts. We monitor your portfolio on an ongoing basis, make adjustments as we believe appropriate, and review your strategy with you periodically (typically at least annually, and more often as needed). You may place reasonable limitations or restrictions on how we manage your accounts—for example, asking us to avoid certain securities, industries, or types of investments—and we will manage your portfolio in accordance with those instructions so long as they are not inconsistent with your overall objectives or applicable law. In addition to managing accounts you custody with an independent custodian, we may also provide advice on “held-away” accounts, such as employer-sponsored retirement plans, where we do not have trading authority. In those cases, we provide recommendations, and you are responsible for deciding whether and how to implement our advice in those accounts. We provide advisory services to retirement investors (such as participants in employer-sponsored retirement plans and owners of individual retirement accounts (“IRAs”)), including advice about rollovers and how to invest retirement assets. In managing portfolios, we typically use a mix of individual U.S. stocks, exchange-traded funds (“ETFs”), mutual funds, cash, and fixed-income investments, tailored to your objectives, risk tolerance, and time horizon. The specific methods of analysis, investment strategies, and risks associated with our approach are described in Item 8 of this Brochure. Business Consulting Services We provide business advisory and consulting services at the request of business-owner clients and closely held businesses. These services may be provided on a stand-alone basis or in combination with our financial planning and investment advisory services. 7  Business consulting services may include, for example: • Helping you understand how your business fits within your overall family balance sheet and estate plan • Evaluating potential succession, sale, or exit strategies for the business • Assessing the financial impact of a potential sale or transition • Assisting with cash-flow planning and capital structure considerations for the business • Helping you coordinate business planning with your personal financial, tax, and estate planning objectives We may also help you identify and coordinate with independent attorneys, CPAs, valuation experts, and other professionals. Legal and Tax Matters. Wealth Intelligence does not provide legal or accounting advice. Many aspects of business consulting involve both basic and complex legal and tax considerations (for example, choice of entity, ownership and succession structures, and income, gift, and estate tax implications of a business sale or transfer). We will help identify these issues and assist you to the extent appropriate as part of our consulting services. Any specific tax or legal advice is provided by independent professionals engaged by you. We work with those professionals, as needed, to help coordinate and integrate their work with your broader business, financial planning, and investment strategies. Business consulting services may be billed on an hourly, project, or other agreed basis, as described in your advisory agreement and in Item 5 of this Brochure. Family Office Services We provide family office services to ultra-high-net-worth and multi-generational families, often in combination with our financial planning and investment advisory services. These services are customized to each family’s situation and may include: • Comprehensive financial planning and ongoing advisory support • Coordination of expense management and bill pay (often through or in coordination with independent third-party providers) • Cash-flow planning and consolidated reporting across multiple accounts and entities • Coordination of tax compliance and tax return preparation services, which are performed by independent accounting firms • Coordination with family attorneys on estate planning, entity structuring, governance, and succession matters • Philanthropic planning and administration for family foundations, charitable trusts, and donor-advised funds • Oversight and monitoring of investments in third-party limited partnerships and other alternative investments, where appropriate for the family’s objectives and risk tolerance 8  Some family office relationships include investment management; others focus primarily on planning, coordination, and administrative support. Where we provide investment management as part of a family office relationship, we generally do so on a discretionary basis, subject to any reasonable client-imposed restrictions, as described above under Investment Advisory Services. Legal and Tax Matters. Wealth Intelligence does not provide legal or accounting advice. Many aspects of family office services involve both basic and complex legal and tax considerations (for example, entity structuring, trust and estate planning, and income, gift, and estate tax planning). We will help identify these issues and assist you to the extent appropriate as part of our family office services. Any specific tax or legal advice is provided by independent professionals engaged by you. We work with those professionals, as needed, to help coordinate and integrate their work with your broader family office, financial planning, and investment strategies. Fees for family office services may be separate from, or in addition to, our investment advisory fees, depending on the scope of services we provide. The applicable fee arrangements are described in your advisory agreement and in Item 5 of this Brochure. Rollover Recommendations When we (or one of our financial professionals) recommend that you roll over assets from an employer-sponsored retirement plan (such as a 401(k) or 403(b)) to an individual retirement account (“IRA”) that we will manage, we have a conflict of interest. If you keep your assets in the plan, we generally do not receive an advisory fee on those assets. If you roll the assets into an IRA that we manage, we will typically charge an advisory fee and, as a result, our compensation will increase. The more assets you roll over for us to manage, the higher our potential advisory fees. Because we earn more if you roll over assets to an IRA with Wealth Intelligence than if you leave them in your plan, our recommendation to open or fund an IRA that we manage creates a financial incentive for us and may conflict with your interests. This conflict could, at least in theory, influence us to recommend a rollover even when keeping some or all assets in your existing plan might be as good as or better for you. We have adopted policies and procedures designed to manage this conflict and to help ensure that rollover recommendations are made in your best interest, including: • Following an impartial conduct standard, which requires us to: o Act in your best interest when providing rollover advice; o Not recommend investments or fee arrangements that would result in unreasonable compensation to Wealth Intelligence; and o Clearly disclose our compensation and any material conflicts of interest related to rollover recommendations and avoid making materially misleading statements. 9  • Considering and discussing with you the available options, which may include: o Leaving assets in your current plan (if permitted), o Rolling assets to a new employer’s plan (if available), o Rolling assets to an IRA with Wealth Intelligence or another provider, or o Taking a distribution (and the tax and penalty implications of doing so). When we provide you with investment advice as a retirement investor about whether to keep assets in your current plan, roll them to an IRA (including an IRA we manage), or take a distribution, Wealth Intelligence acts as a fiduciary under applicable law. In that role, our financial professionals are required to act with the care, skill, prudence, and diligence that a prudent person familiar with such matters would use, based on your investment objectives, risk tolerance, financial circumstances, and needs, and without regard to the financial or other interests of Wealth Intelligence or our associated persons. Assets Under Management As of December 31, 2025, Wealth Intelligence had $247,495,975 in regulatory assets under management. All assets are managed on a discretionary basis currently. Item 5 – Fees and Compensation Fees for Investment Advisory (Portfolio Management) Services For our ongoing investment advisory (portfolio management) services, clients generally pay an annual advisory fee (the “Fee”), payable quarterly in advance, as described in their Advisory Services Agreement and Schedule A. For more information, review How and When Investment Advisory Fees Are Billed. Depending on the relationship, the Fee is typically structured an asset-based fee (percentage of assets under management). Clients are most often charged an annual fee based on a percentage of the assets we manage for them. The applicable fee schedule is set out in Schedule A to the Advisory Services Agreement. Under our current standard schedule, the annual advisory fee will not exceed 2.00% per year. In some cases (for example, certain consulting or limited-scope arrangements), we allow for hourly, annual, or fixed/flat investment consulting fees instead of a traditional percentage-of-assets fee. The specific fee arrangement for each client is described in that client’s Advisory Services Agreement and Schedule A. Our fees are negotiable, and fee rates may vary based on factors such as account size, services requested, and overall relationship. 10  Account Minimums. Our standard minimum account size for investment advisory relationships is $2,000,000. Wealth Intelligence may, in its sole discretion, waive or reduce this minimum or charge a lower advisory fee in appropriate circumstances (for example, based on anticipated future assets, related accounts, existing or long-standing relationships, or other factors we deem relevant). How and When Investment Advisory Fees Are Billed. Unless an alternative fee method is selected in Schedule A and agreed with you: • The Fee is calculated as a percentage of the fair market value of all assets in your advisory accounts as of the last trading day of the prior calendar quarter, as determined by the custodian(s). • The Fee is billed quarterly in advance. • When an account is first opened (incepted), the initial Fee is prorated for the remainder of the current billing period and is based on the account’s fair market value at inception. For purposes of calculating the Fee, the account value generally includes: • Cash • Mutual funds, ETFs, and other pooled investment vehicles Individual securities (such as stocks and bonds) • • Other investments held in the advisory accounts Although we do not typically use margin as a core strategy, a client’s margin balance is typically included when calculating assets under management, so the advisory fee may be based on assets purchased on margin in addition to any margin interest you pay to the custodian. If there is not enough cash in an account to cover the Fee when it is due, securities in the account may be sold to raise cash, which may result in transaction costs and potential tax consequences. Termination and Refunds. If this Agreement terminates before the end of a prepaid quarter, you are entitled to a pro- rata refund of the Fee paid in advance, based on the number of days the account was open during that quarter. All such refunds are to be promptly paid to you. Upon termination, we may deduct any accrued but unpaid fees from your account before assets are transferred or distributed. After termination, your account will no longer be subject to our advisory Fee, and any future trades in that account (if it remains open at the custodian) will be subject to the custodian’s standard brokerage commissions and charges. 11  How Fees Are Paid. Under our standard Advisory Services Agreement, you authorize the custodian to automatically deduct the Fee from your advisory account when due. The deducted Fee appears on the next custodial statement. The custodian sends you at least quarterly account statements showing all activity, including the Fees paid. You are responsible for verifying the accuracy of all Fee calculations because the custodian does not verify our calculation. Fees for Financial Planning Services For most clients who engage us for ongoing investment advisory services, financial planning services are typically provided at no additional charge and are included as part of the client’s investment advisory fee. In those cases, we do not bill a separate fee for financial planning. Under the Advisory Services Agreement, however, financial planning services have their own fee schedule and may also be provided on a separate fee basis, generally as: • Hourly financial planning fees. An hourly rate is agreed and set out in Schedule A. You are invoiced for hours worked, and hourly fees are generally due within 30 days of the invoice date. • Annual financial planning fees. In some cases, an annual planning fee may be agreed and paid periodically (for example, quarterly) by check or account withdrawal, as indicated in Schedule A. We may charge these separate financial planning fees in situations such as stand-alone planning engagements (where you do not engage us for ongoing investment advisory services), or for particularly complex or time-intensive planning projects. Your Advisory Services Agreement provides that financial planning charges may be reduced and/or waived if you obtain investment advisory services from Wealth Intelligence. In practice, this means that for many advisory clients, financial planning is provided at no additional charge beyond the advisory fee. Financial planning fees are negotiable, based on the complexity of your situation, the scope of the planning work, and the time and expertise required. For each planning engagement, we will provide you with a fee quote or fee range and explain how and when the fee will be billed, before you agree to the service. The specific fee arrangement for your engagement is described in your Advisory Services Agreement and Schedule A. You are not required to engage us for investment advisory or family office services in order to receive financial planning services. 12  Fees for Business Consulting Services For clients who engage us for ongoing investment advisory and/or family office services, business consulting that is reasonably related to that broader relationship may be included as part of the overall advisory fee and not billed separately. In other situations, such as stand-alone business consulting engagements or particularly complex projects, business consulting services may be billed separately. In those cases, fees are generally structured as: • Fixed (project-based) fees for a defined scope of work; and/or • Hourly fees where appropriate. Business consulting fees are negotiable and depend on factors such as: • The scope and complexity of the engagement, • The expected time and resources required, and • The level of coordination with other professionals (such as attorneys, CPAs, and valuation experts). Whether your business consulting services are included in your investment advisory fee or billed separately—and, if separate, the specific fee structure and amount—will be described in Schedule A or another written agreement with you. Billing and Payment. When billed separately, business consulting fees are generally billed and paid in advance, in stages (for example, upon completion of certain milestones), or upon completion of the agreed work, as specified in your agreement. Fees for Family Office Services For family office clients, some or all of the family office services that are reasonably related to the broader wealth management relationship may be included as part of the overall investment advisory fee and not billed separately. In other situations—such as where the scope of family office services is extensive, highly customized, or primarily administrative/coordination in nature—family office services may be billed separately. In those cases, fees are generally structured as: • Flat or periodic fees (for example, a quarterly or annual family office fee) for an agreed scope of services; and/or • Project-based or hourly fees for specific projects or incremental work (such as a large governance, reporting, or entity-structure project). Family office fees are negotiable and may depend on factors such as: • The number and complexity of family entities (trusts, partnerships, foundations, operating businesses, etc.), • The volume and frequency of reporting and coordination required, 13  • The level of involvement in bill-pay, cash-flow management, and other administrative tasks, and • The extent of our investment management responsibilities as part of the relationship. Whether your family office services are included in your investment advisory fee or billed separately—and, if separate, the specific fee structure and amount—will be described in your Advisory Services Agreement, Schedule A, and/or a separate family office addendum or engagement letter. Billing and Payment. When billed separately, family office fees are generally billed and paid in advance. However, family office fees may also be billed in arrears, or in stages (for example, monthly, quarterly, or on project milestones), as specified in your agreement. Where family office services include investment management, the advisory fees for that portion of the relationship are usually charged in the same manner as our investment advisory (portfolio management) fees described above (typically asset-based, billed quarterly in advance). Brokerage and Transaction Costs Under the Advisory Services Agreement, clients are responsible for brokerage and transaction costs and custodial fees associated with their accounts. These charges may include: • Brokerage commissions and markups/markdowns • Custodian account fees (such as maintenance, wire, transfer, or account closing fees) • Ticket charges and other transaction-related costs However, under our current standard Schedule A, for accounts subject to the “Standard Investment Advisory Fee,” the advisory fee is exclusive of brokerage and custodian fees and expenses. To the extent applicable, you will also bear indirect expenses of mutual funds, ETFs, and other pooled investment vehicles, including investment companies, separate account managers, and similar vehicles in which your account invests. For example, the internal management fees and operating expenses of those funds. We describe our brokerage practices in more detail in Item 12 – Brokerage Practices of this Brochure. Billing of Fees Unless otherwise specified in your Advisory Services Agreement and Schedule A: • Investment advisory fees (asset-based fees and most alternative consulting fee structures for advisory accounts) are billed quarterly in advance and deducted directly from your advisory account at the custodian, pursuant to your written authorization. 14  • Separate financial planning, business consulting, and family office services fees may be invoiced directly (for example, hourly planning fees due within 30 days) or, if you authorize, may be deducted from your account, as indicated in Schedule A. For any fee billed in advance (whether advisory or otherwise), if the underlying agreement is terminated before the end of the billing period, the unearned portion of prepaid Fees will be refunded on a prorated basis, as described above and in your Advisory Services Agreement. Other General Information on Wealth Intelligence Fees and Compensation Wealth Intelligence’s primary sources of revenue are the advisory and consulting fees that clients pay under the Advisory Services Agreement and any related schedules or addenda. Because we generally charge an asset-based advisory fee (a percentage of the assets in your accounts), the more assets you have in your advisory accounts with us, the more you will pay in fees and the more revenue we and our financial professionals will receive. This creates a conflict of interest because we have a financial incentive to encourage you to increase the assets in your accounts with us (for example, by transferring assets from other accounts or rolling over assets from an employer retirement plan into an account that we manage), even though other options—such as leaving assets in a current plan, investing elsewhere, or using assets for other purposes—may also be available. Our financial professionals are typically paid a portion of the advisory fees that you pay to us, so they also benefit when the value of your accounts and the amount of assets you keep with Wealth Intelligence increase. This may create an additional incentive for them to recommend that you add assets to your advisory accounts with us rather than keeping those assets in other accounts or investments. We seek to manage these conflicts through our fiduciary duty, our policies and procedures, and by disclosing these conflicts so you can consider them when evaluating our recommendations. Neither Wealth Intelligence nor its supervised persons receive commissions or other transaction-based compensation in their capacity as investment adviser representatives of Wealth Intelligence for recommending or selling securities or other investment products. We also do not receive “soft dollar” benefits from brokers or other third parties in connection with client securities transactions, as described in Item 12 of this Brochure. Under certain circumstances, our fees and account minimums may be negotiable, and we may waive account minimums at our discretion. We may also maintain legacy fee schedules or arrangements for relationships that pre-date this Brochure and may manage accounts for employees, their family members, and close friends at discounted or waived fees. All specific fee arrangements for your relationship with us are set out in your Advisory Services Agreement, Schedule A, and any related addenda, and are summarized in this Brochure. 15  Item 6 – Performance-Based Fees and Side-By-Side Management Wealth Intelligence does not charge performance-based fees or any other fees calculated as a share of capital gains or capital appreciation of a client’s assets. All of our advisory fees are charged as asset-based, flat, hourly, or other fixed fees, as described in Item 5 of this Brochure and in your Advisory Services Agreement. Because we do not charge performance-based fees, we do not face the specific conflicts of interest that can arise when an adviser manages both performance-fee and non- performance-fee accounts side-by-side. Item 7 – Types of Clients Wealth Intelligence primarily works with individuals and their families, including: • High-net-worth and ultra-high-net-worth families • Multi-generational families As part of these relationships, we also advise on and may provide services to related entities and structures that our clients own or control, such as: • Trusts and estates • Family investment entities, partnerships, and limited liability companies • Private foundations and other charitable organizations • Closely held businesses, family farms, and other operating or holding companies connected to the family Our standard minimum account size for investment advisory relationships is $2,000,000. Wealth Intelligence may, in its sole discretion, waive or reduce this minimum or charge a lower advisory fee in appropriate circumstances (for example, based on anticipated future assets, related accounts, or the overall scope of the relationship). To establish a client relationship with Wealth Intelligence, you must enter into a written Advisory Services Agreement (and any related schedules or addenda) specifying the particular services we will provide. Item 8 – Methods of Analysis, Investment Strategies, & Risk of Loss Methods of Analysis Our firm primarily uses a fundamental, top-down research process to develop investment ideas and construct portfolios. In practice, this generally involves: • Top-down, theme-based analysis. We start by analyzing broad economic, market, and industry trends and identifying long-term themes (for example, demographic shifts, technology adoption, or other 16  structural trends). We then look for companies and investments that we believe are well positioned to benefit from those themes. • Fundamental, bottom-up company research. Within those themes, we perform company-level analysis to identify what we view as “best-in-breed” U.S. companies, with a focus on larger, established businesses. We consider factors such as business model, balance sheet strength, earnings quality, competitive positioning, management, and valuation. • Asset-allocation and risk alignment. Once we have a universe of equities and other investments, we build asset-allocation models that blend equities, fixed income, and cash (and, where appropriate, other asset classes) based on each client’s goals, time horizon, and risk tolerance. • Use of risk-profiling tools. We use risk-profiling tools, along with our own analysis and discussions with you, to understand your risk tolerance and risk capacity, and to help align your portfolio with that risk profile. • Research sources. Our research draws on a variety of sources, which may include custodial research platforms, independent research providers and data services, company filings and public disclosures, financial news and economic data, and discussions with other professionals in the industry. We seek be “collectors of intelligence” and then narrow that information down to what is relevant for each client’s portfolio. We typically design and manage client portfolios internally, although we may use mutual funds, exchange-traded funds (“ETFs”), or, in limited cases, other pooled vehicles to gain exposure to certain asset classes or strategies where that is more efficient or practical than using only individual securities. Investment Strategies Our core investment strategies are implemented primarily through: • Individual U.S. equities. We typically emphasize individual U.S. stocks, with a focus on larger, established companies we believe are high quality and aligned with our top-down themes. • ETFs and mutual funds. We use ETFs and mutual funds to obtain diversified exposure to specific asset classes, sectors, styles, or markets (for example, fixed income, certain equity sectors, or international exposures) where individual security selection may not be efficient or cost-effective. 17  • Cash and fixed income investments. We use cash and fixed income (such as bond funds and, where appropriate, individual bonds or other fixed-income instruments) to help manage volatility, provide income, and align your portfolio with your risk tolerance and time horizon. • Options strategies (limited use). For certain clients and where appropriate, we may use relatively conservative options strategies, such as covered calls or cash-secured puts, to seek additional income or help manage risk. We do not use complex or speculative derivatives as a primary investment strategy. • Private funds and alternative investments (limited use). We do not routinely recommend hedge funds, private equity funds, or other complex private investment vehicles. In limited cases, where we determine that such an investment is suitable and appropriate for a particular client in light of that client’s objectives, risk tolerance, liquidity needs, and overall financial situation, we may evaluate and recommend such investments as a small part of the client’s broader portfolio. We may also assist certain clients in monitoring private investments they already hold, as part of their overall asset allocation. Customization and Discretion. Portfolios are customized at the client level. While many clients may hold similar core positions or models, we tailor: • Overall asset allocation, • Position sizing, and • Use of cash, fixed income, and any options or alternative exposures to each client’s goals, risk tolerance, income needs, tax situation, and constraints. Most investment advisory relationships are managed on a discretionary basis, as described in Item 4. You may place reasonable restrictions on investing in certain securities, industries, or types of investments, and we will manage your portfolio in accordance with those restrictions to the extent they are reasonable and not inconsistent with your overall objectives or applicable law. Risk of Loss Investing involves risk, including the possible loss of principal. You should be prepared to bear the risk of loss and volatility associated with investing in securities and other financial instruments. There is no guarantee that any investment strategy we recommend will achieve your goals or avoid losses. 18  The key risks associated with our methods and strategies are summarized below in alphabetical order for your convenience. The order does not reflect the relative importance or likelihood of any particular risk. This list is not exhaustive. • Active Management Risk. Our portfolios are actively managed, which means we make ongoing decisions about what to buy, sell, and hold. Active management may result in higher portfolio turnover, which can increase trading costs and, in taxable accounts, may increase realized capital gains or losses and affect the taxes you pay. Our judgments about markets, sectors, or specific securities may prove incorrect, and actively managed accounts may underperform more passive approaches. • Cash and Cash Equivalents Risk. At times, portfolios may hold significant amounts in cash or cash equivalents (such as money market funds or short-term instruments). Holding cash can help manage risk, but there is a risk that the return on cash will not keep pace with inflation, reducing purchasing power over time. In rising markets, a high cash allocation can also cause a portfolio to underperform more fully invested strategies. • Concentration and Non-Diversification Risk. Our top-down, theme-based approach may at times lead us to emphasize certain sectors, industries, or types of companies. Some strategies or accounts may also hold relatively concentrated positions in a smaller number of securities. If a portfolio is less diversified, adverse developments affecting a single issuer, sector, or theme can have a larger negative impact on the portfolio as a whole than would be the case in a more broadly diversified strategy. • Cybersecurity and Operational Risk. Like other firms that rely on technology, Wealth Intelligence and our service providers are subject to operational and information-security risks, including the risk of cyber-attacks, data breaches, and systems failures. Cyber incidents can include unauthorized access to systems, data theft or corruption, ransomware, or denial-of-service attacks. A significant cyber incident or operational disruption could impair our ability to operate, compromise confidential information, or otherwise negatively affect clients (for example, by limiting account access or delaying transactions), even if no client assets are directly lost. • Derivatives and Options Risk. We may use relatively conservative options strategies (such as covered calls and cash-secured puts) for certain clients. In limited circumstances, some accounts may also use other derivative instruments (such as futures or other options) for hedging or risk-management purposes. Derivatives are financial instruments whose value is 19  based on an underlying asset, index, rate, or other reference instrument. Risks associated with derivatives can include: o Imperfect correlation between the derivative and the underlying asset or exposure; o Leverage, which can magnify gains and losses and increase volatility; o Counterparty risk (the risk that the other party to a derivative contract fails to perform); o Liquidity and valuation risk, as some derivatives may be difficult to value or unwind; and o The risk that a derivative strategy does not perform as expected or does not effectively hedge the intended exposure. While we do not use complex or speculative derivatives as a primary investment strategy, even limited derivative use introduces additional risks beyond those associated with investing directly in securities. • ETF and Mutual Fund Risk. When we invest through exchange-traded funds (“ETFs”) or mutual funds, you are exposed to the risks of the underlying securities those funds hold. In addition, you bear your share of each fund’s internal expenses (such as management fees and operating costs), which are in addition to any advisory fees you pay to Wealth Intelligence. A fund may not perfectly track its index or benchmark, and its performance may differ from the performance of the underlying holdings. • Fixed Income and Interest Rate Risk. Fixed income investments (including bond funds and, where used, individual bonds) are subject to interest rate risk (when interest rates rise, bond prices generally fall), credit risk (the risk that an issuer will fail to make payments as promised), inflation risk (purchasing power erosion), and reinvestment risk. Longer-maturity or longer- duration bonds typically experience greater price movements in response to interest rate changes than shorter-duration bonds. • Foreign and Emerging Markets Risk. While we generally focus on U.S. securities, some mutual funds or ETFs we use may invest in foreign or emerging-markets securities. These investments can involve additional risks, including currency risk, political and regulatory risk, less transparent accounting or market practices, and higher volatility. Emerging markets, in particular, can experience significant short-term volatility and may be more prone to abrupt changes in value. 20  • Hedging Strategy Risk. Certain client accounts or strategies may use transactions designed to reduce risk or protect the value of investments (for example, through options or other hedging instruments). Hedging can fail or may only partially offset losses, and in some circumstances, hedging transactions can themselves create additional costs, complexity, or losses. Changes in interest rates, security prices, or currency exchange rates can cause a hedging strategy to underperform or result in a worse outcome than not hedging at all. • Inflation (Purchasing Power) Risk. Over time, inflation reduces the purchasing power of money. Even if the value of your investments increases in nominal terms, the real value (after inflation) may grow more slowly or even decline. Investments that are too conservative may not keep pace with inflation over the long term. • Liquidity Risk. Although rarely used in our strategies, some securities or investments may be difficult to buy or sell quickly, or to sell at a desirable price, particularly during periods of market stress. Even securities that are generally liquid can become illiquid due to market disruptions, trading halts, or a lack of market participants. Liquidity risk may require us to sell other positions at unfavorable times or prices in order to raise cash. • Long-Term and Short-Term Trading Risk. We generally invest with a long-term perspective, but we may also engage in shorter-term trades when we believe it is appropriate. Long-term investing exposes you to various risks (including market, economic, interest rate, and inflation risk) over extended periods. Short-term trading can increase transaction costs and, in taxable accounts, may increase the amount of short-term capital gains, which are typically taxed at higher rates than long-term gains. • Management / Strategy Risk. Our investment strategies and the decisions of our portfolio manager(s) and financial professionals may not achieve their intended objectives. Our views about the direction of markets, the attractiveness of particular themes, or the prospects of specific securities could be wrong. There is no guarantee that any Wealth Intelligence strategy will work under all market conditions, and you should evaluate your ability to remain invested in a strategy during periods of poor performance. 21  • Margin Risk. Although margin is not a core part of our strategies, some clients may choose to use margin in their accounts. Using margin means borrowing money from your custodian or broker to buy securities, which magnifies both gains and losses. If the value of securities in a margin account falls, the broker may issue a margin call requiring you to deposit additional funds or securities. If you cannot meet a margin call, the broker may sell securities in your account at an unfavorable time or price, which can significantly increase losses. • Market Risk. The value of investments may rise or fall due to broad market movements, economic conditions, geopolitical events, changes in interest rates, or other factors. Broad market declines can negatively affect most or all of the securities in your portfolio at the same time. • Model and Tool Risk. We use various web-based risk profiling tools and models to help us analyze portfolios and align risk levels with your risk tolerance and capacity. These tools rely on assumptions, historical data, and models that may not accurately predict future outcomes. Using these tools can help inform our decisions, but they cannot eliminate investment risk or guarantee results. • Regulatory and Legal Risk. Changes in laws, regulations, or regulatory interpretations—whether in the United States or abroad—may limit or restrict certain types of investments or strategies that we use or may increase costs associated with compliance. Regulators may interpret rules differently than we or the industry expect, which can affect our ability to fully implement certain strategies or may require changes in how we manage client accounts. This summary is intended to help you understand the types of risks that may be associated with our methods and strategies. It does not cover every possible risk. You should carefully review this Brochure, your Advisory Services Agreement, and your overall financial situation and objectives, and discuss any questions with us before deciding to engage or continue with our services. Item 9 – Disciplinary Information As an investment adviser, Wealth Intelligence must disclose any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. 22  Neither our firm nor any of our employees has any legal or disciplinary events to disclose under this Item. Item 10 – Other Financial Industry Activities, Affiliates, and Conflicts of Interests Our firm and its financial professionals may have certain other financial industry relationships, as described below. Insurance Activities and Oglesby Strategic Services. Some of our financial professionals are licensed insurance agents and may recommend insurance products such as life, disability, and long-term care insurance. Insurance products and related services are provided through Oglesby Strategic Services (“OSS”), an affiliated insurance firm under common ownership with our firm, and/or through unaffiliated insurance companies. If you choose to purchase insurance through OSS or through one of our financial professionals acting as an insurance agent: • The insurance company and/or OSS will pay commissions or other insurance- related compensation in connection with those products. • This insurance compensation is in addition to any advisory or consulting fees you pay to our firm. This creates a conflict of interest because our firm and our financial professionals have a financial incentive to: • Recommend that you purchase insurance products, • Recommend specific products or coverage levels that generate higher commissions, or • Recommend that you purchase insurance through OSS rather than through another provider or agency. We seek to manage this conflict through our fiduciary obligations and by clearly disclosing these financial incentives so you can consider them when evaluating our recommendations. You are not required to purchase any insurance product through OSS or through any insurance agent affiliated with our firm. You are free to obtain insurance products through any unaffiliated insurance company, agent, or broker of your choosing. Additional information about our insurance-related conflicts is provided in Items 4 and 5 of this Brochure. 23  Item 11 – Code of Ethics Wealth Intelligence has adopted a written Code of Ethics that describes our firm’s commitment to ethical conduct and our fiduciary obligations to clients. As a fiduciary, our firm has a duty of undivided loyalty to clients and an obligation to act with honesty, good faith, and fairness in all advisory activities. Our Code of Ethics, among other things: • Describes our firm’s expectations for ethical behavior and compliance with applicable securities laws; • Reinforces that our firm and our supervised persons must place the interests of clients ahead of their own personal interests; and • Sets out policies and procedures for personal trading, handling of material nonpublic information, and conflicts of interest. Personal Trading and Conflicts From time to time, individuals associated with our firm may buy or sell securities for their own accounts that are the same as, or different from, securities we recommend to clients. They may also have interests or positions in securities, funds, or other investments that are recommended to or held by clients. Our policy is that no person associated with our firm may put their own interests ahead of a client’s interests or make personal investment decisions based on the investment decisions of our clients. Personal trading is subject to oversight and must be conducted in a manner that is consistent with our fiduciary duty and Code of Ethics. To help monitor and manage potential conflicts: • All access persons are required to provide initial and annual holdings reports and quarterly personal securities transaction reports to our Chief Compliance Officer (CCO). • Access persons must obtain pre-approval from the CCO before investing in initial public offerings (IPOs) or certain limited offerings (such as third-party private placements). These requirements are designed to help ensure that personal trading does not disadvantage clients. Compliance with Laws and Prohibition on Material Nonpublic Information Our firm requires all employees and other supervised persons to comply with all applicable federal and state securities laws and regulations that govern investment advisory practices. The Code of Ethics includes our firm’s policy prohibiting the use or communication of material nonpublic information in violation of law. Any person who fails to follow the Code of Ethics, our policies and procedures, or applicable law may be subject to disciplinary action, up to and including termination. 24  Copies of the Code of Ethics We will provide a complete copy of our Code of Ethics to any client or prospective client upon request. Requests may be directed to our Chief Compliance Officer at our principal office address or through the contact information provided in this Brochure. Item 12 – Brokerage Practices Factors Used to Select Custodians / Brokers Wealth Intelligence generally requires clients to custody their accounts with Charles Schwab & Co., Inc. (“Schwab”), through Schwab’s institutional platform. In limited circumstances, and where appropriate, our firm may agree to work with other custodians or broker-dealers on a case-by-case basis. When recommending or selecting a custodian or broker-dealer, our firm considers a range of factors, including: • Our duty to seek “best execution” of client trades (seeking execution on the most favorable terms reasonably available under the circumstances); • The overall quality of trade execution (including price, speed, and likelihood of execution); • The reasonableness of commissions, ticket charges, and other transaction costs; • The custodian’s financial strength, reputation, and stability; • The breadth and quality of the custodian’s services, technology, trading platform, and reporting; and • The availability of support services that help us serve clients (such as account administration, research tools, performance reporting, and access to client account information). Clients will not necessarily pay the lowest possible commission or transaction cost available in the marketplace. Our goal is to seek overall best execution and service, not necessarily the absolute lowest cost on every trade. Our firm does not charge any additional markup, premium, or commission on top of the costs imposed by the custodian or broker. Access to Research and Other Benefits Schwab (and other custodians) make available various platform services, research tools, and technology at little or no direct cost to our firm. These may include, for example: • Electronic trading and order-routing systems; • Research reports, market data, and analytic tools; • Practice management and compliance tools; and • Access to conferences, educational events, or training. These services can benefit both our firm and our clients by improving our ability to manage accounts, access market information, and operate efficiently. However: 25  • Our firm does not have any formal “soft dollar” arrangements; • We do not cause clients to pay higher commissions or markups in order to obtain research or other benefits; and • We do not receive research or other products from brokers in exchange for directing specific securities transactions to them outside of what is available to similarly situated advisers using the same custodial platform. The availability of these services can create an incentive for us to recommend a particular custodian or broker, because our firm benefits from the services and support they provide. We seek to manage this conflict by basing our custodian and broker recommendations primarily on what we believe is in the best interests of our clients overall, considering execution quality, cost, and the quality of services provided. Our firm participates in the Schwab Client Benefits Program, under which Charles Schwab & Co., Inc. (“Schwab”) may reimburse certain third-party vendors for eligible expenses we incur (for example, technology, compliance, research, or marketing services), once the assets that our clients hold in accounts at Schwab reach or maintain certain levels. These reimbursements are paid by Schwab, not by you, but they create a conflict of interest because they give us a financial incentive to recommend that you custody your accounts at Schwab and to keep, or increase, the amount of client assets held there, rather than at another custodian. Brokerage for Client Referrals Our firm does not receive client referrals from any broker-dealer or other third party in exchange for selecting or recommending that broker-dealer or third party to clients. If we ever enter into a referral or solicitation arrangement in the future, we will provide the required disclosures at that time and update this Brochure as needed. Clients Directing Brokerage / Custody In most cases, we will require clients to use Schwab (or another custodian that we approve) for custody and brokerage services in connection with our ongoing investment advisory relationships. Not all advisers require clients to use a particular custodian or broker. If we agree to use a different custodian or broker at a client’s request: • The client may pay higher commissions or transaction costs, • We may have more limited ability to aggregate trades or implement certain strategies across accounts, and • Certain services and tools that we use with our primary custodian may not be available. We will discuss any such directed brokerage or custodian arrangements with you and explain the potential implications. 26  Aggregating (Block) Trading for Multiple Client Accounts When we buy or sell the same security for more than one client at approximately the same time, we may, but are not required to, place those orders as a block trade (also called “bunching”) to seek more favorable prices, lower commissions, or more efficient execution. If we aggregate trades: • The block order is allocated among participating client accounts in a fair and equitable manner, typically on a pro-rata basis, subject to practical considerations (such as minimum trade sizes or specific client restrictions). • All participating accounts receive the average price for the block trade (plus or minus applicable transaction costs), so no account is systematically advantaged or disadvantaged. • We periodically review allocation practices to help ensure that accounts are not systematically disadvantaged by this process. If we do not aggregate orders (for example, due to different custodians, timing needs, or client-specific instructions): • Clients may receive different prices for the same security, • Some clients may pay higher transaction costs, and • Execution may be less efficient than in an aggregated trade. Our firm’s policy is to use aggregation when we reasonably believe it is in the best interests of participating clients and consistent with our duty to seek best execution, recognizing that we are not obligated to aggregate every trade. Item 13 – Review of Accounts Ongoing Monitoring of Managed Accounts Investment advisory accounts managed by Wealth Intelligence are monitored on an ongoing basis by our financial professionals. We review accounts using a combination of: • Day-to-day monitoring of holdings and allocations • Periodic strategy reviews • Client communications (such as phone calls, video calls, and in-person meetings) • Review of monthly and quarterly account statements and reports These reviews are based on the objectives and parameters established with you, which are generally reflected in your Advisory Services Agreement, your Investment Objective, and any related guidelines we agree on together. For held-away accounts, such as employer-sponsored retirement plan accounts where we provide non-discretionary advice and do not place trades, our monitoring is generally limited to periodic reviews and recommendations based on the information available to us from you and/or the plan provider. 27  In addition to ongoing monitoring, we conduct more formal reviews of managed accounts at least periodically (typically at least annually), and more frequently as needed. More frequent reviews may be triggered by events such as: • A change in your investment objectives or risk tolerance • Significant changes in your income, assets, liabilities, or cash-flow needs • Tax considerations (for example, large, realized gains or losses) • Large deposits to or withdrawals from your account • Significant purchases or sales of assets outside your managed account • Loss of confidence in a particular security, fund, or strategy • Material changes in the economy, markets, or regulatory environment Planning, Consulting, and Family Office Engagements For financial planning, business consulting, and family office engagements—where there may be no “managed account” associated with the service—the timing and scope of reviews depend on the nature of the engagement and what we agree with you. In general: • One-time or project-based engagements are typically reviewed and finalized before we deliver the plan or work product. • Ongoing engagements may be reviewed periodically (for example, annually or at another agreed interval) and when there is a significant change in your circumstances, objectives, or the underlying facts (such as a business sale, major investment, or change in family structure). When we update a plan, consulting deliverable, or family office framework, we revisit your goals, assumptions, and recommendations to determine whether any adjustments are needed. We may use planning software and other tools to prepare and update these materials. Reports to Clients For managed investment accounts, you receive standard account statements from your independent qualified custodian at least quarterly. These statements show: • All holdings and transactions in the account • The value of your account • Any advisory fees and other charges deducted from the account The custodian’s statements (and, if applicable, broker-dealer statements) are the official records of your accounts. We may also provide additional portfolio or performance reports from time to time, particularly for clients in ongoing advisory or family office programs. For planning, consulting, and family office engagements, we typically provide a written plan, analysis, or other deliverable as part of the engagement. We do not provide ongoing 28  written reports unless an update or additional services are requested and agreed, in which case we will prepare updated materials as appropriate. Item 14 – Client Referrals and Other Compensation As of the date of this Brochure, Wealth Intelligence does not receive cash compensation or other direct economic benefits from third parties in exchange for providing investment advice or recommending specific investment products, managers, or programs to our clients. Our advisory and consulting fees are paid by clients as described in Items 4 and 5 of this Brochure and in the Advisory Services Agreement. As noted in Item 12, the custodians and service providers we work with may make certain services, tools, and technology available to our firm at little or no direct cost (for example, trading platforms, research tools, and reporting systems). These services can benefit both our firm and our clients, but they are not paid to us in exchange for recommending a particular custodian or investment product and do not involve “soft dollar” arrangements in which clients pay higher commissions so that we can receive research or other benefits. Our firm does not directly or indirectly compensate any person or firm for referring clients or prospective clients to us, and we do not have any solicitor or referral fee arrangements in place. If we enter into any such arrangements in the future, we will provide the required disclosures and update this Brochure as appropriate. Item 15 – Custody Although Wealth Intelligence does not maintain physical custody of client funds or securities, our firm is deemed to have custody of client assets under SEC rules in certain limited situations: • When you authorize us to instruct your custodian to deduct advisory fees directly • • from your account; In certain accounts where you provide us with a Standing Letter of Authorization (“SLOA”) to transfer funds from your account to a third party you designate; and In limited cases where we provide bill pay or expense management services and have authority to direct payments from your account on your behalf. In all cases, an independent qualified custodian (such as your brokerage firm or bank) maintains actual custody of your assets. You will receive account statements directly from the custodian at least quarterly, sent to the email or mailing address you provide to the custodian in your account paperwork (or in any subsequent change-of-address instructions). You should carefully review those statements when you receive them, and we strongly encourage you to compare: • The custodian’s account statements (which are the official records of your accounts), with 29  • Any periodic portfolio reports or summaries that you receive from our firm. Standing Letters of Authorization (SLOAs) For accounts where you grant us SLOA authority, it is our policy to act only in accordance with your instructions. In practice, this means we will only initiate a withdrawal or transfer: • To a third party you have designated, • For a specific amount, and • At the time and in the manner you authorize. Under SEC guidance issued on February 21, 2017, certain SLOA arrangements cause an adviser to be deemed to have custody, but a surprise examination is not required if specific conditions are met. Our firm relies on this guidance for SLOA-related custody and seeks to operate within those conditions so that a surprise custody examination is not required solely because of SLOAs or our authority to deduct advisory fees. Bill Pay and Expense Management In some family office and similar relationships, we may provide bill pay or expense management services, which can include directing your custodian or bank to pay certain bills or expenses from your account. Depending on how these authorities are structured, we have determined that, in limited circumstances, our bill pay activities may cause us to be deemed to have custody of those specific accounts under SEC rules. Because of this, our firm has elected to engage an independent public accountant to perform a surprise custody examination of those accounts where our bill pay or expense management authority results in us having custody. This surprise exam is in addition to, and separate from, the safeguards provided by your independent custodian’s account statements and controls. Item 16 – Investment Discretion As part of our investment management services, Wealth Intelligence typically provides advice on a discretionary basis. This means you give our firm written authority to make day-to-day investment decisions in your account(s) without asking for your approval before each trade. When you grant us discretionary authority (usually through your Advisory Services Agreement and related account-opening documents), you authorize us to do some or all of the following, consistent with your goals, risk tolerance, and any reasonable restrictions you impose: • Determine which securities to buy or sell • Determine the amount of each security to buy or sell • Exchange or convert securities, including money market instruments • Decide the timing of securities transactions 30  • Select the broker or custodian to execute transactions, as described in Item 12 of this Brochure You may place reasonable limitations or restrictions on our discretionary authority (for example, excluding certain securities, industries, or strategies), as long as they are not inconsistent with your stated objectives or applicable law. Any such restrictions should be provided to us in writing, typically through your new account paperwork, investment policy statement, or other written instructions. You may change or amend these limitations at any time by providing updated written instructions. We do not typically agree to such a service, but in some cases, you may request that our firm manage your account on a non-discretionary basis. In these non-discretionary relationships: • We make recommendations regarding which securities to buy or sell and in what amounts; • You decide whether and when to accept or implement those recommendations; and • You are ultimately responsible for the timing and execution of transactions, although we may assist with placing trades if you authorize us to do so. Non-discretionary arrangements are more common for held-away accounts (such as employer-sponsored retirement plans) or limited-scope consulting engagements, as described in Item 4 of this Brochure. Item 17 – Voting Client Securities Wealth Intelligence does not vote proxies or make other voting decisions for client securities, and we do not respond to legal notices or class action claims on behalf of clients. This is true regardless of whether we have discretionary authority over your account. You retain the exclusive right and responsibility to: • Receive and review proxy materials and other issuer communications; • Decide how to vote proxies for securities held in your accounts; and • Respond to any legal notices, class action claims, or similar matters relating to your investments. We will instruct your independent qualified custodian to send all proxy materials, legal notices, and class action information directly to you at the address or email you have provided to the custodian. If our firm receives any such materials in error, we will promptly forward them to you by mail or electronic mail (if you have authorized electronic communication). While we do not vote proxies for you, we may, upon request, be available to discuss general issues relating to a particular proxy or corporate action as part of our advisory relationship. 31  Any such discussions are for informational purposes only; the decision and responsibility for how to vote or respond remain with you. Item 18 – Financial Information Wealth Intelligence has not been the subject of a bankruptcy petition. Our firm has no financial condition that we believe is reasonably likely to impair our ability to meet our contractual commitments to clients. We do not require or solicit prepayment of more than $1,200 per client, six months or more in advance for advisory services. As a result, we are not required to include a balance sheet or other financial statement with this Brochure. If you have any questions about this Firm Brochure or our advisory services, our Chief Compliance Officer, Christopher Payne, is available to assist you. You may contact him at (513) 399-8091. 32