WEALTH NAVIGATION, LLC

Wealth Navigation, LLC (dba Oak Lane Advisors) 1222 W. Legacy Crossing Blvd, Suite 6 Centerville, UT 84014 801-335-8200 th Branch Office: 3350 S. 15 E. Idaho Falls, ID 83404 www.oaklanewealth.com Part 2A Firm Brochure www.edgefinancialadvisors.com August 2025 This brochure provides information about the qualifications and business practices of Wealth Navigation, LLC. If you have any questions about the contents of this brochure, please contact us at 801-335-8200 and / or info@oaklanewealth.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 Navigation, LLC is also available at the SEC’s website www.adviserinfo.sec.gov (click on the link, select “investment adviser firm” and type in our firm CRD# 140612). Results will provide you with Parts 1, 2, and 3 of our Form ADV. Registration with the SEC does not imply a certain level of skill or training. 1  Item 2 – Material Changes Wealth Navigation, LLC (dba Oak Lane Advisors) sets forth the following updates since our last filing dated April 29, 2025. The ADV Part 1A has been updated to include certain disclosures concerning advisory affiliated persons, fees for a third party investment manager; and custody. The ADV Part 2A has been updated regarding custody for third party standing letters of authorization; private funds; and fee debiting. Additionally, certain conflict of interest disclosures have been added for specific private fund offerings for which several of our WN clients are invested. See Item 10. 2  Item 3 – Table of Contents Item 2 – Material Changes .......................................................................................................................................... 2 Item 3 – Table of Contents .......................................................................................................................................... 3 Item 4 – Advisory Business ........................................................................................................................................ 4 Item 5 – Fees and Compensation ............................................................................................................................. 6 Item 6 – Performance-Based Fees and Side-By-Side Management .............................................................. 9 Item 7 – Types of Clients ............................................................................................................................................. 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Analysis .................................... 9 Item 9 – Disciplinary Information ......................................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ................................................................... 11 Item 11 – Code of Ethics ............................................................................................................................................ 12 Item 12 – Brokerage Practices ............................................................................................................................... 13 Item 13 – Review of Accounts ................................................................................................................................. 14 Item 14 – Client Referrals and Other Compensation ...................................................................................... 15 Item 15 – Custody ........................................................................................................................................................ 16 Item 16 – Investment Discretion ........................................................................................................................... 17 Item 17 – Voting Client Securities (i.e., Proxy Voting) .................................................................................... 17 Item 18 – Financial Information ............................................................................................................................ 19 3  Item 4 – Advisory Business Wealth Navigation, LLC (“WN”) has been in operation since 2007 and is wholly owned by WN Holdings, LLC. WN Holdings, LLC is owned by Axis Family Holdings, LLC. 1 for discretionary accounts. The Wealth Navigation, LLC also does business under the name Oak Lane Advisors or Oak Lane Wealth (“Oak Lane”). Certain Investment Advisor Representatives of WN have their own legal business entities and business names as part of an RIA co-brand; however, investment advisory services of these representatives are provided through WN. WN provides both asset management services and fee-based planning services. The asset management services we provide are investment recommendations made for these accounts include the following steps: Comprehensive Evaluation of Investment Objectives 1) WN will meet with each client for an initial review to determine investment objectives, risk tolerance and other relevant information at the beginning of the advisory relationship. The client is provided with an Investment Advisory Agreement (IAA) which includes the fee structure, privacy policy, Form ADV Parts 2A and B, and Form CRS. Under this authority, WN has authority to purchase and sell securities for the client’s account, arrange for delivery and payment in connection with security transactions, and act on behalf of a client in all matters necessary or incidental to the purchase and sale of securities in the client’s account. Unless specifically directed otherwise in writing by a client, WN is authorized to receive and vote proxies on issues held in each account and receive annual reports. Appropriate Asset Allocation Recommendation 2) WN will recommend an asset allocation according to the client’s risk tolerance, investment objectives and various other factors as explained below in the Asset Management Services section. WN will use its best judgment and good faith efforts in rendering this service to its clients. WN cannot warrant or guarantee any particular level of account performance, or that account will be profitable over time. Not every investment decision or recommendation made by WN will be profitable. Client assumes all market risk involved in the investment of the account assets under the terms of the IAA. Except as otherwise be provided by law, WN will not be liable to the Client for: (a) (b) (c) Loss that Client suffers by reason of any investment decision made or other action taken or omitted in good faith by WN with that degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use Loss arising from WN’s adherence to Client’s instructions Any act or failure to act by a custodian of Client’s account, except as required by law. 1 4 See Item 10 for a list of those arrangements and business entities.  Federal and state securities laws impose liabilities under certain circumstances on persons who act in good faith and therefore, nothing herein shall in any way constitute a waiver or limitation of any rights which Client have under any federal and/or state securities laws. As of December 31, 2024, the total discretionary assets under management were $367,281,893 and non-discretionary assets were $0. Services Offered Asset Management Services WN offers various Asset Management services as part of its investment management program. Asset Management service begins with meetings between Advisor and Client to review long- term goals and objectives. These meetings include discussions on Client’s current financial situation, goals for investment assets, risk tolerance, time horizon, liquidity needs and so forth. WN will use information provided by the client to identify an appropriate strategy. WN will then create a portfolio using a mix of investments that can include investments such as stocks, bonds, mutual funds (stock funds, bond funds and other asset classes), exchange-traded funds (“ETFs”), alternative investments, and other securities. WN will also consider client requested investment considerations (e.g., not buy certain positions based on a client’s preference). Once the portfolio is created, WN will monitor the portfolio and adjust the portfolio as necessary. Reallocating and rebalancing in the portfolio may be required by changes in market conditions or as deemed necessary to meet the client’s needs and objectives. WN retains the right to use discretion in the purchase and sale of investment items such as but not limited to stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), alternative investments, variable annuity sub-accounts and other securities as part of its Asset Management Services. In addition to standard brokerage confirmations and statements sent by the custodian, clients can be provided with reports or portfolio evaluations as well as information detailing the performance of the investments held in the portfolio. Comprehensive Financial Planning Wealth Navigation provides comprehensive financial and wealth planning services for its Clients. Planning fees are charged according to various factors such as the income and net worth of the client and the complexity of the client assets. The fee depends on whether the fee is for a new contract, a renewal of an existing contract, or for an ongoing service contract. All planning fees are based on the specific planning services provided to the client and the complexity of the client’s financial situation and goals. The General Areas of Comprehensive Financial Planning include: • • • • • • Financial Planning Services Estate Planning Executive Consulting Services Income and Estate Tax Planning Retirement Planning Pension Consulting Services 5  • • • • • Real Estate Consulting Family Office Services Divorce Financial Planning Investment Analysis Insurance Analysis The services included in the planning process are limited to recommending planning strategies for the client to consider. Should the Client choose to implement the recommendations contained in the Client’s plan or consultation, the implementation of those recommended strategies is entirely at Client’s discretion. In all legal matters, WN’s planning services are analytical and advisory only, and do not include any legal, accounting or other professional services. Clients are encouraged to review their plans on a regular basis, based on individual circumstances. The fee also includes the time and activities necessary to work with Clients’ attorney and/or accountant in reaching agreements on solutions, as well as assisting those advisers in implementation of all appropriate documents. WN is not responsible for attorney or accountant fees charged to Client as a result of the above activities. Separately Managed Accounts with Third Party Money Manager WN may recommend the use of a separate money manager, or a “managed account”. Managed accounts can be used to provide access to outside money managers and asset allocations tailored to the Client’s specific needs. The client enters into a separate and individualized contract with the outside money manager which is monitored by WN. Fees for the managed account are asset-based and include brokerage, custody and money manager services. Separately Managed Accounts will only be offered to clients if the Advisor determines it is appropriate based upon each client’s suitability standards and investment philosophy. The minimum and maintenance level of investment is determined by the outside money manager. Item 5 – Fees and Compensation Annual advisory fees are charged to a client and are to be paid quarterly in arrears based on the average daily balance of the preceding calendar quarter of the client’s account. Fees paid shall be in accordance with the fee schedule agreed upon by WN and client as illustrated in the Investment Advisory Agreement executed by the Client. Except to the extent client directs otherwise in writing, client authorizes and directs the custodian to deduct normal and customary transaction charges and all fees payable under the terms of the Investment Advisory Agreement from client’s account as billed by WN. Payment of fees may result in the liquidation of client’s securities if there is insufficient cash in the Account. Client may be required to pay, in addition to the Advisor fee, a proportionate share of any mutual fund’s fees and charges. WN may modify the terms of the Investment Advisor Agreement fee schedules prospectively with a newly signed agreement or amendment signed by both parties. Prior to deducting fees from the client’s account, WN will send to the custodian simultaneously, a bill showing the fee amount. By signing the Investment Advisory Agreement, the Client has directed the Custodian to pay the advisory fee as instructed by WN or any other third-party 6 manager on a scheduled basis without any additional prior notice to Client. Custodians provide  quarterly account statements to each client, which show all amounts disbursed from the account including the amount of the advisory fee and the custodial fee. Fees will only be deducted where authorized by the client. Service may be terminated for any reason by any party effective upon receipt of written notice of termination by the other parties to this Agreement. Any termination fees charged by the custodian are the responsibility of the client. At Client’s request, handbill or documentation as otherwise required by law, may be generated by WN and delivered directly to Client via email or regular mail. Client is then responsible for direct payment to WN. Advisory fees payable to us do not include all the fees the client will pay when we purchase or sell securities for your Account(s). The following list of fees or expenses are what you pay directly to third parties, whether a security is being purchased, sold or held in your Account(s) under our management. Fees charged are charged by the custodian. We do not receive, directly or indirectly, any of these fees charged to you. They are paid to your custodian, mutual fund company or other party(parties). The fees include: • • • • • • • • • • • • • • Brokerage commissions Transaction fees Exchange fees SEC fees Advisory and administrative fees charged by Mutual Funds, Exchange Traded Funds 3rd party investment manager advisory fees (if any are used for your account) Custodial Fees Deferred sales charges (on MF or annuities) Odd-Lot differentials Deferred sales charges (charged by MFs) Transfer taxes Wire transfer and electronic fund processing fees Commissions or mark-ups / mark-downs on security transactions Certain fees for private fund offerings , Advisory Fees While fees may be negotiable in certain situations, WN typically uses the following fee schedule. Standard Asset Management Fee Schedule As noted above, annual fees are charged to a client and are to be paid quarterly in arrears based on the average daily balance of the preceding calendar quarter of the client’s account. ASSETS UNDER MANAGEMENT ANNUAL FEE Assets under $500,000 Assets between $500,000 - $1,000,000 Assets between $1,000,000 - $2,000,000 7 Assets in excess of $2,000,000 1.25% 1.15% 1.00% 0.90%  The fee described herein compensates Advisor for investment advice, account management and reporting services only and is separate from other compensation paid by mutual fund companies. Mutual funds, annuities or index-based depository receipts purchased for a Client’s account can be purchased directly from the sponsor or exchange without an advisory fee. However, in the event of a direct purchase, a sales charge may apply, and the client would not receive the service described herein. Third Party Manager Fees Separately managed accounts with outside managers typically include an asset-based fee which varies by money manager and the services they provide in addition to WN’s advisory fee. The individualized money manager fee includes brokerage, custody and money manager services and requires Client authorization via a separate contract. Generally, WN utilizes TownSquare and Goldman Sachs as a third party managers for a small allocation of a Client’s total investable assets in the event it is in the Client’s best interest to invest a portion of their assets directly into a strategy which actively trades equities or fixed income investments. The cost to the Client for third party managers for investment management services ranges between 15bps and 65bps, depending upon the strategy and total assets managed by the third party manager. Again, this third-party manager fee is in addition to WN’s advisory fee. Comprehensive Financial Planning All planning fees are based on the specific planning services provided to the client and the complexity of the client’s financial situation and goals. A fixed fee is specified within the personal financial planning contract, and a down-payment of up to 100% of the total fee is billed to the client when the contract is entered into. Fees charged to clients are outlined in the Financial Consulting Agreement. This fee is based on the scope of planning and complexity of the plan being done. Fee will be based on an approximate hourly rate of between $250-$300 per hour. Depending on the services provided, the delivery of plan(s) range from 60 to 90 days, and in no case will the delivery of plan(s) take place more than 6 months after the upfront fee. However, because situations affecting the planning process may change, fees may be re-negotiated and adjusted with the Client’s consent. Based on the client’s individual financial situation and personal or business objectives, financial planning services may be provided in separate phases with a different fee charged for each phase. The individual phases and applicable fees would be based on the various components of the planning process, such as data collection and definition of objectives, and recommendations on specific areas in which the client requires financial planning services. Compensation from Sale of Securities WN does not have any advisory representatives actively registered in a brokerage capacity. Compensation from Sale of Insurance Products Some of our advisory representatives are also registered as independent insurance agents with 8 various insurance carriers and listed as agents of WN Insurance Group LLC. The insurance  agents receive commissions from the sale of insurance products. Receipt of these commissions creates a conflict of interest by giving the advisory representative an incentive to recommend insurance products based on compensation received by the advisory representative, rather than on the client’s needs. We seek to address this conflict of interest by disclosing to clients that the receipt of compensation by certain advisory representatives in connection with the sale of insurance products, and insurance products will not be in excess to investment advisory fees. WN will not charge an investment advisory fee when the representative is acting in a brokerage capacity. The assets will not be included in the assets under management for the computation of advisory fees for the client. Clients should also speak to their WN representative to understand the different types of services available through WN. Item 6 – Performance-Based Fees and Side-By-Side Management WN does not charge performance fees and therefore does not engage in side-by-side management. Item 7 – Types of Clients We provide our services to a number of types of Clients, including: • • • • • Individuals, including high net worth individuals Trust, estates and charitable organizations Corporations or other business entities Not for profit entities Others as necessary Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Analysis Methods of Analysis WN primarily utilizes mutual funds and ETFs as well as individual securities accounts. Alternative investments are also used when appropriate for the Client. Appropriate asset allocation mixes of these portfolios are determined and implemented by the investment advisor representative. Information used and analyzed comes from a variety of sources such as Dow Jones, Standard & Poors, Bloomberg, Morningstar, the U.S. Government, numerous periodicals, and personal discussions with fund managers and economists. WN uses that information for selecting mutual funds, ETFs and outside money managers and recommending the proper asset allocation mix. Investment Strategies WN investment advisors attempt to identify an appropriate asset allocation which is suitable to the client’s investment goals and risk tolerance. The strategy is designed to offer clients a diversified long-term approach to their personal investment goals and objectives through asset allocation, re-balancing, monitoring, supervision, consolidated reporting and periodic recommendations. The focus of recommendations made by WN is directed primarily toward 9 assisting the client in a diversified portfolio of investments with risk and return characteristics  consistent with those desired by the client. This strategy includes evaluation of the client’s current allocation of assets among or within various broad categories and may involve recommendations to reposition assets more in line with the client’s long-term goals and objectives. WN also provides investment advisory service in the area of non-public alternative investments to certain sophisticated and accredited investors as those terms are defined under federal and state law. Alternative investments often invest in more complex and less liquid investments. Our analysis methods rely on the assumption that the companies whose securities we recommend, and other available sources of information about these investments, are providing accurate and unbiased data. While we are alert to indications that the data may be inaccurate, there is always a risk that our analysis may be compromised by inaccurate or misleading third-party information. WN will also provide investment advice to certain accredited investors relating partnerships and other entities investing in venture capital, corporate restructurings, leveraged buyouts and direct equity investments. Also, private equity investments participating directly in companies or to their businesses which provide equity for venture capital, corporate restructures, leveraged buyouts, and direct equity investments. Risk of Loss An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund's underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains, in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund's stated daily per share net asset value ("NAV"), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund's holdings. The trading prices of a mutual fund's shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund's shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. All investments in securities include a risk of loss of your principal (invested amount) and any profits that have not been realized (the securities were not sold to “lock in” the profit). As you know, stock markets and bond markets can fluctuate substantially over time. In addition, as 10 global and domestic economic events have indicated, performance of any investment is not  guaranteed. As a result, there is a risk of loss of the assets WN manages that is out of our control. WN will do its very best in the management of your assets as a fiduciary; however, WN cannot guarantee any level of performance or that you will not experience a loss of your account assets. Item 9 – Disciplinary Information Adam Fisher and Scott Jones were involved in an arbitration claim in 2023, Troy Clayton was involved in an arbitration claim in 2024 and WN was involved in arbitration claims in 2024 (1) and 2025 (2). All of the mentioned arbitration claims were Dismissed with Prejudice. Additional information is available on the SEC’s website at www.adviserinfo.sec.gov . Item 10 – Other Financial Industry Activities and Affiliations Often financial needs include a wider spectrum of professional help than is provided by WN. In these cases, certain associated individuals of WN are involved with one or more of the following: • 317 Capital Group, LLC (“317 Capital” • • • ), is a real estate development company located in Centerville, Utah. 317 offers both debt and equity real estate investments to accredited investors. Wealth Navigation has in the past allocated a certain % of client assets to offerings provided through 317 Capital. Wealth Navigation or its managers participate in ownership of those offerings. Adam Fisher (“Fisher”), the CEO of WN, also has a 50% ownership interest in 317 Capital. 317 Capital is the sole member of 317 Manager LLC (“317 Manager”) and 317 PE Manager LLC (“317 PE” and, together with 317 Manager, the “317 Managers”). The 317 Managers managed 317 Private Fund. 317 Managers are entitled to receive compensation for management of the 317 Private Funds pursuant to the applicable operating agreement. As the sole member of the 317 Managers, 317 Capital is entitled to amounts payable to those entities and the net profits of 317 Capital “shall be allocated in the percentages of capital ownership,” resulting in Fisher also receiving 50% of the 317 Capital net profits. • WN Insurance Group, LLC (“WN Insurance”) , is an affiliated insurance group under common ownership and control. Representatives of WN Insurance may offer insurance products to clients and non-clients of WN. Certain individual associated persons are licensed as insurance agents under WN Insurance Group, LLC and appointed as agents for various insurance companies. Some associated persons of WN are also separately employed or licensed with other related professions. These individuals spend as much as 40% of their time on these related activities. WN’s clients are under no obligation to engage in these businesses. RIA Co-Brand – Business Entities of Investment Advisor Representatives Certain Investment Advisor Representatives have their own legal business entities whose 11 business names and logos appear on marketing materials as approved by WN, or client  statements as approved by the Custodian. The Client should understand that the businesses are legal entities of the Investment Advisor Representative (IAR) and not of WN or the Custodian. Investment Advisory Services of the Investment Advisor Representatives are provided through WN. WN has the aforementioned arrangement with the following Investment Advisor Representatives: • Edge Financial Advisors, LLC: Troy Clayton, Porter Clayton, Tyson McDonald and Nathan Riggs. Item 11 – Code of Ethics WN has adopted a Code of Ethics (Code) designed to comply with Rule 204A-1 under the Investment Advisers act of 1940 and similar state rules and statutes. As required by regulation (and because it is good business), we have adopted a Code of Ethics that governs a number of potential conflicts of interest we have when providing our advisory services to you. This Code of Ethics is designed to ensure we meet our fiduciary obligation to you, our Client (or Prospective Client) and to emphasize a culture of compliance within our firm. The Code is designed to ensure that the high ethical standards long maintained by WN continue to be applied. The purpose of the Code is to disclose and mitigate activities which may lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct. The name and reputation of our firm continues to be a direct reflection of the conduct of each employee and Investment Advisor Representative. WN expects every employee to demonstrate the highest standards of ethical conduct for continued employment with WN. Our Code is comprehensive, is distributed to each employee at the time of hire, and annually thereafter (if there are changes). We also supplement the Code with training and on-going monitoring of employee activity. Our Code includes the following: • • • • • Reporting of gifts and business entertainment; Reporting (on an on-going and quarterly basis) all personal securities transactions (what we call “reportable securities” as mandated by regulation); and, On an annual basis, we require all employees to re-certify to our Code, identify members of their household and any account to which they have a beneficial ownership (they “own” the account or have “authority” over the account), securities held in certificate form and all securities they own at that time). Requirements related to the confidentiality of your Information Prohibitions on: o o o Insider trading (if we are in possession of material, non-public information); Rumor mongering; The acceptance of gifts and entertainment that exceed our policy standards; Our Code does not prohibit personal trading by employees (or our firm). As a professional investment adviser, we follow our own advice. As a result, we purchase or sell the same or 12 similar securities (or securities that are suitable for an employee or related account but not  suitable for any client, including you) at the same time that we place transactions for your account and the accounts of our other Clients. Strict compliance with the provisions of the Code shall be considered a basic condition of employment with Wealth Navigation. WN’s reputation for fair and honest dealing with its clients has taken considerable time to build. This standing could be seriously damaged as the result of even a single securities transaction being considered questionable. Employees are urged to seek the advice of the Chief Compliance Officer or designated person, for any questions about the Code or the application of the Code to their individual circumstances. A material breach of the provisions of the Code constitute grounds for potential disciplinary action, up to and including termination of employment with Wealth Navigation. The provisions of the Code is not all-inclusive. Rather, they are intended as a guide for employees of WN in their conduct. In situations where an employee is uncertain as to the intent or purpose of the Code, he/she is advised to consult with the Compliance Department. All questions arising in connection with personal securities trading should be resolved in favor of the client even at the expense of the interests of the employee. If you have any questions or concerns regarding the Code of Ethics or would like to receive the Code in its entirety, please contact us at 801-335-8200. Item 12 – Brokerage Practices WN cannot directly execute trades but must direct trades to a clearing firm. Clearing charges imposed by a clearing firm could result in clients paying higher commission rates than otherwise available through unaffiliated broker-dealers. We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. WN will take into account the custodian/broker’s reliability, accuracy of recommendations on particular securities, reputation, financial responsibility, and stability, ability to execute trades, nature and frequency of sales coverage, commission rate and responsiveness to WN. WN will seek best execution in transactions for its clients. We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), Inspira Financial, or Interactive Brokers (IB), as qualified custodian(s), and in some cases, American Funds. We are independently owned and operated and not affiliated with Schwab, Inspira Financial, IB or American Funds. Schwab, Inspira Financial, IB or American Funds will hold your assets in a brokerage account and buy and sell securities when we/you instruct them to. While we recommend that you use Schwab, Inspira Financial, IB or American Funds as a custodian/broker, you will decide whether to do so and open your account by entering into an account agreement directly with them. Your Brokerage and Custody Costs For our clients' accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees 13 on trades that it executes or that settle into your Schwab account. Certain trades (for example,  many mutual funds and ETFs) currently do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab's Cash Features Program. Your accounts at Schwab benefit because the overall commission rates you pay are lower than they would be otherwise. In addition to commissions, Schwab charges you a flat dollar amount as a "prime broker" or "trade away" fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Services that Benefit You. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit You. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • • • • • provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; provide pricing and other market data; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. Item 13 – Review of Accounts WN will monitor client accounts on a periodic basis and conduct account reviews regularly. Reviews are designed to ensure the advisory services provided to the client and the asset allocation are consistent with investment needs and objectives. Reviews are conducted based on various circumstances, including, but not limited to: • • • • • 14 Contributions and Withdrawals Tax Planning Market moving events Security specific events Updates to alternative investments  • Changes in client risk/return objectives WN may provide clients with additional reports in conjunction with account reviews. If a report is provided, it will contain relevant account and/or market-related information such as inventory of account holdings and account performance. Alternative investments often receive an updated price monthly. Such changes in value are mailed from the current custodian of the funds to the client as described in the private placement memorandum provided prior to the investment in the security. Any funds held in a brokerage account through one of our custodians will generate a monthly or quarterly statement delivered to the client via email or their address of record depending on their account preferences. WN does use a data aggregation system to provide a combined view of all accounts currently held but discloses that although we make every effort to ensure the data is correct, we suggest the client refer to the product sponsor’s statement for the most accurate value. Item 14 – Client Referrals and Other Compensation WN has an agreement with Aspirant Partners, LLC to perform personal consultation and advisory services for various real estate projects that WN may approve for investment through the RIA. As part of the agreement, WN may qualify and recommend an investment in the Company to accredited investors who meet various suitability requirements (e.g., investor risk tolerance, investment objectives, duration of investment, tolerance for illiquidity, etc.) and receive a portion of the Manager’s carried interest profits (the “Profits Interest”) of the Fund. Carried Profits Interest is a financial interest in the long- term capital gain of the Company. This creates a conflict of interest because WN has an incentive to recommend an investment in the Company for the purpose of their participation in the Manager’s Profit Interest. Notwithstanding such conflict of interest, WN addresses its fiduciary duty by qualifying investors for an equity investment in the company based on the various investor suitability requirements and openly disclosing participation in the Manager’s carried Profit Interests to investors. Additionally, WN’s potential share in a portion of the Manager’s Profit Interest in no way impacts the potential performance, return or value of an investor’s capital. WN has a legacy agreement to pay certain ongoing referral fees to Andina Capital Management, LLC in which Andina earns 25% of the investment advisory fee received by WN. Applicable clients were provided with disclosures related to this compensation arrangement. Brokerage Compensation WN does not have any advisory representatives actively registered in a brokerage capacity. Insurance Compensation Some of our advisory representatives are also registered as independent insurance agents with various insurance carriers and listed as agents of WN Insurance Group LLC. The insurance 15 agents receive fees and commissions from the sale of insurance products. To the extent  insurance products are purchased through our advisory professionals by advisory clients, the advisory professional(s) will be paid a commission by the insurance company who issues the policy. This creates a conflict of interest as there is an incentive for them to recommend insurance products based on the compensation received, rather than on your needs. Notwithstanding such conflict of interest, we address our fiduciary duty by utilizing insurance products only where it is in the best interest of clients, and after consultation with the client. Item 15 – Custody While WN does not maintain physical custody of any client funds or securities, we do deduct fees from the client accounts where clients have instructed us to do so in writing. Clients receive at least quarterly statements from the custodian, bank or other qualified custodian that holds and maintains client’s investment assets. WN does not hold or maintain custody of client funds. In the event a client check is received which are made payable to the respective custodian, resulting in the firm having inadvertent custody, those checks are promptly forwarded to the account custodian (e.g. Charles Schwab and Company Inc., Interactive Brokers, Inspira Financial, American Funds or another direct sponsor). WN also is deemed to have custody of certain client assets solely because clients have executed Standing Letters of Authorization (“SLOAs”) that permit us to transfer assets to designated third parties on the client’s behalf. These authorizations are processed and maintained by our qualified custodian, Charles Schwab & Co., Inc. (“Schwab”). We rely on the SEC’s February 2017 no-action relief regarding SLOAs and comply with all seven Client Authorization: conditions outlined in that guidance: 1. Each SLOA is an instruction from the client, in writing and Third-Party Identification: signed, identifying the designated third-party recipient. 2. The instruction includes the name and account number Custodian Oversight: (or other unique identifier) of the third-party account. 3. Schwab, as qualified custodian, independently verifies the Client Notifications: client’s authorization before the first transfer. 4. Schwab sends a written confirmation of each transfer to the client Adviser Role: promptly after execution. 5. Recordkeeping: We have no ability to change the identity of the third-party recipient, the destination account number, or other key transfer information without a new client- signed authorization. 6. Schwab maintains records of all transfers made under SLOAs, and we Custodian Notice of Instructions: maintain matching internal records. 7. Schwab sends written notice to the client, promptly after setup, confirming the SLOA arrangement. Because we and Schwab meet all of these conditions, we are deemed to have custody but are not required to undergo an annual surprise examination under the Custody Rule. 16  WN also prepares an aggregate account report in an effort to provide a clear view of all client accounts in one document. This report is for illustration purposes only because certain values are estimations and generally, have not been audited. Performance figures are purely historical and are net of investment advisory fees. We believe the information contained in this report to be reliable, however, the accuracy and completeness of the information is not guaranteed. In the event of any discrepancy, the sponsor's valuation shall prevail. Performance data quoted represents past performance and does not guarantee future results. The return and principal of an investment will fluctuate and when redeemed, it may be worth more or less than original cost. Investments are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Investments such as alternative investments (e.g., partnerships, limited liability companies, and real estate investment trusts which are not listed on any exchange), commodity pools, private equity, private debt and hedge funds are generally illiquid investments, and their current values may be different from the purchase price. Unless otherwise indicated, the values shown in this statement for such investments have been provided by the management, administrator, or sponsor of each program or a third- party vendor and represent their estimate of the value of the investor's participation in the program. Therefore, the estimated values shown herein are not necessarily reflective of values that will be realized upon liquidation. If an estimated value is not provided, valuation information is not available and the initial investment amount can be provided, however the holding will be excluded from the performance calculation. We urge you to review any reports/statements and compare such official custodial records to the account statements that we provide to you. Item 16 – Investment Discretion WN primarily provides advisory services on a discretionary basis. As such, prior to engaging WN to provide any investment management services, the client will be required to enter into a formal Investment Advisory Agreement with WN setting forth the terms and conditions under which WN shall manage client assets, including discretionary authorization. Item 17 – Voting Client Securities (i.e., Proxy Voting) WN has responsibility for voting proxies for portfolio securities consistent with the best economic interests of the clients. Our firm maintains written policies and procedures as to the handling, research, voting and reporting of proxy voting and makes appropriate disclosures about our firm’s proxy voting policies and practices. Our policy and practice include the responsibility to monitor corporate actions, receive and vote client proxies and disclose any conflicts of interest as well as making information available to clients about the voting of proxies for their portfolio securities and maintaining relevant and required records. Background 17 Proxy Voting is an important right of shareholders and reasonable care and diligence must be  undertaken to ensure that such rights are properly and timely exercised. Investment advisers registered with the SEC, and which exercise voting authority with respect to client securities, are required by Rule 206(4)-6 of the Advisers Act and similar state statutes and rules to: • • • • Adopt and implement written policies and procedures that are reasonably designed to ensure that client securities are voted in the best interests of clients, which must include how an adviser addresses material conflicts that arise between an adviser’s interests and those of its clients; Disclose to clients how they can obtain information from the WN with respect to the voting proxies for their securities; Describe to clients a summary of its proxy voting policies and procedures, and upon request, furnish a copy to its clients; Maintain certain records relating to the WN’s proxy voting activities when the adviser does have voting authority. Responsibility The CCO, or a designated person, has the responsibility for the implementation and monitoring of our proxy voting policy, practices, disclosures and recordkeeping, including outlining our voting guidelines in our procedures. Procedure WN has adopted procedures to implement our policy and conduct reviews to monitor and insure it is observed, implemented properly and amended or updated. WN’s voting procedures are: • • • All employees will forward any proxy materials received on behalf of clients to the CCO; The Proxy Manager will determine which client accounts hold the security to which the proxy relates; Absent material conflicts, the Proxy Manager will determine how Wealth Navigation should vote the proxy in accordance with applicable voting guidelines, complete the proxy and vote the proxy in a timely and appropriate manner. Disclosure WN has disclosed here the information summarizing this proxy voting policy and procedure, including a statement that clients can request information on how WN voted a client’s proxies, and how clients can request a copy of our policies and procedures. The Proxy Manager will also send a copy of this summary to all existing clients who have previously received WN’s Disclosure Document; or the Proxy Manager may send each client the amended Disclosure Document. Either mailing shall highlight the inclusion of information regarding proxy voting. All client requests for information regarding proxy votes, or policies or procedures, received by any employee should be forwarded to the Proxy Manager. In response to any request, the Proxy Manager will prepare a written response to the client with the information requested, and as applicable will include the name of the issuer, the proposal voted upon, and how WN voted the client’s proxy with respect to each proposal. 18  Voting Guidelines WN’s policy is to vote all proxies from a specific issuer the same way for each client absent qualifying restrictions from a client. Clients are permitted to place reasonable restrictions, in writing, on WN’s voting authority in the same manner that they may place such restrictions on the actual selection of account securities. WN will generally vote in favor of routine corporate housekeeping proposals such as the election of directors and selections of auditors absent conflicts of interest raised by an auditor’s non-audit service. WN will generally vote against proposals that cause board members to become entrenched or cause unequal voting rights. In reviewing proposals, WN will further consider the opinion of management and the effect on management, and the effect on shareholder value and the issuer’s business practices. Conflicts of Interest WN will identify any conflicts that exist between the interests of the adviser and the client by reviewing the relationship of WN with the issuer of each security to determine if WN or any of its employees have any financial, business or personal relationship with the issuer. If a material conflict of interest exists, the Proxy Manager will determine whether it is appropriate to disclose the conflict to the affected clients, to give the clients an opportunity to vote the proxies themselves, or to address the voting issue through other objective means such as voting in a manner consistent with a predetermined voting policy or receiving an independent third-party voting recommendation. WN will maintain a record of the voting resolution of any conflict of interest. Recordkeeping The Proxy Manager shall retain the following proxy records in accordance with the SEC’s five- year retention requirement. • • • • • These policies and procedures and any amendments; Each proxy statement that WN receives; A record of each vote that WN casts; Any document WN created that was material to making a decision how to vote proxies, or that memorializes that decision including periodic reports to the Proxy Manager or proxy committee, if applicable A copy of each written request from a client for information on how WN voted such client’s proxies, and a copy of any written response. Item 18 – Financial Information Annual fees are charged to a client and are to be paid quarterly in arrears based on the average daily balance of the preceding calendar quarter of the client’s account. WN does not require or solicit prepayment of more than $1200 in fees per client, six months or more in advance. Please see ITEM 5 for fee amounts and procedures. Based on the above, the firm is not required to disclose any financial information. 19