Overview

Headquarters
San Francisco, CA
Total Firm Assets
$121 million
Average High-Net-Worth Client Portfolio Size
$2.6 million
Minimum Account Size
$1,250,000

Fee Structure

Primary Fee Schedule (WEALTH SCRIPT ADVISORS LLC - FORM ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $1,500,000 1.00%
$1,500,001 $3,000,000 0.80%
$3,000,001 $8,000,000 0.65%
$8,000,001 $15,000,000 0.55%
$15,000,001 and above 0.10%

Minimum Annual Fee: $12,500

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million Below minimum client size
$5 million $40,000 0.80%
$10 million $70,500 0.70%
$50 million $133,000 0.27%
$100 million $183,000 0.18%

Clients

High-Net-Worth Share of Firm Assets
96.47%
Number of High-Net-Worth Clients
45
Total Client Accounts
187
Discretionary Accounts
186
Non-Discretionary Accounts
1

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection

Regulatory Filings

SEC CRD Number
334760

Primary Brochure: WEALTH SCRIPT ADVISORS LLC - FORM ADV PART 2A (2026-06-18)

View Document Text
Item 1: Cover Page 605 Market Street Suite 509 San Francisco, California, 94105 (415)300-0610 www.mywealthscript.com Fo r m ADV Pa r t 2A – Fir m Bro ch u re Dated June 11, 2026 This Brochure provides information about the qualifications and business practices of Wealth Script Advisors LLC. If you have any questions about the contents of this Brochure, please contact us at (415)300-0610 alex@mywealthscript.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. Wealth Script Advisors LLC is a registered investment adviser with the SEC. Registration does not imply a certain level of skill or training. Additional information about Wealth Script Advisors LLC also is available on the SEC’s website at www.adviserinfo.sec.gov, which can be found using the firm’s identification number, 334760. 1 Item 2: Material Changes The Firm’s last annual updating amendment to its Form ADV Part 2A was filed in May 2026 while registered with the State of California. Since that time, the following material changes have been made: Item 4 – Advisory Business – Updated assets under management and added disclosure regarding non- discretionary and non-trading investment management services. Additionally, theFfirm has gone through a succession event, being transferred from ownership of Alexey Caswell-Yatsenko to The Jennifer and Alex Caswell Family Trust. Item 5 – Fees and Compensation – Updated to include revised fee tiers and methodology, compensation associated with the Firm’s financial planning services, minimum account size and termination provisions applicable to ongoing financial planning services. Item 1 0 – Other Financial Industry Activities and Affiliates – Updated to disclose firm representative’s minority ownership interest in Electus, including related conflict of interest disclosures and client referral practices. Item 12: The ADV Part 2A was updated to reflect the fact we are no longer working with Interactive Brokers as a custodian on 2/3/2025. Item 1 5 – Custody – Updated to remove the firm’s prior invoicing practices applicable under state registration requirements following the firm’s transition to SEC registration. Item 16 - Investment Discretion – Updated to reflect the Firm’s authority to provide non-discretionary services. Item 1 8 – Financial Information – Updated to revise the prepaid advisory fee threshold from $500 to $1,200 following the firm’s transition to SEC registration. Item 19 – Requirements for State Registered Advisers – Removed following the Firm’s transition to SEC registration. Pursuant to regulation, Wealth Script Advisors will ensure that clients receive a summary of any materials changes to this Brochure within 120 days of the close of Wealth Script Advisors fiscal year-end. Additionally, as the Firm experiences material changes in the future, we will send you a summary of our “Material Changes” under separate cover. For more information about the firm, please contact us at (415)300-0610. Additional information about Wealth Script Advisors and its investment adviser representatives is also available on the SEC’s website at www.adviserinfo.sec.gov. 2 Item 3: Table of Contents Item 1: Cover Page 1 Item 2: Material Changes 2 Item 3: Table of Contents 3 Item 4: Advisory Business 4 Item 5: Fees and Compensation 8 Item 6: Performance-Based Fees and Side-By-Side Management 11 Item 7: Types of Clients 12 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss 13 Item 9: Disciplinary Information 18 Item 10: Other Financial Industry Activities and Affiliations 19 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 20 Item 12: Brokerage Practices 22 Item 13: Review of Accounts 25 Item 14: Client Referrals and Other Compensation 26 Item 15: Custody 27 Item 16: Investment Discretion 28 Item 17: Voting Client Securities 29 Item 18: Financial Information 30 3 Item 4: Advisory Business De scrip t io n o f Ad viso ry Firm Wealth Script Advisors LLC is a SEC registered Investment Adviser principally located in the state of California. We are organized as a limited liability company and began operations in 2025. Wealth Script Advisors LLC became registered with the SEC in 2026. Effective February 1, 2026, and pursuant to a succession by amendment, Wealth Script experienced a “succession event” when a change in ownership occurred, but this change did not result in a practical change of control or management. As of this date, The Jennifer and Alex Caswell Family Trust now serves as the principal owner of the firm, which is in turn owned by Alex and Jennifer Caswell. Alex Caswell will continue to serve as the managing member and chief compliance officer of the firm. As used in this brochure, the words “WSA”, "we", "our firm", “Advisor”, and "us" refer to Wealth Script Advisors LLC, and the words "you", "your", and "Client" refer to you as either a client or prospective client of our firm. Typ e s o f Ad viso r y Se r vice s WSA is a fee-only firm, meaning the only compensation we receive is from our Clients for our services. From time to time, WSA recommends third-party professionals such as attorneys, accountants, tax advisors, insurance agents, or other financial professionals. Clients are never obligated to utilize any third-party professional we recommend. WSA is not affiliated with nor does WSA receive any compensation from third- party professionals we may recommend. We a lt h Ma n a ge m e n t Se rvice s Wealth Management encompasses investment management services and financial planning. Our firm provides continuous advice to a Client regarding the investment of Client funds based on the individual needs of the Client. Through personal discussions in which goals and objectives based on a Client's particular circumstances are established, we develop a Client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation targets. We will also review and discuss a Client’s prior investment history, as well as family composition and background. Account supervision is guided by the stated objectives of the Client (e.g., maximum capital appreciation, growth, income, or growth and income), as well as risk tolerance and tax considerations. We primarily advise our Clients regarding investments in stocks, bonds, mutual funds, ETFs, U.S. government and municipal securities, and cash and cash equivalents. We may also provide advice regarding investments held in Client’s portfolio at the inception of our advisory relationship and/or other investment types not listed above, at the Client’s request. When we provide investment management services, Clients grant us limited authority to buy and sell securities on a discretionary and non-discretionary basis. More information on our trading authority is explained in Item 16 of this Brochure. Clients may impose reasonable restrictions in writing on investing in certain securities, types of securities, or industry sectors. On occasion, WSA offers non-trading investment management services. The Advisor will not have authority to execute transactions, place orders for securities or other investments, transfer assets, or otherwise effect trades in any Client account. The Client will retain sole authority and responsibility for determining whether to implement 4 any recommendations provided by the Advisor and for executing any transactions, either directly or through the Client’s selected broker, adviser, custodian, or other service providers. When appropriate, we utilize the services of third-party investment advisers (“Outside Managers”) to assist with the management of Client accounts. We assist Clients in completing the Outside Managers’ investor profile questionnaire, selecting an appropriate asset allocation model, interacting with the Outside Managers and conducting an ongoing review of the Outside Managers’ investment offerings and investment selection. Our review process and analysis of Outside Managers is further discussed in Item 8 of this Brochure. Additionally, we will meet with the Client on a periodic basis to discuss changes in their personal or financial situation, suitability, and any new or revised restrictions to be applied to the account. Financial planning involves an evaluation of a Client's current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they affect and are affected by the entire financial and life situation of the Client. Clients purchasing this service will receive a written report, providing the Client with a detailed financial plan designed to help achieve the Client’s stated financial goals and objectives. In general, the financial plan will address some or all of the following areas of concern. The Client and WSA will work together to select specific areas to cover. These areas may include, but are not limited to, the following: ● Bu s in e s s Pla n n in g: We provide consulting services for Clients who currently operate their own business, are considering starting a business, or are planning for an exit from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. ● Ca s h Flo w a n d De b t Ma n a ge m e n t : We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. ● Co lle ge Sa vin gs : Includes projecting the amount that will be needed to achieve college or other post- secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to children and grandchildren (if appropriate). ● Em p lo ye e Be n e fit s Op t im iza t io n : We will provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. ● Est a t e Pla n n in g: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. 5 ● Fin a n cia l Go a ls : We will help Clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. ● In s u ra n ce : Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile. ● In ve s t m e n t An a lys is : This may involve developing an asset allocation strategy to meet Clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. ● Re t ire m e n t Pla n n in g: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. ● Ris k Ma n a ge m e n t : A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self-insuring”). ● Ta x Pla n n in g St r a t e gie s: Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with the consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. Clie n t Ta ilo re d Se rvice s a n d Clie n t Im p o se d Re st rict io n s We tailor the delivery of our services to meet the individual needs of our Clients. We consult with Clients initially and on an ongoing basis, through the duration of their engagement with us, to determine risk tolerance, time horizon and other factors that may impact the Clients’ investment and/or planning needs. Clients are able to specify, within reason, any restrictions they would like to place as it pertains to individual securities and/or sectors that will be traded in their account. All such requests must be provided to WSA in writing. WSA will notify Clients if they are unable to accommodate any requests. Wra p Fe e Pro gra m s We do not participate in wrap fee programs. 6 Asse t s Un d e r Ma n a ge m e n t As of May 26, 2025, WSA has $121,388,307 assets under management, of which $111,638,090 are managed on a discretionary basis, and $9,750,217 on a non-discretionary basis. 7 Item 5: Fees and Compensation Please note, unless a Client has received this brochure at least 48 hours prior to signing an Advisory Contract, the Advisory Contract may be terminated by the Client within five (5) business days of signing the Advisory Contract without penalty or incurring any fees. How we are paid depends on the type of advisory services we perform. Below is a brief description of our fees, however, you should review your executed Advisory Contract for more detailed information regarding the exact fees you will be paying. No increase to the agreed-upon advisory fees outlined in the Advisory Contract shall occur without prior Client consent. Please note, lower fees for comparable services may be available from other sources. If WSA utilizes an Outside Manager, the fee schedules below do not include the Outside Manager’s fee. The Outside Manager’s advisory fees, billing schedule, and payment procedures are set forth in their separate written disclosure documents, advisory agreements, and/or the account opening documents of your account Custodian. At no point will the combined fee charged to the Client exceed 2% of assets under management. Please note, unless instructed otherwise, each Account will typically be billed individually for its respective fees owed. However, WSA will at times bill Accounts disproportionately for fees should such actions be necessary due to insufficient funds in any respective Client Account, or if doing so is deemed by the WSA to be in the best interest of Client. We a lt h Ma n a ge m e n t Se rvice s Our fee for Wealth Management Services is either a flat annual fee or a percentage of assets under management as outlined below: For Clients with managed assets greater than $1,250,000 Asse t s Un d e r Ma n a ge m e n t An n u a l Ad viso ry Fe e 1.00% $0 - $ 1,500,000 $1,500,001 - $3 ,000,000 0.80% 0.65% $3,000,001 - $8,0 00,000 0.55% $8,000,001 - $1 5,000,000 Ab o ve $15,000,001 0.10% 8 balance. The formula for the quarterly fee is determined by the following calculation: (($1,500,000 x 1.00%) + ($500,000 x 0.80%) ÷ 4 = $4,750.00. In determining the advisory fee, we may allow accounts of members of the same household to be aggregated. WSA relies on the valuation as provided by Client’s custodian in determining assets under management. Our advisory fee is prorated for any partial billing periods occurring during the engagement, including the initial and terminating billing periods. Adjustments will be made for deposits and withdrawals during the billing period. We deduct our advisory fee from one or more account(s) held at an unaffiliated third-party custodian, as directed by the Client. Please refer to Item 15 of this Brochure regarding our policy on direct fee deduction. When an Outside Manager is used, the Outside Manager will debit the Client’s account for both the Outside Manager’s fee, and WSA’s advisory fee. For Clients with managed assets below $1,250,000 Fees are charged on a flat fee basis. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of the Client’s engagement with WSA. The fee is to be charged quarterly in advance and will not exceed $12,500 annually. If the client has allocated assets under management, once the assets exceed $1,250,000 the client will be converted to the fee for assets under management exceeding $1,250,000 as described above. The flat fee and the minimums are subject to change. No fee changes will be made without explicit permission and agreement from the client in advance. The flat fee charged to clients with managed assets under $1,250,000 will not exceed 2% of assets under management. Fees are paid by electronic funds transfer (EFT) or debit/credit card. We use an independent third party payment processor in which the Client can securely input their banking information and pay their fee. We do not have access to the Client’s banking information at any time. The Client will be provided with their own secure portal in order to make payments. Ot h e r Typ e s o f Fe e s a n d Exp e n s e s Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange-traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that we consider in selecting or recommending custodians for Client’s transactions and determining the reasonableness of their compensation (e.g., commissions). Clients may incur fees from third-party professionals such as accountants and attorneys that WSA may recommend, upon Client request. Such fees are separate and distinct from WSA’s advisory fees. 9 Fin a n cia l Pla n n in g Fe e s Clients engaging for financial planning services are generally assessed a fixed fee. The fixed base rate fee is $12,500 per annum for financial planning services. The rate will increase based on additional services as requested by the Client. WSA bills quarterly, at the beginning of each calendar quarter, at a rate of one-fourth (1/4th) the annual fee per quarter. Clients under an “ongoing” Agreement may terminate services at any time upon thirty (30) days’ written notice. Upon termination, any prepaid but unearned fees shall be prorated and refunded to the Client based on the services performed through the effective date of termination, including the applicable thirty (30) day notice period. Fees are paid by electronic funds transfer (EFT) or debit/credit card. We use an independent third party payment processor in which the Client can securely input their banking information and pay their fee. We do not have access to the Client’s banking information at any time. The Client will be provided with their own secure portal in order to make payments. Te rm in a t io n s a n d Re fu n d s The Advisory Contract may be terminated with written notice 30 calendar days in advance. Upon termination of the Advisory Contract, a prorated refund will be provided to the Client based on the number of days services were provided. Sa le o f Se cu r it ie s o r Ot h e r In ve st m e n t Pro d u ct s Advisor and its supervised persons do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. 10 Item 6: Performance-Based Fees and Side-By-Side Management We do not offer performance-based fees and do not engage in side-by-side management. 11 Item 7: Types of Clients We provide financial planning and investment management services to individuals and high net-worth individuals. Our minimum account size requirement is $1,250,000 to open or maintain an account under our management. WSA may reduce or waive the minimum account size requirement on a case-by-case basis. Our minimum annual fee is $12,500. 12 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Me t h o d s o f An a lysis Fu n d a m e n t a l a n a lys is involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience, and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The risk of fundamental analysis is that the information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Cyclica l a n a lys is is a type of technical analysis that involves evaluating recurring price patterns and trends based upon business cycles. Economic/business cycles may not be predictable and may have many fluctuations between long-term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Mo d e rn Po rt fo lio Th e o ry (MPT) The underlying principles of MPT are: ● Investors are risk averse. The only acceptable risk is that which is adequately compensated by an expected return. Risk and investment return are related and an increase in risk requires an increased expected return. ● Markets are efficient. The same market information is available to all investors at the same time. The market prices every security fairly based upon this equal availability of information. ● ● ● The design of the portfolio as a whole is more important than the selection of any particular security. The appropriate allocation of capital among asset classes will have far more influence on long-term portfolio performance than the selection of individual securities. Investing for the long-term (preferably longer than ten years) becomes critical to investment success because it allows the long-term characteristics of the asset classes to surface. Increasing diversification of the portfolio with lower correlated asset class positions can decrease portfolio risk. Correlation is the statistical term for the extent to which two asset classes move in tandem or opposition to one another. Mu t u a l Fu n d a n d / o r ETF An a lysis: We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in other funds in the Client’s portfolio. In addition, we monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were 13 to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the fund or ETF less suitable for the Client’s portfolio. Us e o f Ou t s id e Ma n a ge r s : We may refer Clients to Third Party Investment Advisers or advisory programs (“Outside Managers”). Our analysis of Outside Managers involves the examination of the experience, expertise, investment philosophies, and past performance of the Outside Managers in an attempt to determine if that Outside Manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the Outside Manager's underlying holdings, strategies, concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as part of our due diligence process, we survey the Outside Manager's compliance and business enterprise risks. A risk of investing with an Outside Manager who has been successful in the past is that they may not be able to replicate that success in the future. In addition, we do not control the underlying investments in an Outside Manager's portfolio. There is also a risk that an Outside Manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our Clients. Moreover, as we do not control the Outside Manager's daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. In ve st m e n t St r a t e gie s Asse t Allo ca t io n In implementing our Clients’ investment strategy, we begin by attempting to identify an appropriate ratio of equities, fixed income, and cash (i.e. “asset allocation”) suitable to the Client’s investment goals and risk tolerance. A risk of asset allocation is that the Client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of equities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the Client’s goals. We attempt to closely monitor our asset allocation models and make changes periodically to keep in line with the target risk tolerance model. Pa ssive a n d Act ive In ve st m e n t Ma n a ge m e n t We may choose investment vehicles that are considered passive, active, or a combination of both styles. Passive investing involves building portfolios that are composed of various distinct asset classes. The asset classes are weighted in a manner to achieve a desired relationship between correlation, risk and return. Funds that passively capture the returns of the desired asset classes are placed in the portfolio. Active investing involves a single manager or managers who employ some method, strategy or technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a designated benchmark. Actively managed funds are also designed to reduce volatility and risk. We may engage in both passive and active investing in the Client's portfolio. However, we strive to construct portfolios of funds and individual securities that we believe will have the greatest probability for achieving our Clients’ personal financial goals with the least amount of volatility and risk rather than attempt to outperform an arbitrary index or benchmark. Specific investment selections are based on a number of factors that we evaluate in order to select, what we believe to be, the highest quality funds or individual securities for our Clients. These factors include but are not limited to underlying holdings of funds, percentage weighting of holdings within funds, liquidity, tax efficiency, bid/ask spreads, and other smart/strategic beta factors. These factors may or may not result in the lowest cost ETFs and mutual funds available when utilizing funds in a Client’s portfolio, but we strive to keep internal fund expenses as low as possible. So cia lly Re sp o n sib le In ve st in g We may utilize various socially conscious investment approaches if a Client desires. WSA may construct 14 portfolios that utilize mutual funds, ETFs, or individual securities with the purpose of incorporating socially conscious principles into a Client’s portfolio. These portfolios may sometimes also be customized to reflect the personal values of each individual, family, or organization. This allows our Clients to invest in a way that aligns with their values. WSA may rely on mutual funds and ETFs that incorporate Environmental, Social and Governance (“ESG”) research as well as positive and negative screens related to specific business practices to determine the quality of an investment on values-based merits. Additionally, WSA may construct portfolios of individual securities in order to provide Clients with a greater degree of control over the socially conscious strategies they are utilizing. WSA relies on third-party research when constructing portfolios of individual securities with socially conscious considerations. If you request your portfolio to be invested according to socially conscious principles, you should note that returns on investments of this type may be limited and because of this limitation you may not be able to be as well diversified among various asset classes. The number of publicly traded companies that meet socially conscious investment parameters is also limited, and due to this limitation, there is a probability of similarity or overlap of holdings, especially among socially conscious mutual funds or ETFs. Therefore, there could be a more pronounced positive or negative impact on a socially conscious portfolio, which could be more volatile than a fully diversified portfolio. Lo n g-t e r m / Sh o r t -t e r m p u rch a se s We purchase securities and generally hold them in the Client's account for a year or longer. Short-term purchases may be employed as appropriate when: ● We believe the securities to be currently undervalued, and/or ● We want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Bla ckRo ck® Mo d e l Port folios BlackRock’s ETF Model Portfolios are designed for investors who believe in passive investing, which tracks a market- weighted index through index funds which have very low fund management fees. BlackRock provides a comprehensive set of risk-based model solutions designed by BlackRock’s diverse team of investment professionals and asset class experts. WSA utilizes BlackRock’s model solutions exclusively using ETFs. BlackRock aims to add value by choosing tactical allocations based on their market research and analysis of various risks of investing at any particular point in time. Their use of low-cost ETFs keeps fund expenses very low. We conduct ongoing due diligence on BlackRock and receive regular research and performance information regarding the Model Portfolios. In certain circumstances we will use long/short investing and alternative products such as exchange funds. These strategies will be used based on client unique tax needs, risk reduction methodology, and addressing key issues such as concentrated and highly appreciated securities, as well as capital gains recognized outside of our management. These strategies will be introduced to clients in advance of our use and only with the sole permission of the client. All fees, pros/cons, risks and other considerations will be clearly explained prior to implementation. Ma t e r ia l Ris ks In vo lve d All in ve s t in g s t r a t e gie s we o ffe r in vo lve r is k a n d m a y re s u lt in a lo s s o f yo u r o rigin a l in ve s t m e n t wh ich yo u s h o u ld b e p r e p a re d t o b e a r . Many of these risks apply equally to stocks, bonds, commodities, and any other investment or security. Material risks associated with our investment strategies are listed below. Ma rke t Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. 15 St r a t e gy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Sm a ll a n d Me d iu m Ca p Co m p a n y Ris k: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the Client’s portfolio. Tu r n o ve r Ris k: Actively managed mutual funds tend to have a higher turnover rate than passive funds. A high portfolio turnover would result in higher transaction costs and in higher taxes when shares are held in a taxable account. These factors may negatively affect the account’s performance. Lim it e d m a rke t s : Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate investments at prices we consider reasonable or favorable or find buyers at any price. In t e r e s t Ra t e Ris k: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Le ga l o r Le gis la t ive Ris k: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. In fla t io n : Inflation may erode the buying power of your investment portfolio, even if the dollar value of your investments remains the same. MPT Risk: Market risk is that part of a security's risk that is common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Sh o r t in g Ris k: Short selling involves borrowing securities to sell them with the expectation of buying them back at a lower price, but it carries significant risks, including unlimited loss potential if the price of the security rises instead of falling, margin risks that require additional funds to cover losses, and borrowing costs that can erode profits. Additionally, short selling may be affected by market volatility, regulatory restrictions, or a short squeeze, where a rapid price increase forces the short seller to buy back securities at higher prices, leading to substantial losses. Due to these risks, short selling is typically employed only in specific situations and may not be suitable for all clients. Priva t e ly He ld Illiq u id In ve st m e n t s: Privately held illiquid investments involve securities that are not publicly traded and may be difficult to sell or value. These investments can carry significant risks, including limited marketability, long holding periods, and the potential for significant losses if the investment cannot be sold or liquidated when needed. Additionally, valuations of such investments can be challenging, often relying on estimates that may not reflect current market conditions. The lack of liquidity may also restrict the ability to diversify or adjust the portfolio in response to changing market conditions, making these investments more suitable for investors with a long-term horizon and the capacity to bear illiquidity risk. Risks Asso cia t e d wit h Se cu r it ie s Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Co m m o n s t o cks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an 16 adverse effect on the price of all stocks. Co r p o r a t e Bo n d s are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Exch a n ge Tr a d e d Fu n d s prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above (premium) or below (discount) their net asset value and an ETF purchased at a premium may ultimately be sold at a discount; (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are delisted from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the Clients invest. Mu n icip a l Bo n d s are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Mu t u a l Fu n d s When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). Op t io n s a n d o t h e r d e riva t ive s carry many unique risks, including time-sensitivity, and can result in the complete loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. 17 Item 9: Disciplinary Information Cr im in a l o r Civil Act io n s WSA and its management persons have not been involved in any criminal or civil action. Ad m in ist ra t ive En fo rce m e n t Pro ce e d in gs WSA and its management persons have not been involved in any administrative enforcement proceedings. Se lf-Re gu la t o ry Orga n iza t io n En fo rce m e n t Pro ce e d in gs WSA and its management persons have not been involved in any self-regulatory organization (SRO) proceedings. 18 Item 10: Other Financial Industry Activities and Affiliations Bro ke r-De a le r Affilia t io n Neither WSA or its management persons is registered, or have an application pending to register, as a broker- dealer or a registered representative of a broker-dealer. Ot h e r Affilia t io n s Certain representatives of WSA are minority shareholders and on the advisory board of Electus, a private education technology company. At times, representatives of WSA may recommend clients utilize the services of Electus for educational technology and related services. Although WSA and its representatives do not receive referral fees should a client engage Electus for services, WSA representatives maintain a minority ownership interest in Electus. Accordingly, this arrangement creates a conflict of interest in that WSA may indirectly benefit from the success, profitability, or increased enterprise value of Electus resulting from client engagements. In order to mitigate these conflicts, they are disclosed to clients through this Brochure and relevant Brochure Supplements. Further, clients are made aware, typically through the delivery of this Brochure, that they always have the right to decide whether or not to implement any recommendations made by the Firm, are under no obligation to utilize Electus for services, and are free to select any service provider of their choosing. Re la t e d Pe rso n s Neither WSA or its management persons have any relationship or arrangement with any outside financial industry related parties. Re co m m e n d a t io n s o r Se le ct io n s o f Ot h e r In ve st m e n t Ad vise rs WSA may recommend Clients to Outside Managers to manage their accounts. In the event that we recommend an Outside Manager, we do not share in their advisory fee. Our fee is separate and in addition to their compensation (as noted in Item 5 of this brochure). Clients will receive a copy of the Outside Manager’s Form ADV 2A, Firm Brochure, which also describes the Outside Manager’s fee. You are not obligated, contractually or otherwise, to use the services of any Outside Manager we recommend. Moreover, WSA will only recommend an Outside Manager who is properly licensed or registered as an investment adviser. 19 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm has a duty of utmost good faith to act solely in the best interests of each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board of Standards Inc., and accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. Additionally, WSA requires adherence to its Insider Trading Policy, and the CFA Institute's Asset Manager Code of Professional Conduct and Code of Ethics and Standards of Professional Conduct. Co d e o f Et h ics De scr ip t io n This Code of Ethics does not attempt to identify all possible conflicts of interest, and compliance with each of its specific provisions will not shield our firm or its access persons from liability for misconduct that violates a fiduciary duty to our Clients. A summary of the Code of Ethics' Principles is outlined below. ● Integrity - Access persons shall offer and provide professional services with integrity. ● Objectivity - Access persons shall be objective in providing professional services to Clients. ● Competence - Access persons shall provide services to Clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. ● Fairness - Access persons shall perform professional services in a manner that is fair and reasonable to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. ● Confidentiality - Access persons shall not disclose confidential Client information without the specific consent of the Client unless in response to proper legal process, or as required by law. ● Professionalism - Access persons conduct in all matters shall reflect the credit of the profession. ● Diligence - Access persons shall act diligently in providing professional services. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request. In ve s t m e n t Re co m m e n d a t io n s In vo lvin g a Ma t e r ia l Fin a n cia l In t e r e s t a n d Co n flict s o f In t e r e st Neither our firm, its access persons, or any related person is authorized to recommend to a Client or effect a transaction for a Client, involving any security in which our firm or a related person has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, principal transaction, among others. Ad viso r y Fir m Pu r ch a se o f Sa m e Se cu r it ie s Re co m m e n d e d t o Clie n t s a n d Co n flict s o f In t e r e s t Our firm, its access persons, and its related persons may buy or sell securities similar to, or different from, those we recommend to Clients. In an effort to reduce or eliminate certain conflicts of interest, our Code of Ethics may require that we restrict or prohibit access persons’ transactions in specific reportable securities. Any exceptions or trading pre-clearance must be approved by WSA’s Chief Compliance Officer in advance of 20 the transaction in an account. WSA maintains a copy of access persons’ personal securities transactions as required. Tra d in g Se cu r it ie s At / Ar o u n d t h e Sa m e Tim e a s Clie n t ’s Se cu r it ie s From time to time our firm, its access persons, or its related persons may buy or sell securities for themselves at or around the same time as they buy or sell securities for Clients’ account(s). To address this conflict, it is our policy that neither our firm or access persons shall have priority over Clients’ accounts in the purchase or sale of securities. 21 Item 12: Brokerage Practices Fa ct o r s Us e d t o Se le ct Cu st o d ia n s In recommending custodians, we have an obligation to seek the “best execution” of transactions in Client accounts. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the custodian’s services. The factors we consider when evaluating a custodian for best execution include, without limitation, the custodian’s: ● Combination of transaction execution services and asset custody services (generally without a separate fee for custody); ● Capability to execute, clear, and settle trades (buy and sell securities for your account); ● Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.); ● Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.); ● Availability of investment research and tools that assist us in making investment decisions; ● Quality of services; ● Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; ● Reputation, financial strength, security and stability; ● Prior service to us and our clients. With this in consideration, our firm generally recommends Charles Schwab & Co., Inc. (“Schwab”), as independent and unaffiliated SEC registered broker-dealer firms and members of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Re s e a rch a n d Ot h e r So ft -Do lla r Be n e fit s We do not have any soft-dollar arrangements with custodians whereby soft-dollar credits, used to purchase products and services, are earned directly in proportion to the amount of commissions paid by a Client. However, as a result of being on their institutional platform, Schwab may provide us with certain services that may benefit us. Ch a rle s Sch wa b Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide our Clients and us with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our Clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. The benefits received by Advisor or its personnel do not depend on the number of brokerage transactions directed to Schwab. As part of its fiduciary duties to Clients, Advisor at all times must put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits by Advisor or its related persons in and of itself creates a potential conflict of interest and may indirectly influence the Advisor’s choice of Schwab for custody and brokerage services. This conflict of interest is mitigated as Advisor regularly reviews the factors used to select custodians to ensure our recommendation is appropriate. Following is a more detailed description of Schwab’s support services: 22 1. Se r vice s t h a t b e n e fit yo u . 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. 2. Se r vice s t h a t m a y n o t d ir e ct ly b e n e fit yo u . 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 may use this research to service all or a 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 facilitate payment of our fees from our Clients’ accounts ● ● provide pricing and other market data ● ● assist with back-office functions, recordkeeping, and Client reporting 3. Se r vice s t h a t ge n e r a lly b e n e fit o n ly u s . Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: ● Educational conferences and events ● Consulting on technology, compliance, legal, and business needs ● Publications and conferences on practice management and business succession 4. Yo u r b ro ke r a ge a n d cu s t o d y co s t s . 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 on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Br o ke r a ge fo r Clie n t Re fe rr a ls We receive no referrals from a custodian, broker-dealer or third party in exchange for using that custodian, broker-dealer or third party. Clie n t s Dir e ct in g Wh ich Bro ke r/ De a le r / Cu s t o d ia n t o Use Our firm generally requires Clients establish account(s) at Schwab to execute transactions through. We will assist with establishing your account(s) at Schwab, however, we will not have the authority to open accounts on the Client's behalf. Not all investment advisers require their Clients to use their recommended custodian. By requiring that Clients use Schwab, we may be unable to achieve most favorable execution of Client transactions, and this practice may cost Clients more money. We base our recommendations on the factors disclosed in Item 12 herein and will only recommend custodians if we believe it's in the best interest of the Client. We do not permit Clients to direct brokerage (direct us to a broker-dealer of your choosing). Aggr e ga t in g (Blo ck) Tr a d in g fo r Mu lt ip le Clie n t Acco u n t s Aggregating orders, batch trading, or block trading is a process where trades for the same securities are purchased or sold for several clients at approximately the same time. We do not engage in block trading. It should be noted that implementing trades on a block or aggregate basis may be less expensive for client accounts; however, it is our trading policy to implement all client orders on an individual basis. Therefore, we do not aggregate or “block” client transactions. Considering the types of investments we hold in advisory client accounts, we do not believe clients are hindered in any way because we trade accounts individually. This is because we develop individualized investment strategies for clients and holdings will vary. Our strategies are 23 primarily developed for the long-term and minor differences in price execution are not material to our overall investment strategy. Outside Managers used by WSA may block Client trades at their discretion. Their specific practices are further discussed in their ADV Part 2A, Item 12. 24 Item 13: Review of Accounts Pe rio d ic Re vie ws Clients who engage us for investment management services will have their account(s) reviewed regularly on a quarterly basis by Alexey Igorevich Caswell-Yatsenko, Founder and CCO. The account(s) are reviewed with regards to the Client’s investment objectives and risk tolerance levels. Trigge r s o f Re vie ws Events that may trigger a special review would be unusual performance, addition or deletions of Client- imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per Client's needs. Re vie w Re p o r t s Clients will receive trade confirmations from the custodian(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. WSA will provide written performance and/or holdings reports to Investment Management Clients on a quarterly basis. We urge Clients to compare these reports against the account statements they receive from their custodian. 25 Item 14: Client Referrals and Other Compensation Co m p e n sa t io n Re ce ive d b y We a lt h Scrip t Ad viso rs LLC WSA is a fee-only firm that is compensated solely by its Clients. WSA does not receive commissions or other sales-related compensation. Except as mentioned in Item 12 above, we do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our Clients. Clie n t Re fe rr a ls fr o m So licit o r s WSA does not, directly or indirectly, compensate any person who is not advisory personnel for Client referrals. 26 Item 15: Custody WSA does not hold, directly or indirectly, Client funds or securities, or have any authority to obtain possession of them. All Client assets are held at a qualified custodian. Pursuant to the Investment Advisers Act of 1940, the firm is deemed to have “constructive custody” of client funds because we have the authority and ability to debit our fees directly from the accounts of those clients receiving our services. If WSA deducts its advisory fee from Client’s account(s), the following safeguards will be applied: i. ii. The Client will provide written authorization to WSA, permitting us to be paid directly from Client’s accounts held by the custodian. The custodian will send at least quarterly statements to the Client showing all disbursements from the accounts, including the amount of the advisory fee. WSA will send an itemized invoice to the Client at the same time it instructs the custodian to debit the advisory fee. Itemization includes the formula used to calculate the fee, the amount of assets under management the fee is based on, and the time period covered by the fee. The qualified custodian maintains actual physical custody of Client assets. Client account statements from custodians will be sent directly to each client to the email or postal mailing address that is provided by the Client to the qualified custodian. We urge you to carefully review custodial statements and compare them to the account invoices or reports that we may provide to you and notify us of any discrepancies. Clients are responsible for verifying the accuracy of these fees as listed on the custodian’s brokerage statement as the custodian does not assume this responsibility. Our invoices or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. If Client funds or securities are inadvertently received by our firm, they will be returned to the sender immediately, or as soon as practical. We encourage our clients to raise any questions with us about the custody, safety or security of their assets. The custodians we do business with will send you independent account statements listing your account balance(s), transaction history and any fee debits or other fees taken out of your account. 27 Item 16: Investment Discretion For those Client accounts where we provide Investment Management Services, WSA has discretionary authority and limited power of attorney to determine the securities and the amount of securities to be bought or sold for a Client’s account without having to obtain prior Client approval for each transaction. Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm discretion over the account(s). Additionally, the discretionary relationship will be outlined in the Advisory Contract and signed by the Client. Clients may limit our discretion by requesting certain restrictions on investments. However, approval of such requests are at the firm’s sole discretion. If WSA has engaged an Outside Manager to assist with the management of Client’s portfolio, WSA has the discretion to direct the Outside Manager to buy or sell securities for Client’s portfolio without obtaining prior Client approval for each transaction. When managing accounts on a non-discretionary basis, WSA receives Client authorization prior to each transaction for (1) which securities are to be bought or sold in Client accounts; (2) the amount of securities to be bought or sold in Client accounts. After receiving authorization from the Client, WSA generally has discretion with regard to when the transaction is executed. WSA’s authority to trade securities could be limited in certain circumstances by applicable legal and regulatory requirements. Additionally, in some instances, WSA’s discretionary authority can be limited by conditions imposed by Clients, including restrictions on investing in certain securities or types of securities. All such limitations, restrictions, and investment guidelines must be provided to WSA in writing. 28 Item 17: Voting Client Securities We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the Client has any questions on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies. 29 Item 18: Financial Information We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to our Clients, nor have we been the subject of any bankruptcy proceeding. We do not have custody of Client funds or securities, except as disclosed in Item 15 above, or require or solicit prepayment of more than $1200 in fees six months or more in advance. 30

Frequently Asked Questions