WEALTH PLANNING ASSET MANAGEMENT LIMITED LIABILITY COMPANY

Wealth Planning Asset Management Limited Liability Company d/b/a WP Asset Management Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Wealth Planning Asset Management Limited Liability Company. If you have any questions about the contents of this brochure, please contact us at (908) 719-8800 or by email at: madhu@wealthplanning.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Wealth Planning Asset Management Limited Liability Company is also available on the SEC’s website at www.adviserinfo.sec.gov. Wealth Planning Asset Management Limited Liability Company’s CRD number is: 279034. 302 US-202 Bedminste, NJ, 07921 (908) 719-8800 madhu@wealthplanning.com Registration does not imply a certain level of skill or training. Version Date: 5/15/2025 i  Item 2: Material Changes The material changes in this brochure are from the last annual updating amendment of Wealth Planning Asset Management Limited Liability Company on 03/29/2024. Material changes relate to Wealth Planning Asset Management Limited Liability Company’s policies, practices, or conflicts of interests. • Vishal Muni is no longer owner or supervisor of the firm. • The firm no longer offers financial planning services. i  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes .................................................................................................................................. i Item 3: Table of Contents.................................................................................................................................. ii Item 4: Advisory Business ................................................................................................................................ 4 A. Description of the Advisory Firm ........................................................................................................... 4 B. Types of Advisory Services ...................................................................................................................... 4 C. Client Tailored Services and Client Imposed Restrictions .................................................................... 5 D. Wrap Fee Programs ................................................................................................................................. 5 E. Assets Under Management ...................................................................................................................... 6 Item 5: Fees and Compensation ....................................................................................................................... 6 A. Fee Schedule ............................................................................................................................................. 6 B. Payment of Fees ........................................................................................................................................ 7 C. Client ResponsibilityFor Third Party Fees ............................................................................................. 7 D. Prepayment of Fees .................................................................................................................................. 7 E. Outside Compensation For the Sale of Securities to Clients ................................................................. 7 Item 6: Performance-Based Fees and Side-By-Side Management ................................................................. 7 Item 7: Types of Clients .................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ........................................................ 8 A. Methods of Analysis and Investment Strategies .............................................................................. 8 B. Material Risks Involved...................................................................................................................... 9 C. Risks of Specific Securities Utilized ................................................................................................. 10 Item 9: Disciplinary Information ................................................................................................................... 13 A. Criminal or Civil Actions ................................................................................................................. 13 B. Administrative Proceedings............................................................................................................. 13 C. Self-regulatory Organization (SRO) Proceedings ........................................................................... 13 Item 10: Other Financial Industry Activities and Affiliations ..................................................................... 13 A. Registration as a Broker/Dealer or Broker/Dealer Representative .............................................. 13 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity B. Trading Advisor .......................................................................................................................................... 13 ii  Registration Relationships Material to this Advisory Business and Possible Conflicts of C. Interests........................................................................................................................................................ 13 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ..................................................................................................................................................... 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 14 A. Code of Ethics ................................................................................................................................... 14 B. Recommendations Involving Material Financial Interests ............................................................ 14 C. Investing Personal Money in the Same Securities as Clients......................................................... 14 D. Trading Securities At/Around the Same Time as Clients’ Securities ........................................... 14 Item 12: Brokerage Practices .......................................................................................................................... 15 A. Factors Used to Select Custodians and/or Broker/Dealers .......................................................... 15 B. Aggregating (Block) Trading for Multiple Client Accounts .......................................................... 16 Item 13: Reviews of Accounts ........................................................................................................................ 16 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ............................ 16 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ......................................... 16 C. Content and Frequency of Regular Reports Provided to Clients .................................................. 16 Item 14: Client Referrals and Other Compensation ..................................................................................... 17 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales A. Awards or Other Prizes) ............................................................................................................................. 17 B. Compensation to Non – Advisory Personnel for Client Referrals ................................................ 17 Item 15: Custody ............................................................................................................................................. 17 Item 16: Investment Discretion ...................................................................................................................... 17 Item 17: Voting Client Securities (Proxy Voting) ......................................................................................... 17 Item 18: Financial Information ....................................................................................................................... 18 A. Balance Sheet ..................................................................................................................................... 18 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients .......................................................................................................................................................... 18 C. Bankruptcy Petitions in Previous Ten Years................................................................................... 18 iii  Item 4: Advisory Business A. Description of the Advisory Firm Wealth Planning Asset Management Limited Liability Company d/b/a WP Asset Management (hereinafter “WPAM”) is a Limited Liability Company organized in the State of New Jersey. The firm was formed in April 2015, and the principal owner is Sekhar Vemparala. B. Types of Advisory Services Portfolio Management Services WPAM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. WPAM creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring WPAM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. WPAM will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. WPAM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of WPAM’s economic, investment or other financial interests. To meet its fiduciary obligations, WPAM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, WPAM’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is WPAM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. 4  Selection of Other Advisers WPAM has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, WPAM will always ensure those other advisers are properly licensed or registered as an investment adviser. WPAM conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. WPAM then makes investments with a third-party investment adviser by investing with the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third party adviser on behalf of WPAM's client. WPAM may also allocate among one or more private equity funds or private equity fund advisers. WPAM will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Services Limited to Specific Types of Investments WPAM generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds and private placements. WPAM may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions WPAM will tailor a program for each individual client. WPAM will render advice through client interviews based on age, net-worth, client goals and objectives, investment horizon, tax needs, risk tolerance and other qualitative criteria. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by WPAM on behalf of the client. WPAM may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent WPAM from properly servicing the client account, or if the restrictions would require WPAM to deviate from its standard suite of services, WPAM reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. WPAM does not participate in any wrap fee programs. 5  E. Assets Under Management WPAM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $101,111,858 December 2024 $14,212,594 Item 5: Fees and Compensation A. Fee Schedule Asset-Based Fees for Portfolio Management Total Assets Under Management Annual Fee $250,000 - $10,000,000 2.50% $10,000,001 - $25,000,000 2.00% $25,000,001 and above 1.50% These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of WPAM's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. WPAM uses the value of the account as of the last business day of the prior billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Selection of Other Advisers Fees WPAM will receive its standard fee on top of the fee paid to the third party adviser. This relationship will be memorialized in each contract between WPAM and each third-party adviser. The fees will not exceed any limit imposed by any regulatory agency. These fees are negotiable. WPAM may engage in the selection of third-party money managers, but does not have any such arrangements in place at this time. This service may be canceled immediately upon written notice. 6  B. Payment of Fees Payment of Asset-Based Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in advance. Payment of Selection of Other Advisers Fees The timing, frequency, and method of paying fees for selection of third-party managers will depend on the specific third-party adviser selected. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by WPAM. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees WPAM collects certain fees in advance and certain fees in arrears, as indicated above. Refunds for fees paid in advance will be returned within fourteen days to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. E. Outside Compensation For the Sale of Securities to Clients Neither WPAM nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management WPAM does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 7  Item 7: Types of Clients WPAM generally provides advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Pension and Profit Sharing Plans ❖ Corporations or Other Businesses ❖ Charitable Organizations Minimum Account Size for Portfolio Management There is no account minimum. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis WPAM’s methods of analysis include charting analysis, fundamental analysis, technical analysis, cyclical analysis, quantitative analysis and modern portfolio theory. Charting analysis involves the use of patterns in performance charts. WPAM uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. 8  Investment Strategies WPAM uses long term trading, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Quantitative Model Risk: Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more 9  risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies WPAM's use of margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Selection of Other Advisers: Although WPAM will seek to select only money managers who will invest clients' assets with the highest level of integrity, WPAM's selection process cannot ensure that money managers will perform as desired and WPAM will have no control over the day-to-day operations of any of its selected money managers. WPAM would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulatory breaches or fraud. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized WPAM's use of margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. 10  Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. 11  Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Hedge Funds often engage in leveraging and other speculative investment practices that may increase the risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; May involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 12  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither WPAM nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither WPAM nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither WPAM nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections WPAM has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. Clients will pay WPAM its standard fee in addition to the standard fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract between WPAM and each third-party advisor. The fees will 13  not exceed any limit imposed by any regulatory agency. WPAM will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. WPAM will ensure that all recommended advisers are licensed or notice filed in the states in which WPAM is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics WPAM has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. WPAM's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests WPAM does not recommend that clients buy or sell any security in which a related person to WPAM or WPAM has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of WPAM may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of WPAM to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. WPAM will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of WPAM may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of WPAM to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, WPAM will never engage in 14  trading that operates to the client’s disadvantage if representatives of WPAM buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on WPAM’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and WPAM may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in WPAM's research efforts. WPAM will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. WPAM will require clients to use Schwab Institutional, a division of Charles Schwab & Co., Inc.. 1. Research and Other Soft-Dollar Benefits While WPAM has no formal soft dollars program in which soft dollars are used to pay for third party services, WPAM may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). WPAM may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and WPAM does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. WPAM benefits by not having to produce or pay for the research, products or services, and WPAM will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that WPAM’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals WPAM receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 15  3. Clients Directing Which Broker/Dealer/Custodian to Use WPAM will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If WPAM buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, WPAM would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. WPAM would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for WPAM's advisory services provided on an ongoing basis are reviewed at least quarterly by Sehkar Vemparala , with regard to clients’ respective investment policies and risk tolerance levels. All accounts at WPAM are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of WPAM's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. WPAM will also provide at least quarterly a separate written statement to the client. 16  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) WPAM may receive compensation from third-party advisers to which it directs clients. B. Compensation to Non – Advisory Personnel for Client Referrals WPAM may enter into written arrangements with third parties to act as solicitors for WPAM's investment management services. Solicitor relationships will be fully disclosed to each Client to the extent required by applicable law. WPAM will ensure each solicitor is exempt, notice filed, or properly registered in all appropriate jurisdictions. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, WPAM will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion WPAM provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, WPAM generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, WPAM’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to WPAM. Item 17: Voting Client Securities (Proxy Voting) WPAM will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. 17  Item 18: Financial Information A. Balance Sheet WPAM neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither WPAM nor its management has any financial condition that is likely to reasonably impair WPAM’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years WPAM has not been the subject of a bankruptcy petition in the last ten years. 18