WEALTH MANAGEMENT NEBRASKA LLC

Item 1 – Cover Page Wealth Management Nebraska LLC 125 South 4th Norfolk, NE 68701 Ph: 402-371-1160 www.wealthmanagement.info Date of Brochure: April 2025 This Brochure provides information about the qualifications and business practices of Wealth Management Nebraska LLC. If you have any questions about the contents of this brochure, please contact Nathan A. Raabe at 402-371-1160 or at nathanr@wealthfirm.info . 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 as an investment advisor does not imply a certain level of skill or training. Additional information about Wealth Management Nebraska LLC (hereafter also referred to as Wealth Management) is also available on the Internet at www.adviserinfo.sec.gov.  Item 2 – Material Changes There have been no material changes made to Wealth Management Nebraska LLC's Brochure since the last update to this brochure, which was dated June 2024. Please note that other changes were made to this Brochure, which are not discussed in this summary. Consequently, we encourage you to read the Brochure in its entirety. 2 Wealth Management Disclosure Brochure  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 General Description of Primary Advisory Services ................................................................................ 4 Limits Advice to Certain Types of Investments .................................................................................... 4 Tailor Advisory Services to Individual Needs of Clients ........................................................................ 5 Client Assets Managed by Wealth Management .................................................................................. 5 Item 5 – Fees and Compensation .......................................................................................................... 5 Fiduciary Services ............................................................................................................................ 6 Fiduciary Fees .................................................................................................................................. 6 Backoffice Services .......................................................................................................................... 6 Backoffice Fees ................................................................................................................................ 6 Investment Advisory (Asset Management) Services ............................................................................ 7 Investment Advisory Fees ................................................................................................................. 7 Financial Planning Services and Fees ................................................................................................. 9 Newsletter....................................................................................................................................... 9 Termination ..................................................................................................................................... 9 Item 6 – Performance-Based Fees and Side-By-Side Management ......................................................... 10 Item 7 – Types of Clients ................................................................................................................... 10 Minimum Investment Amounts Required .......................................................................................... 12 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 12 Use of Primary Method of Analysis or Strategy ................................................................................. 13 Risk of Loss ................................................................................................................................... 14 Item 9 – Disciplinary Information ........................................................................................................ 18 Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 19 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ................................ 20 Item 12 – Brokerage Practices ............................................................................................................ 21 Handling of Trade Errors ................................................................................................................ 24 Block Trading Policy ....................................................................................................................... 24 Item 13 – Review of Accounts ............................................................................................................ 24 Account Reviews and Reviewers ...................................................................................................... 24 Statements and Reports ................................................................................................................. 25 Item 14 – Client Referrals and Other Compensation ............................................................................. 25 Client Referrals .............................................................................................................................. 25 Other Compensation ...................................................................................................................... 25 Item 15 – Custody ............................................................................................................................. 21 3 Wealth Management Disclosure Brochure  Item 16 – Investment Discretion ......................................................................................................... 21 Item 17 – Voting Client Securities ....................................................................................................... 27 Item 18 – Financial Information .......................................................................................................... 28 4 Wealth Management Disclosure Brochure  Item 4 – Advisory Business Wealth Management Nebraska LLC (the “firm”, “we”, “us” or “our”) is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) and is a Limited Liability Company formed in the State of Delaware. • Wealth Management Nebraska LLC formally known as Wealth Management LLC has been a registered as an investment advisor with the SEC since February 2006. Wealth Management Nebraska LLC is an indirect wholly owned subsidiary of Integrity Marketing Group, LLC. General Description of Primary Advisory Services The advisory services we provide are qualified retirement plan services (which we refer to as “Fiduciary Services”), backoffice services, investment advisory (asset management) services, and financial planning services. A detailed description of each of our advisory services is provided in Item 5 – Fees and Compensation so that clients and prospective clients can review the description of services and description of fees in a side-by-side manner. Overall, the services we provide utilize no load passively managed mutual funds and ETFs with an emphasis on fee transparency and cost minimization to our clients. Limits Advice to Certain Types of Investments Wealth Management provides investment advice on the following types of investments. No-Load (i.e., no trading fee) and Load-Waived (i.e., trading fee waived) Mutual Fund Shares Exchange-listed securities (i.e., stocks) Securities traded over-the-counter (i.e., stocks) Fixed income securities (i.e., bonds) Closed-End Funds and Exchange Traded Funds (ETFs) Foreign Issues Corporate debt securities (other than commercial paper) Commercial paper Certificates of deposit Variable life insurance Variable annuities United States government securities • • • • • • • Warrants • • • • Municipal securities • • • • Options contracts on securities and commodities 5 Wealth Management Disclosure Brochure  Futures contracts on tangibles and intangibles Interests in partnerships investing in real estate, oil and gas interests • • Wealth Management renders advice on a regular basis regarding mutual funds, exchange-listed securities and securities traded over-the-counter, variable annuities, corporate debt securities (other than commercial paper), certificates of deposit, municipal securities, investment company securities, and United States government securities. All other items listed above represent types of investments on which we do not regularly render advice. From time to time we may be required to evaluate investments of other types acquired by our clients prior to establishing a relationship with us. We do not generally recommend that clients invest in options and futures programs. The primary vehicles we use for investing are no-load mutual funds and ETFs (exchange traded funds). Portfolios generally include funds managed by Dimensional Fund Advisors (DFA), which are passive asset class funds. With respect to partnerships we do not recommend purchase of public programs due to their illiquidity and the fee structures. Occasionally we recommend public real estate investment trusts (REITS) for certain clients who desire to include real estate in their asset allocation strategy. We also evaluate insurance products such as annuities and various types of life insurance products. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients Wealth Management’s services are provided based on the individual needs of each client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client on a one-on-one basis through interviews and questionnaires to determine the client’s investment objectives and suitability information. Client Assets Managed by Wealth Management The amount of clients assets managed by Wealth Management totaled approximately $3,100,744,962 as of December 31, 2023. Approximately $3,074,174,114 of these assets are managed on a discretionary basis and approximately $26,570,848 are managed on a non-discretionary basis. Item 5 – Fees and Compensation In addition to the information provide in Item 4 – Advisory Business , this section provides additional details regarding our firm’s advisory services along with descriptions of each service’s fees and compensation arrangements. 6 Wealth Management Disclosure Brochure  Wealth Management does not receive any income in connection with acting as your investment advisor except for the fees we charge as described below. Wealth Management does not receive commissions, referral fees, finder’s fees or other cash compensation. Fiduciary Services Wealth Management offers Fiduciary Services both to defined contribution retirement plan sponsors (“Sponsors”) and to investment advisers to defined contribution retirement plans (“Plans”). When we work with an investment adviser to a Plan, we refer to that investment adviser as a “Relationship Manager Advisor”. Fiduciary Services typically include: • Providing a sample investment policy statement and assisting in its preparation for a Plan based upon information provided by the Plan’s Sponsor; The Relationship • • Providing model investment portfolios to the Relationship Manager Advisor. Manager Advisor primarily offers six asset allocation models and makes them available to the Plan participants. Wealth Management monitors the asset allocation models and adjusts the holdings and weightings of each model on a discretionary basis in an effort to meet the stated investment objective of the model; Recommending specific mutual funds or investment vehicles to be offered as investment options under the Plan; Preparing reports concerning the performance of the investment options; Providing recommendations regarding changes in the Plan’s investments; Notifying the Sponsor of other relevant information regarding the investment options; and Providing other services as negotiated with the Sponsor or investment adviser to the Plan. • Monitoring of the Plan’s investment options; • • • • Wealth Management consults with each Relationship Manager Advisor about the investment options to be made available under a Plan, including whether the Sponsor wishes investment vehicles to be selected from the universe available through the custodian. Fiduciary Fees For its Fiduciary Services, Wealth Management charges a fee expressed as a percentage of the assets covered by its investment advice and related services (the “Co-Fiduciary Fee”). The Co-Fiduciary Fee will generally be between 0.10% to 0.15% per annum of covered assets with the right to adjust on a plan by plan basis. Backoffice Services We provide backoffice services to other investment advisors. Our backoffice services include trade processing, collection of management fees, record maintenance, report preparation, marketing assistance, and research. 7 Wealth Management Disclosure Brochure  Backoffice Fees For our backoffice services, Wealth Management receives a portion of the fee paid by the clients to their investment advisor. Our fee for backoffice services is charged directly to the investment advisor and is not separately charged to the advisory clients that are serviced by the investment advisors. You (as an individual client of the advisor receiving backoffice services) will not be charged any additional amount for charges made to the registered investment advisor or investment advisor representative receiving backoffice services from Wealth Management. The fee for backoffice services from Wealth Management is negotiable. A fee schedule specific to each Investment Advisor Representative or Registered Investment Advisor is negotiated and agreed upon for backoffice services to be received. The annual fee we receive for backoffice services generally ranges from 0.10% to 1.0%, which is calculated based upon the amount of assets receiving backoffice services. The fee is negotiable based upon factors including the total amount of assets receiving backoffice services, the number of client accounts receiving services, the number of Plan participants in qualified accounts receiving services, and the complexity of services to be provided. Typically, our fees are calculated and billed quarterly, in advance, and are based on the market value of your account (Investment Advisor Representative or Registered Investment Advisor) as reflected in the statements issued by the custodian at that point in time. On an exception basis, our fees may be calculated and billed quarterly, in arrears, and based on the market value of your account at the end of the billing quarter. Our fees are prorated in the event that our services are provided for a partial quarter. On a quarterly basis we will provide you with a report of all investment fees in total and show the portion for our services. Generally, the entire fee will be charged against client accounts. Investment Advisory (Asset Management) Services We provide investment advisory services on your behalf. These services include the following: A. Analyze your financial condition, B. Recommend options to achieve your financial objectives, Implement investment strategies, and C. D. Monitor performance of your investments. We work with you to determine your investment objectives and investor risk profile (investment policy) and design a written investment policy statement. We use investment and portfolio allocation software to evaluate alternative portfolio designs and we assist you in selecting the investment strategies that are consistent with your investment policy. At your request we evaluate your existing investments with respect to your investment policy and their individual performance. We work with you to develop a transition plan in order to move from your existing asset allocation to the desired asset allocation. We monitor the performance of the assets as well as the asset allocation strategy and we hold review meetings with you as requested and produce quarterly performance reports for you. We have developed model no-load mutual fund portfolios, which we use with you if we consider a developed model to be appropriate for your investment policy. 8 Wealth Management Disclosure Brochure  Investment Advisory Fees The following is our Fee Schedule: Account Balance Up to $49,999 $50,000 to $199,999 $200,000 to $499,999 $500,000 to $999,999 $1,000,000 to $1,999,999 $2,000,000 to $2,999,999 $3,000,000 to $3,999,999 $4,000,000 to $4,999,999 $5,000,000 or more Annual Fee 1.75% 1.50% 1.25% 1.00% 0.90% 0.80% 0.70% 0.60% 0.50% This schedule may be modified and fees may be negotiated with each client. The fee schedule that applies to your account(s) will be specified in your Investment Advisory Agreement (IAA). The annual fee is calculated based upon the total value of your account that is receiving investment advisory services. Our fee is calculated and billed quarterly in advance based on the market value of your account on the last day of the preceding calendar quarter as reported on your quarterly statements from the account custodian. At the firm’s option, fees may be billed annually for small accounts. If you open an account mid-quarter, the first partial quarter’s fees are prorated and charged in arrears and will be billed with the first full quarter’s fees, which are charged in advance for the first full calendar quarter that you receive investment advisory services. On a quarterly basis we provide you with an invoice showing all fees charged to your account. Upon termination, fees will be pro-rated to the effective date of termination. If you are billed in advance, you will receive a refund of any fees paid but not yet earned through the effective date of termination unless your pro-rata refund would be less than $50. If the pro- rata refund due upon termination is an amount up to $50, the fee may be retained to cover administrative costs incurred to process our termination of services to your account. The “client” is defined to include all accounts considered in the billing group of accounts, and “the date of termination” is defined as the date of total withdrawal or total transfer from the account(s). If unearned fees total more than $50 per client upon termination, the fees will be refunded in total to the client. Depending on the service required, we will occasionally negotiate fees alternative to those described above, including potentially a fixed fee for services to your account. Fees may vary based on individual or family circumstances. Generally, fees are deducted from client accounts. Individual accounts for members of the same family, which is defined as including a client’s spouse and dependent children, are assessed fees based on the total account balance of all family accounts. Accounts for business entities and accounts related thereto, including those of the business owner are generally assessed fees based on the total account balances of all such related accounts. The fee schedule may be amended from time to time by Wealth Management. We will provide clients with at least forty-five (45) days advance written notice for any amendments to our fee schedule and clients have the option to terminate services before the increased fee schedule takes effect. Generally, we require clients to provide at least thirty (30) days written notice to terminate services. 9 Wealth Management Disclosure Brochure  In addition to advisory fees paid to Wealth Management, clients pay fees to the mutual funds in the form of internal expenses at the fund level, which expenses reduce the net value of the funds. Trade fees may apply to trades placed at Charles Schwab & Company, Inc. ("Schwab"), MG Trust Company (a subsidiary of Matrix Financial Solutions), Fidelity Brokerage Services, LLC, Aegon, or other custodians. Wealth Management receives no portion of these internal expenses or trade fees. Financial Planning Services and Fees We also provide general financial planning to you if requested. Normally this service is provided to clients that are already a client with Wealth Management without any additional fees. For financial planning services that are subject to additional fees, hourly fees will be charged at a rate of up to $250 per hour and the specific rates and estimated time to complete the requested financial planning services will be discussed before such charges are incurred. The specific hourly fees for each client will be disclosed prior to any engagement undertaken for an hourly fee. The purpose of the financial plan is to assist the client in defining personal financial planning goals and objectives to be pursued in the areas of business planning, children’s education, retirement planning, estate planning, tax planning, and investments, and to supply an analysis and recommendations as to the actions and investment strategies necessary to attain these goals and objectives. Financial planning is not an exact science and projections are prepared based upon information provided by you (the client) and assumptions made at the time. We do not attempt to verify the accuracy or completeness of information that is provided to us. The future cannot be forecast with certainty; the degree of uncertainty increases the farther into the future we attempt to forecast. Actual results will vary from projections made, and it is possible that the variation will be significant. Also, financial planning is an ongoing process. Decisions made are based on the best information available at the time and such things as changes in market conditions, tax laws, and your personal goals can all impact the outcome of your financial plan. The client is not obliged to follow recommendations made during the financial planning process, and Wealth Management is not responsible for actual results to match the projections made during the financial planning process. Newsletter Registered investment advisors and investment advisor representatives who have contracted for investment advisory services are provided our quarterly newsletter entitled Wealth Management. Termination Concerning fiduciary services, the client’s authorized representative, Wealth Management, or the Relationship Manager Advisor may terminate the agreement for services with sixty (60) days written notice. A copy of the termination notice must additionally be provided to the Plan Custodian (or Plan 10 Wealth Management Disclosure Brochure  trustee), if any. Failure to pay service fees by the client will also terminate the contract. A refund of any unearned fees will be made based on the time expended by Wealth Management and the Relationship Manager Advisor before termination. A full refund of any fees paid will be made if the agreement is terminated within five (5) business days. For backoffice services, the termination provisions will vary among the Investment Advisor Representatives or Registered Investment Advisors contracting for and receiving backoffice services. For example, we may require a longer advance notice for termination of services depending on the amount of assets receiving services, and the administrative complexity of processing termination of the backoffice services. The termination provisions will be specified in each agreement for backoffice services. You may terminate your Investment Advisory Agreement without penalty within five (5) business days after you sign your Investment Advisory Agreement. In all other situations your Investment Advisory Agreement is continuous unless terminated by either you or Wealth Management. Upon termination, advisor fees will be pro-rated to the effective date of termination. The proration of fees upon termination is further described previously in the Investment Advisory Fees section. Wealth Management has no obligation to provide any additional further recommendations, actions, or services upon termination of any agreement for investment advisory services, backoffice services, or fiduciary services. Item 6 – Performance-Based Fees and Side-By-Side Management Item 6 is not applicable to Wealth Management. Wealth Management does not charge or accept performance-based fees. Performance-based fees are fees based on a share of capital gains on or capital appreciation of the assets held within a client’s account. Further, “Side-by-Side Management” refers to a situation in which the same firm manages accounts that are billed based on a percentage of assets under management and at the same time manages other accounts for which fees are assessed on a performance fee basis. As Wealth Management has no performance-based fee accounts, it has no side- by-side management. Item 7 – Types of Clients Wealth Management generally provides investment advice to the following types of clients: Individuals High-Net Worth Individuals Banks or thrift institutions Pension and profit sharing plans Trusts, estates, or charitable organizations Corporations or business entities other than those listed above State or municipal government entities • • • • • • • 11 Wealth Management Disclosure Brochure  Minimum Investment Amounts Required There are no minimum investment amounts or conditions required for establishing an account managed by Wealth Management. However, all clients are required to execute an agreement for services prior to commencing any work. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Wealth Management uses the following methods of analysis in formulating investment advice: Fundamental. This is a method of evaluating a security by attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of companies). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This method of security analysis is considered to be the opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. Wealth Management’s security analysis is based upon a number of factors including those derived by commercially available software technology, securities rating services, general market and financial information, due diligence reviews and specific investment analysis you request from time to time. Wealth Management uses the following investment strategies when managing client assets and/or providing investment advice: Long term purchases. Investments held at least a year. Margin transactions. When an investor buys a stock on margin, the investor pays for part of the purchase and borrows the rest from a brokerage firm. For example, an investor may buy $5,000 worth of stock in a margin account by paying for $2,500 and borrowing $2,500 from a brokerage firm. Clients cannot borrow stock or cash from Wealth Management. Wealth Management does bill on the higher margin value, therefore there is a conflict of interest that arises due to Wealth Management earning a higher fee. Other. Our investment strategies used to implement our investment advice include the purchase or sale of specific securities. Our advice is based upon long-term investment strategies that incorporate the principles of modern portfolio theory. Our investment approach is firmly rooted in the belief that markets are “efficient”, and that investors’ returns are determined principally by asset allocation decisions, not market timing or stock picking. We develop diversified portfolios principally through the use 12 of Wealth Management Disclosure Brochure  passively managed, asset class mutual funds that are available only to institutional investors and clients of a network of carefully selected investment advisors. We may also recommend the use of long-term investment techniques such as dollar-cost averaging. Use of Primary Method of Analysis or Strategy Wealth Management’s primary method of analysis or strategy is based on the principles of Modern Portfolio Theory (MPT). The tenets of MPT provide for a passive long-term buy-and-hold strategy implemented through globally diversified portfolios. Mutual funds representing asset classes where academic research has demonstrated higher expected returns for the level of risk taken are combined in a single portfolio. Portfolios are constructed in a manner to provide diversification for the purpose of reducing the risk caused by volatility. Portfolios are rebalanced to maintain agreed upon asset allocations. Some of the risks involved with using this method include: market risk, small companies risk, risk of concentrating in the real estate industry, foreign securities and currencies risk, emerging markets risk, banking concentration risk, interest rate risk, risk of investing for inflation protection, risk of municipal securities, and /or fund of funds risk. Investments in foreign issuers are subject to certain considerations that are not associated with investments in US public companies. Investments of the International Equity, Emerging Markets Equity and the Global Fixed Income portfolios will be denominated in foreign currencies. Changes in the relative values of these foreign currencies and the US dollar, therefore, will affect the value of investments in the portfolios. Forward currency contracts will be utilized to attempt to minimize these changes. Foreign issuers are not generally subject to uniform accounting, auditing, and financial reporting standards comparable to those of US public corporations and there may be less publicly available information about such companies than comparable US companies. Also, legal, political, or diplomatic actions of foreign governments, including expropriation, confiscatory taxation, and limitations on the removal of securities, property, or other assets of the portfolios, could adversely affect the value of the assets of these portfolios. Securities of small companies are often less liquid than those of large companies. As a result, small company stock and the funds which invest in them may fluctuate relatively more in price. Although securities of larger firms fluctuate relatively less, economic, political and issuer specific events will cause the value of all securities and the funds which invest in them to fluctuate as well. Additionally, investments in Real Estate Securities Portfolios are concentrated in the real estate industry. This exclusive focus on the real estate industry may cause its risk to approximate the general risks of direct real estate ownership. Its performance may be materially different from the broad US equity market. The net asset value of a fund that invests in fixed income securities will fluctuate when interest rates rise. An investor can lose principal value investing in a fixed income fund during a rising interest rate environment. 13 Wealth Management Disclosure Brochure  Focus on the banking industry would link the performance of certain Fund Portfolios to changes in performance of the banking industry generally. For example, a change in the market’s perception of the riskiness of banks compared to non-banks would cause the Portfolio’s values to fluctuate. Inflation Protected Securities and Portfolios invested in them are expected to be protected from long- term inflationary trends; however, short-term increases in inflation may lead to a decline in the Portfolio’s value. If interest rates rise due to reasons other than inflation, the Portfolio’s investment in these securities may not be protected to the extent that the increase is not reflected in the securities’ inflation measures. The Portfolio may also suffer a loss during periods of sustained deflation. Risk of Loss All investing and trading activities risk the loss of capital. Although we will attempt to moderate these risks, no assurance can be given that the investment activities of an account we advise will achieve the investment objectives of such account or avoid losses. Direct and indirect investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. It is important that you understand the risks associated with investing in the types of investments and strategies listedabove. Except as may otherwise be provided by law, we are not liable to clients for: • • Any loss that you may suffer by reason of any investment decision made or other action taken or omitted by us in good faith; Any loss arising from our adherence to your instructions or the disregard of our recommendations made to you; or Any act or failure to act by a custodian or other third party to your account. • The information included in this Brochure does not include every potential risk associated with an investment strategy, technique or type of security applicable to a particular client account. You are encouraged to ask questions regarding risks applicable to a particular strategy or investment product and read all product-specific risk disclosures. It is your responsibility to give us complete information and to notify us of any changes in financial circumstances or goals. 14 Wealth Management Disclosure Brochure  There are certain additional risks associated when investing in securities; including, but not limited to: • Market Risk: Either the stock market as a whole, or the value of an individual company or fund, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. • Legal and Regulatory Risks: The regulation of the U.S. and non-U.S. securities and futures markets investment funds has undergone substantial change in recent years and such change may continue. In particular, in light of the recent market turmoil there have been numerous proposals, including bills that have been introduced in the U.S. Congress, for substantial revisions to the regulation of financial institutions generally. Some of the additional regulation includes requirements that private fund managers register as investment advisers under the Advisers Act and disclose various information to regulators about the positions, counterparties and other exposures of the private funds managed by such managers. Further, the practice of short selling has been the subject of numerous temporary restrictions, and similar restrictions may be promulgated at any time. Such restrictions may adversely affect the returns of Underlying Investment Funds that utilize short selling. The effect of such regulatory change on the accounts and/or the underlying investment funds, while impossible to predict, could be substantial and adverse. • Inflation Risk: When inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. The firm’s portfolios face inflation risk, which results from the variation in the value of cash flows from a financial instrument due to inflation, as measured in terms of purchasing power. • Market or Interest Rate Risk: The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the prices of fixed income securities fall. If the firm holds a fixed income security to maturity, the change in its price before maturity may have little impact on the firm portfolios’ performance. However, if the firm determines to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss. • Market Volatility: The profitability of the portfolios substantially depends upon the firm correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The firm cannot guarantee that it will be successful in accurately predicting price and interest rate movements. • Material Non-Public Information: By reason of their responsibilities in connection with other activities of the firm and/or its principals or employees, certain principals or employees of the firm and/or its affiliates may acquire confidential or material non- public information or be restricted from initiating transactions in certain securities. The firm will not be free to act upon any such information. Due to these restrictions, the firm may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. 15 Wealth Management Disclosure Brochure  • Accuracy of Public Information: The firm selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the firm by the issuers or through sources other than the issuers. Although the firm evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the firm is not in a position to confirm the completeness, genuineness, or accuracy of such information and data. In some cases, complete and accurate information is not available. • Trading Limitations: For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the account to loss. Also, such a suspension could render it impossible for the firm to liquidate positions and thereby expose the Client account to potential losses. • Recommendation of Particular Types of Securities: In some cases, the firm recommends mutual funds. There are several risks involved with these funds. These funds have portfolio managers that trade the fund’s investments in agreement with the fund’s objective and in line with the fund prospectus. While these investments generally provide diversification there are some risks involved especially if the fund is concentrated in a particular sector of the market, uses leverage, or concentrates in a certain type of security (i.e. foreign equities). The returns on mutual funds can be reduced by the costs to manage the funds. And the shares rise and fall in value according to the supply and demand. Open end funds may have a diluted effect on other investors’ interest due to the structure of the fund while closed end funds have limited shares which rise and fall in value according to supply and demand in the market. In addition, closed end funds are priced daily and as a result they may trade differently than the daily net asset value(NAV). • Firm’s Investment Activities: The firm’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the firm. Such factors include a wide range of economic, political, competitive and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The markets may be volatile, which may adversely affect the ability of the firm to realize profits on behalf of its Clients. As a result of the nature of the firm’s investing activities, it is possible that the firm’s results may fluctuate substantially from period to period. • Equity (stock) market risk: Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. • Company Risk: When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate 16 Wealth Management Disclosure Brochure  diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Risks Associated with Fixed Income: When investing in fixed income instruments such as bonds or notes, the issuer may default on the bond and be unable to make payments. Further, interest rates may increase and the principal value of your investment may decrease. Individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. • ETF and Mutual Fund Risk: When investing in an Exchange-Traded Fund (ETF) or mutual fund, a client will bear additional expenses based on the client’s pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients will also incur brokerage costs when purchasing or selling ETFs. • Options Risk: Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. • Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited market in which they trade. Thus, you may experience the risk that your investment or assets within your investment may not be able to be liquidated quickly, thus, extending the period of time by which you may receive the proceeds from your investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e. not being able to quickly get out of an investment before the price drops significantly) a particular investment and therefore, can have a negative impact on investment returns. • Management Risk: Your investments will vary with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If you implement our financial planning recommendations and our investment strategies do not produce the expected results, you may not achieve yourobjectives. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to bonds. • Call Risk: Bonds that are callable carry an additional risk because they may be called prior to maturity depending on current interest rates thereby increasing the likelihood that reinvestment risk may be realized. • Credit Risk: The price of a bond depends on the issuer’s credit rating, or perceived ability to pay its debt obligations. Consequently, increases in an issuer’s credit risk, may negatively impact the value of a bondinvestment. 17 Wealth Management Disclosure Brochure  • Speculation Risk: The securities markets are populated by traders whose primary interest is in making short-term profits by speculating whether the price of a security will go up or go down. The speculative actions of these traders may increase market volatility that could drive down the prices of securities. • Geopolitical Risk: The risk an investment's returns could suffer as a result of political changes or instability in a country. Instability affecting investment returns could stem from a change in government, legislative bodies, other foreign policy makers or military control. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Foreign Market Risk: The securities markets of many foreign countries, including emerging countries, have substantially less trading volume than the securities markets of the United States, and securities of some foreign companies are less liquid and more volatile than securities of comparable United States companies. As a result, foreign securities markets may be subject to greater influence by adverse events generally affecting the market, by large investors’ trading significant blocks of securities, or by large dispositions of securities, than as it is in the United States. The limited liquidity of some foreign markets may affect our ability to acquire or dispose of securities at a price and time it believes is advisable. Further, many foreign governments are less stable than that of the United States. There can be no assurance that any significant, sustained instability would not increase the risks of investing in the securities markets of certain countries. • Counterparty and Broker Credit Risk: Certain assets will be exposed to the credit risk of the counterparties when engaging in exchange-traded or off-exchange transactions. There may be a risk of loss of assets on deposit with or in the custody of a broker in the event of the broker’s bankruptcy, the bankruptcy of any clearing broker through which the broker executes and clears transactions, or the bankruptcy of an exchange clearinghouse. • Leverage Risk: Wealth Management does employ leverage in the implementation of its investment strategies. In addition, some ETFs and CEFs also employ leverage. Leverage increases returns to investors if the investment strategy earns a greater return on leveraged investments than the strategy’s cost of such leverage. Although it is not Wealth Management’s strategy to incur margin, Wealth Management will do so when directed by a client; however, the use of leverage exposes investors to additional levels of risk and loss that could be substantial. Item 9 – Disciplinary Information Wealth Management is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of our firm or the integrity of our management. An administrative proceeding by Florida’s state regulatory agency, the Florida Office of Financial Regulations (FOFR), was initiated in January 2018 and resolved on February 13, 2019. During a routine examination, the FOFR found that the firm and Jay Malik failed to timely amend Mr. Malik’s Investment Adviser Representative Application for material changes including Mr. Malik’s failure to complete state 18 Wealth Management Disclosure Brochure  registration, state notice filings and associated fees with the state of Florida while providing investment advisory services in the state of Florida and exceeding Florida’s de minimis requirements for Investment Adviser Representative registration. The action taken resulted in a Consent Order to Cease and Desist from providing investment advisory services in the state of Florida until registration was approved, state notice filings were completed and a Civil and Administrative Penalty of $8,750, of which $5,500 was negotiated as the final amount owed, has been paid (Case #98079). There have been no self-regulatory organization (SRO) proceedings against us or any civil or criminal actions against us in a court of jurisdiction. Item 10 – Other Financial Industry Activities and Affiliations Wealth Management is not and does not have a related company that is a (1) broker/dealer, municipal securities dealer, government securities dealer or broker, (2) investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund), (3) futures commission merchant, commodity pool operator, or commodity trading advisor, (4) banking or thrift institution, (5) insurance company, (6) real estate broker or dealer, or (7) sponsor or syndicator of limited partnerships. Wealth Management is affiliated with McMill CPA & Advisors. McMill CPA & Advisors offers a full range of services including: Tax Planning and Preparation, Financial Statements, Computer/ Accounting/Bookkeeping Services, Payroll Services, Accounting Systems, Computer Programs & Advice, Benefit Plans, Business Valuations, Business Consulting & Controllership, Estate and Retirement Planning, Personal Financial Planning, Like-Kind Exchanges, Health & Life, Long Term Care, Disability, and Medicare Supplement insurance, Fixed Annuities and Elder Care. McMill CPA PC is also an insurance agency licensed in Nebraska. Larry E. Hilkemann, Michael Carlson, Nathan Raabe, and Jared Faltys are licensed Insurance Producers in the State of Nebraska. Certain investment adviser representatives of the firm may conduct advisory business through a personal legal entity (such as an LLC or S-Corporation) for branding, tax, or administrative purposes. In such cases, the firm may direct the payment of advisory fees to the investment adviser representative's approved personal entity. These entities are wholly owned and controlled by the investment adviser representative and used solely as a compensation conduit; they do not themselves provide investment advisory services, custody client assets, or hold themselves out to the public as independent advisory firms. The use of such entities does not change the advisory relationship between the client and the firm. All investment adviser representatives, regardless of any personal entity used for compensation, remain individually registered and subject to the firm’s compliance policies, supervision, and regulatory oversight. Wealth Management is affiliated with Retirement Plan Consultants LLC. Retirement Plan Consultants LLC is owned Integrity Marketing Group, LLC. Retirement Plan Consultants LLC acts as a Third Party Administrator (TPA) and recordkeeper and offers Independent Fiduciary services. Investment advisory services and the aforementioned fiduciary services are provided through McMill CPA and Advisors and Wealth Management. 19 Wealth Management Disclosure Brochure  Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading We recognize the fiduciary responsibility that we owe clients, including the avoidance of activities, interests, and relationships that run contrary, or appear to run contrary, to your best interests. We also believe that our firm’s good name and reputation is a direct reflection on the conduct of each employee. Accordingly, Wealth Management has adopted a Code of Ethics (“Code”) for all supervised persons of the firm. All supervised persons must acknowledge and accept the terms of the Code of Ethics annually, or as amended. Wealth Management or individuals associated with Wealth Management may buy or sell securities identical to those recommended to clients for their personal accounts. We only recommend mutual funds and ETFs for our clients and not individual stocks or bonds. We may purchase or hold individual stocks or bonds upon a client’s request, but we do not make recommendations about individual stocks and bonds for purchases in client’s accounts. Wealth Management may also make recommendations or take action with respect to investments for its clients, which may differ in nature or timing from recommendations made to or actions taken for other clients or its employees. As these situations represent a conflict of interest, Wealth Management has established the following restrictions in order to ensure its fiduciary responsibilities: 1) A director, officer, employee, or investment advisor representative of Wealth Management shall not buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No person of Wealth Management shall prefer his or her own interest to that of the advisory client, and client transactions always take precedence. Disclosure of transactions and/or the nature of transactions are required to be reported on a quarterly basis to determine and confirm that conflicts of interest in trading do not exist. 2) Wealth Management emphasizes the unrestricted right of the client to decline to implement any advice rendered. 3) Wealth Management requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices. 20 Wealth Management Disclosure Brochure  The Code sets forth policies and procedures to monitor and review to monitor and review the personal trading activities of our supervised persons. From time to time our supervised persons or associated persons may invest in the same securities recommended to clients. Under the Code, we have adopted procedures designed to prevent the conflicts of interest that this could potentially cause. The Code’s personal trading policies include procedures for limiting the personal securities transactions of supervised persons and associated persons, requiring the reporting and review of such trading, and requiring the pre- clearance of certain types of personal trading activities for employees, associated persons and members of their household. For example, if an employee or associated person wishes to participate in an initial public offering or invest in a private placement, he or she must submit a pre-clearance request and obtain Wealth Management’s approval. Further, Wealth Management’s policy requires that client transactions generally be completed first unless the associated person’s trade is bundled or aggregated with clients if associated persons trade the same security on the same day alongside our clients. In that situation, if the trade is not filled in its entirety, the associated person’s shares will be removed from the block and the balance of shares will be allocated among client accounts in accordance with our written policy. These policies are designed to discourage and prohibit personal trading that would disadvantage clients. The Code also provides for disciplinary action as appropriate for violations to this policy. Wealth Management also reserves the right to disapprove any proposed transaction that may have the appearance of improper conduct. Wealth Management will provide you with a full copy of our Code of Ethics upon request. We will comply with all applicable federal and state regulations governing registered investment advisory practices. We have established standards of conduct for all associated persons to protect our clients and ensure our fiduciary responsibilities. Item 12 – Brokerage Practices We maintain relationships (for custodial and brokerage services), compensatory or otherwise, with Schwab, MG Trust Company (a subsidiary of Matrix Financial Solutions), Nationwide Life Insurance Company, Fidelity Brokerage Services, LLC, and Aegon. Wealth Management may recommend Schwab. The recommendation of Schwab is based on past experiences, minimizing transactional fees and other costs as well as offerings or services the custodian provides that Wealth Management or the client may require or find valuable such as online access. Schwab will permit you to purchase no-load mutual funds through the account as well as individual securities. This arrangement allows all of your investments to be maintained in one place. 21 Wealth Management Disclosure Brochure  Clients may pay higher trade fees at one custodian over another based upon the variance in offerings and services available among different custodians. Fee structures of various custodians are periodically reviewed by Wealth Management to ensure clients are receiving best execution. Accordingly, while Wealth Management will consider competitive rates, we may not necessarily obtain the lowest possible trade fees for client account transactions. Therefore, the overall services provided by the custodian are evaluated to determine the best execution. For Wealth Management's clients' accounts maintained in its custody, Schwab generally does not charge separately for custody but is compensated by account holders through transaction- related fees for securities trades that are executed through Schwab or that settle into Schwab accounts. While Wealth Management does recommend the use of Schwab, clients are free to select any custodian with which Wealth Management has a relationship. When a client directs the use of a particular custodian, Wealth Management may not be able to obtain the best prices and execution for the transaction. Clients who direct the use of a particular custodian may receive less favorable prices than would otherwise be the case if clients had not designated a particular custodian. While there will not be a direct linkage between the investment advice provided by Wealth Management and Schwab, economic benefits may be received that would not be received if Wealth Management did not use these services to implement the investment advice provided. These benefits may include, but not necessarily be limited to: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk; the ability to have investment advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; receipt of compliance publications; and access to mutual funds that generally require significantly higher minimum initial investments or are generally only available to institutional investors. Schwab also makes available to Wealth Management other products and services that benefit Wealth Management but may not benefit its clients’ accounts including but not limited to software, research, and other market data. Wealth Management is independently owned and operated and is not affiliated with Schwab. Schwab provides Wealth Management with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. Schwab’s services include custody, research 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. Wealth Management receives free software from various sources, including Dimensional Fund Advisors (DFA), which we utilize as part of our considerations in forming asset allocation strategies. 22 Wealth Management Disclosure Brochure  Handling of Trade Errors. Wealth Management has implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with its fiduciary duty, it is the policy of Wealth Management to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes the trade error, the client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client will be made whole and any loss resulting from the trade error will be absorbed by Wealth Management if the error was caused by the firm. If the error is caused by the broker-dealer, the broker-dealer will be responsible for covering all trade error costs. If an investment gain results from the correcting trade, the gain will be donated by Wealth Management to a charitable organization selected by Wealth Management’s owners. Wealth Management will never benefit or profit from trade errors. Block Trading Policy Transactions implemented by Wealth Management for client accounts are generally effected independently. Wealth Management utilizes trading methodology through its custodians that result in either low or no trading costs to individual clients. One such methodology is dollar-cost averaging which provides trades at no cost to the client. 23 Wealth Management Disclosure Brochure  Item 13 – Review of Accounts Account Reviews and Reviewers In accordance with your investment policy statement, we review your portfolio quarterly and annually, but we will conduct a special review of your account either upon request, or if Wealth Management deem it necessary or advisable or should unusual market occurrences prevail. The review is made by the investment advisor representative assigned to service your account or another investment advisor representative designated to do so. The number of accounts reviewed by each investment advisor representative will vary. Reviews are conducted for the purpose of evaluating, reporting and implementing the investment objective of each client. The assets may be reallocated to keep the portfolio allocation consistent with the client’s investment objective. Market conditions and certain economic and/or financial conditions may necessitate a more frequent review. Most accounts are managed on a discretionary basis; however, (as further described in Item 16), there are some accounts that are managed on a non-discretionary basis and require client approval for eachtransaction. To better serve you in attaining your investment goals, we remind you that it is very important to advise us of any changes in your investment objectives or your financial situation. Based upon this information, we can better determine if your portfolio requires modification. Statements and Reports You will receive quarterly reports from Wealth Management, which summarize your asset management account performance. You will also receive monthly statements from your account custodian who outlines your current positions, cost basis of securities and current market values. You should carefully compare reports received from Wealth Management against the statements received from the account custodian and should immediately report any discrepancies to Wealth Management and/or the custodian. 24 Wealth Management Disclosure Brochure  Item 14 – Client Referrals and Other Compensation Client Referrals We receive referrals from attorneys, accountants, and other professionals. We do not pay a referral fee for these referrals. Wealth Management c u r r e n t l y ha s no r e f e r r a l f e e a r r a n g e m e n t s w i t h independent solicitors for the referral of other investment advisors or their clients. I f w e , i n t h e f u t u r e , e l e c t t o e s t a b l i s h s u c h a rr a n g e m e n t s , it w i l l be c o n d u c t e d in accordance with Rule 206(4)-1 of the Investment Advisors Act of 1940. Such referral fee represents a share of Wealth Management’s asset- based investment advisory fee. This arrangement will not result in higher costs to the client. For any such arrangement, Wealth Management maintains a Solicitor Agreement in compliance with Rule 206(4)- 1 of the Investment Advisors Act of 1940 and applicable state and federal laws. All clients referred by Solicitors to Wealth Management will be given a full written disclosure regarding the Solicitor arrangement. Other Compensation The only compensation received from advisory services is the fees charged for providing investment advisory services as described in Item 5 of this brochure. Wealth Management receives no other form of compensation in connection with providing investment advice. As disclosed under Item 12 above, Wealth Management may recommend Schwab for custody and brokerage services. While there will not be a direct linkage between the investment advice provided by Wealth Management and Schwab, economic benefits may be received that would not be received if Wealth Management did not use these services to implement the investment advice provided. These benefits may include, but not necessarily be limited to: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk; the ability to have investment advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; receipt of compliance publications; and access to mutual funds that generally require significantly higher minimum initial investments or are generally only available to institutional investors. Schwab also makes available to Wealth Management other products and services that benefit Wealth Management but may not benefit its clients’ accounts including but not limited to software, research, and other market data. We receive free software from various sources, including Dimensional Fund Advisors, which we utilize as part of our considerations in forming asset allocation strategies. The only form of other compensation received from advisory services is the fees charged for providing investment advisory services as described in Item 5 of this brochure. We receive no other forms of compensation in connection with providing investment advice. 25 Wealth Management Disclosure Brochure  Item 15 – Custody Custody, as it applies to investment advisors, has been defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody and must ensure proper procedures are implemented. Wealth Management is deemed to have custody of client funds and securities whenever we are given the authority to have fees deducted directly from client accounts and because some clients accounts have standing letters of instruction or other similar asset transfer authorization agreements. However, these are the only forms of custody Wealth Management will ever maintain. Wealth Management maintains procedures to ensure these standing letter of authorizations are signed by the client and give us the authority to transfer funds to a third party as directed by the client. For accounts in which Wealth Management is deemed to have custody, the firm has established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and, therefore, are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client or the client’s independent representative at least quarterly. Clients should carefully review those statements and are urged to compare the statements against reports received from Wealth Management. When clients have questions about their account statements, they should contact Wealth Management or the qualified custodian preparing the statement. 26 Wealth Management Disclosure Brochure  Item 16 – Investment Discretion Through its investment advisory (asset management) services and upon receiving written authorization from a client, Wealth Management will maintain trading authorization over client accounts. Upon receiving written authorization from the client, Wealth Management may implement trades on a discretionary basis. When discretionary authority is granted, Wealth Management will have the authority to determine the type of securities and the amount of securities that can be bought or sold for the client’s portfolio without obtaining the client’s consent for each transaction. We will maintain the asset allocation selected with you and provided in your Investment Policy Statement to the best of our ability with expected variances in market fluctuation. Most clients who have contracted for our asset management advisory services are required to grant us discretionary trading authority. We do not provide asset management services on a non-discretionary basis except for a few backoffice Registered Investment Advisors who obtain client consent before giving Wealth Management the trades to be made. Wealth Management prepares the proper reports to aide the Registered Investment Advisor and his/her client in making a decision on the trades to be processed. All clients have the ability to place reasonable restrictions on the types of investments that may be purchased in an account. Clients may also place reasonable limitations on the discretionary power granted to our firm so long as the limitations are specifically set forth or included as an attachment to the client agreement. Item 17 – Voting Client Securities Wealth Management will not vote proxies on behalf of your account. While there are some investment advisors that will vote proxies, we have determined that taking on the responsibility for voting client securities does not add enough value to the services provided to clients to justify the additional compliance and regulatory costs associated with voting client securities. Therefore, it is your responsibility to vote all proxies for securities held in accounts managed by our firm. 27 Wealth Management Disclosure Brochure  Clients will receive proxies directly from their custodian or transfer agent and such documents will not be delivered by our firm. Although we do not vote client proxies, if you have a question about a particular proxy, feel free to contact us. Item 18 – Financial Information This item is not applicable to this brochure. Wealth Management does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, Wealth Management has not been the subject of a bankruptcy petition at any time. 28 Wealth Management Disclosure Brochure