Overview

Assets Under Management: $2.2 billion
Headquarters: OMAHA, NE
High-Net-Worth Clients: 375
Average Client Assets: $3.1 million

Frequently Asked Questions

WEALTHPLAN INVESTMENT MANAGEMENT LLC charges 2.00% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #311364), WEALTHPLAN INVESTMENT MANAGEMENT LLC is subject to fiduciary duty under federal law.

WEALTHPLAN INVESTMENT MANAGEMENT LLC is headquartered in OMAHA, NE.

WEALTHPLAN INVESTMENT MANAGEMENT LLC serves 375 high-net-worth clients according to their SEC filing dated February 28, 2026. View client details ↓

According to their SEC Form ADV, WEALTHPLAN INVESTMENT MANAGEMENT LLC offers financial planning, portfolio management for individuals, portfolio management for pooled investment vehicles, portfolio management for institutional clients, pension consulting services, and selection of other advisors. View all service details ↓

WEALTHPLAN INVESTMENT MANAGEMENT LLC manages $2.2 billion in client assets according to their SEC filing dated February 28, 2026.

According to their SEC Form ADV, WEALTHPLAN INVESTMENT MANAGEMENT LLC serves high-net-worth individuals, pooled investment vehicles, institutional clients, and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (FORM ADV PART 2A: FIRM BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 2.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $20,000 2.00%
$5 million $100,000 2.00%
$10 million $200,000 2.00%
$50 million $1,000,000 2.00%
$100 million $2,000,000 2.00%

Clients

Number of High-Net-Worth Clients: 375
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 53.52%
Average Client Assets: $3.1 million
Total Client Accounts: 5,313
Discretionary Accounts: 5,160
Non-Discretionary Accounts: 153
Minimum Account Size: None

Regulatory Filings

CRD Number: 311364
Filing ID: 2062518
Last Filing Date: 2026-02-28 13:41:10

Form ADV Documents

Additional Brochure: FORM ADV PART 2A: FIRM BROCHURE (2026-01-05)

View Document Text
Form ADV Part 2A: Firm Brochure WealthPlan Investment Management LLC CRD# 311364 A Registered Investment Adviser 101 S. 108th Ave., Third Floor Omaha, NE 68154 (402) 691-0200 Date of Disclosure Brochure: January 5, 2026 This disclosure brochure provides information about the qualifications and business practices of WealthPlan Investment Management LLC (also referred to as we, us and WealthPlan Investment Management throughout this disclosure brochure). If you have any questions about the contents of this brochure, please contact us at (402) 691-0200. The information in this disclosure brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about WealthPlan Investment Management is also available on the Internet at www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for WealthPlan Investment Management LLC or our firm’s CRD number 311364. Registration as an investment adviser does not imply a certain level of skill or training. WealthPlan Investment Management LLC Page 1 Form ADV Part 2A: Firm Brochure Item 2 – Material Changes WealthPLAN Investment Management, LLC is required to notify clients of any information that has changed since the last annual update of the Firm Brochure (“Brochure”) that may be important to them. The following material changes were made to this brochure since our most recent annual amendment filing on 03/27/2025. Expansion of Investment Strategy Implementation and Oversight The Firm has expanded and clarified its authority to select, monitor, and terminate unaffiliated third-party investment strategists and sub-advisers, as well as its ability to implement internally developed investment strategies, in accordance with client authorizations. Strategy descriptions and implementation details are provided to clients separately through advisory agreements or related appendices. Strategist Compensation Arrangements The Firm has updated disclosures regarding strategist compensation arrangements. When WealthPlan Investment Management serves as a strategist, it receives a strategist fee paid by the investment adviser representative or advisory firm implementing the strategy. This fee is not charged directly to clients, is not deducted from client accounts, and does not increase the advisory fee paid by the client. These arrangements create potential conflicts of interest, which are disclosed and managed through the Firm’s policies, procedures, and oversight processes. Use of Exchange-Traded Options for Liquidity Management The Firm has expanded its disclosure regarding the facilitation of certain exchange-traded options strategies, including box spreads, which may be used by eligible clients as a liquidity management tool. These strategies are executed on regulated options exchanges and cleared through the Options Clearing Corporation (“OCC”) and do not involve securities lending, margin lending, or the extension of credit by the Firm. Private Fund and Pooled Investment Vehicle Clarifications The Firm has clarified its role with respect to private funds and pooled investment vehicles. WealthPlan Investment Management does not exercise discretionary authority to subscribe client assets into private funds or pooled investment vehicles. Client participation in such investments requires affirmative client consent and separate documentation. The Firm may act as a sub-adviser to certain pooled investment vehicles, including collective investment trusts, as disclosed elsewhere in this brochure. WealthPlan Investment Management LLC Page 2 Form ADV Part 2A: Firm Brochure Item 3 – Table of Contents Item 2 – Material Changes ................................................................................................................................. 2 Item 3 – Table of Contents ................................................................................................................................. 3 Item 4 – Advisory Business ................................................................................................................................ 4 Item 5 – Fees and Compensation .................................................................................................................... 15 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................ 19 Item 7 – Types of Clients ................................................................................................................................. 19 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 19 Item 9 – Disciplinary Information ...................................................................................................................... 25 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 25 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ...................................... 27 Item 12 – Brokerage Practices ......................................................................................................................... 27 Item 13 – Review of Accounts ......................................................................................................................... 30 Item 14 – Client Referrals and Other Compensation ....................................................................................... 30 Item 15 – Custody ............................................................................................................................................ 32 Item 16 – Investment Discretion ....................................................................................................................... 33 Item 17 – Voting Client Securities .................................................................................................................... 34 Item 18 – Financial Information ........................................................................................................................ 34 WealthPlan Investment Management LLC Page 3 Form ADV Part 2A: Firm Brochure Item 4 – Advisory Business WealthPlan Investment Management LLC (“WealthPLAN Investment Management,” “WPIM,” “we,” “our,” or “us”) is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) with its primary place of business in Omaha, Nebraska. The firm is a limited liability company formed under the laws of the State of Nebraska. WealthPLAN Investment Management was formed in October 2020 and became registered as an investment adviser in December 2020. WPIM is a wholly owned subsidiary of WealthPLAN Group LLC. In addition to doing business under the name WealthPLAN Investment Management, LLC, certain of our Investment Adviser Representatives (“IARs”) use different “doing business as” (“DBA”) names (for example, “WealthPlan Partners – The Coble & McCune Team”). These additional DBA names are disclosed on our Form ADV Part 1. WealthPLAN Investment Management and WealthPlan Partners are separate SEC-registered investment advisers under common ownership through WealthPLAN Group. This Disclosure Brochure describes our business. In this brochure, the words “we,” “our,” “the firm,” and “us” refer to WealthPLAN Investment Management, and the words “you,” “your,” and “client” refer to you as either a client or prospective client of the firm. IARs may have their own legal business entities whose business names and logos may appear on approved marketing materials or on client statements as approved by the custodian. Clients should understand that such businesses are legal entities of the IAR and not of WealthPLAN Investment Management, LLC (and not of any custodian). Additionally, an IAR’s separate legal entity may provide services other than investment advisory services, as disclosed in this brochure. However, investment advisory services provided by our IARs are provided through WealthPLAN Investment Management, LLC. We provide financial planning, consulting, and investment management services. Prior to engaging us to provide any investment advisory services, a client is required to enter into one or more written agreements with the firm setting forth the terms and conditions under which we render our services (collectively, the “Agreement”). Retirement Plans, Participants, and Individual Retirement Accounts When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code, as applicable. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Description of Direct Advisory Services The following are descriptions of the primary advisory services of WealthPLAN Investment Management. A written agreement detailing the exact terms of the service must be signed by you and WealthPLAN Investment Management before we can provide you with the services described below. Our investment advisory services are provided to you through IARs of WealthPLAN Investment WealthPlan Investment Management LLC Page 4 Form ADV Part 2A: Firm Brochure Management (referred to as your “investment adviser representative” throughout this brochure). Financial Planning and Consulting Services We provide clients with a broad range of comprehensive financial planning and consulting services. These services may include business planning, investments, insurance, retirement, education, estate planning, and tax and cash-flow planning needs. Financial planning services may be provided in an ongoing relationship. In performing these services, we are not required to verify information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and are expressly authorized to rely on such information. We may recommend our own services, our advisory representatives, in their individual capacities as registered representatives of a broker-dealer, and/or other professionals to implement recommendations. Clients should understand a conflict of interest exists if we recommend our own services. The client is under no obligation to act upon any recommendation we make under a financial planning or consulting engagement or to engage us or the services of any recommended professional. The client retains absolute discretion over implementation decisions and is free to accept or reject any recommendation. We strongly recommend you promptly notify us if there is ever a change in your financial situation or investment objectives for the purpose of reviewing, evaluating, or revising our recommendations and/or services. Results of the analysis or review may be provided verbally, in a written financial plan or analysis, or delivered via online access to a financial planning or analysis tool. Asset Management Services We offer asset management services, which involve providing you with continuous and ongoing supervision over specified accounts. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., the right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). You can establish an Account through Charles Schwab & Co., Inc. We can also manage one or more Accounts held at other broker-dealer custodians. Please refer to Item 12 – Brokerage Practices for more information. We can also render services to clients related to variable life/annuity products they own (see “Variable Sub-Account Management Services” below), their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, we either direct or recommend the allocation of client assets among the various investment options that are available within the product. The Account is managed by us based on your financial situation, investment objectives, and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting, or holding securities, cash, or other investments in the Account. We primarily allocate clients’ investment management assets among mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, managed futures, real estate partnerships and/or options, as well as the securities components of variable annuities and variable life insurance contracts in accordance with the investment objectives of the client. In addition, we may recommend that clients who are “accredited investors,” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities, which may include debt, equity, and/or pooled investment vehicles WealthPlan Investment Management LLC Page 5 Form ADV Part 2A: Firm Brochure when consistent with the client’s investment objectives. We also provide advice about any type of investment held in clients’ portfolios. We tailor our advisory services to the individual needs of clients. We consult with clients initially and on an ongoing basis to determine risk tolerance, time horizon, and other factors that may impact the client’s investment needs. We strive to ensure that clients’ investments are suitable for their investment needs, goals, objectives, and risk tolerance based on information provided by the client on the Client Profile form, the Fact Finder, and during an initial one-on-one meeting and at least annually thereafter. Clients are advised to promptly notify the firm if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon our management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., requiring that a portion of assets be invested in socially responsible funds). As part of its asset management services, WPIM may implement internally developed, proprietary investment strategies and model portfolios From time to time, we may utilize the sub-advisory services of a third-party investment advisory firm or individual adviser to aid in implementing an investment portfolio designed by our firm. This may include receiving research recommendations that we may or may not utilize in the management of your accounts. Before selecting a firm or individual, we will ensure that the chosen party is properly licensed or registered. Asset Management for Held Away Accounts As part of our asset management services for held-away accounts, our firm has entered into a service agreement with Pontera Solutions Inc. (“Pontera®”) so that we may create and implement a portfolio for certain employer-sponsored retirement plan accounts and similar held-away accounts, consisting of the securities or investment opportunities made available by the plan sponsor. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the investment options made available in their plan. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored and, if necessary, rebalanced. We will need to obtain certain information from you to determine your financial situation and investment objectives. You are responsible for notifying us of updates regarding your financial situation, risk tolerance, or investment objective and whether you wish to impose or modify investment restrictions; however, we will contact you at least annually to discuss any changes. We are always reasonably available to consult with you regarding the status of your Account. You have the ability to impose reasonable restrictions on account management, including instructing us not to purchase certain securities. Differences Among Clients / Allocation and Other Conflicts It is important that you understand that we manage investments for other clients and may give them advice or take action for them or for our personal accounts that differs from the advice we provide to you or actions taken for you. We are not obligated to buy, sell, or recommend to you any security or other investment that we may buy, sell, or recommend for any other clients or for our own accounts. Conflicts can arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate among accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity will be allocated in any particular manner. If we obtain material, non- public information about a security or its issuer that we may not lawfully use or disclose, we have no obligation to disclose that information to any client or use it for any client’s benefit. WealthPlan Investment Management LLC Page 6 Form ADV Part 2A: Firm Brochure Institutional Intelligent Portfolios® (Schwab) We may offer portfolio management services using Institutional Intelligent Portfolios® (“IIP”), an online investment management platform that automatically rebalances portfolios for use by independent investment advisers and sponsored by Schwab Wealth Investment Advisory, Inc. (“SWIA”). Through the Program, our firm offers clients a range of investment strategies we construct and manage, each consisting of a portfolio of ETFs and a cash allocation. The client’s portfolio is held in a brokerage account opened by the client at SWIA’s affiliate, Charles Schwab & Co., Inc. Our firm is independent of and not owned by, affiliated with, sponsored by, or supervised by SWIA, Schwab, or their affiliates (together, “Schwab”). The Program is described in SWIA’s IIP Disclosure Brochure, which is delivered to clients during the online enrollment process. The minimum investment required to open an account is $5,000. Our firm, and not Schwab, is the client’s investment adviser and primary point of contact for the Program. Our firm is solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio, and managing that portfolio on an ongoing basis. SWIA’s role is limited to delivering the Program Disclosure Brochure and administering the Program so that it operates as described. Our firm has contracted with SWIA to provide the technology platform and related trading and account management services for the Program. The platform includes a system that automates certain key parts of the investment process. Our firm will make the final decision and select a portfolio based on client information. The system includes an automated investment engine through which portfolios are managed on an ongoing basis through systematic rebalancing and tax-loss harvesting (if the client is eligible and elects). In connection with the client’s appointment of our firm, the client grants trading authority over the account to SWIA. The client understands that when electing to use the Program, the client will not have authority to give Schwab trading instructions on the Program account or to closely control the timing of purchases or liquidations; trading instructions are given by SWIA via the automated engine. Clients will also execute a Financial Planning & Consulting Agreement and pay a separate, one-time initial fee for financial planning and consulting services. Thereafter, clients will receive ongoing financial planning and consulting services as part of the IIP service (with no separate ongoing financial planning and consulting fees) unless disclosed in advance, provided the client pays $6,000 or more in advisory fees attributed to our firm’s IIP service. Please see the Financial Planning & Consulting section in Item 5 for more information regarding initial planning fees. Discretionary Authority to Select Unaffiliated Third-Party Investment Advisers We may select for your Accounts one or more unaffiliated third-party investment advisers. Third-party investment advisers can be selected to serve either as a signal provider or as a sub-adviser to your Account. When selected as a signal provider, the third-party adviser develops and provides us with model investment portfolios and recommendations for when to buy and sell investments; we will trade your Account to implement those recommendations. When selected as a sub-adviser, the third-party adviser has discretionary trading authority to manage the Account or a portion of the Account. We conduct due diligence on any third-party investment adviser selected and used. We also monitor performance of third-party advisers relative to appropriate peers and/or benchmarks, as applicable. We are available to answer client questions regarding any portion of the client’s Account managed by a third- party adviser, and we act as the communication conduit between the client and the third-party adviser. The recommendation of a third-party investment adviser or other products and funds will be on either a discretionary or non-discretionary basis as set forth in the Advisory Agreement. When a client authorizes WealthPlan Investment Management LLC Page 7 Form ADV Part 2A: Firm Brochure us to select third-party advisers, products, or funds on a discretionary basis, we have authority to select and terminate them without the client’s specific approval. Variable Sub-Account Management Services Under our variable sub-account management services, we manage a client’s variable annuity or variable life insurance contract by selecting, monitoring, and exchanging (as necessary) among sub-accounts available from the insurance company issuing the contract. We assist you in completing a questionnaire detailing your financial goals, risk tolerance, and time horizon. You may list reasonable restrictions in your investment advisory agreement. You are responsible for notifying us of updates, and we will contact you at least annually to discuss changes. Once appropriate authorizations are provided, we use discretionary authority to select or exchange among available sub-accounts consistent with your investment objective and risk tolerance. We may utilize signal providers for guidance regarding strategies, asset allocation, and timing of exchanges. Variable annuity assets are maintained at the issuing insurance company, which will issue periodic account statements to the client as custodian of assets. Retirement Plan Services We offer retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For plan sponsors, services may include the following: Fiduciary Management Services (ERISA 3(38)) We may provide: (i) discretionary management services over designated plan assets, (ii) discretionary investment selection services (adding/removing plan investment options), (iii) default investment alternative management for qualified default investment alternatives (“QDIAs”), and (iv) investment management via model portfolios that are available as investment options for participants (with the ability for participants to impose reasonable restrictions by written instructions). If you elect to utilize these fiduciary management services, we will be acting as an “investment manager” to the plan as defined in ERISA section 3(38) and acknowledge fiduciary status with respect to these services. Fiduciary Consulting Services (ERISA 3(21)) We may provide: (i) investment policy statement preparation, (ii) general non-discretionary investment advice regarding asset classes and investment options consistent with the plan’s IPS, (iii) investment selection recommendations consistent with ERISA section 404(c), (iv) periodic due diligence reviews, (v) investment monitoring reports and recommendations, (vi) non-discretionary QDIA advice (with plan sponsor retaining responsibility for required notices), and (vii) individualized participant advice upon request. All recommendations are submitted to you for approval or rejection. Fiduciary consulting services are not management services; we do not serve as plan administrator or trustee, and we do not act as custodian for any client account or have access to client funds or securities (except that in some cases we may have written authorization from the client to deduct our fees). We acknowledge that in providing fiduciary consulting services we are acting as a fiduciary under ERISA section 3(21)(A)(ii) for purposes of providing non-discretionary investment advice only, and we will act consistent with ERISA fiduciary requirements as applicable based on the facts and circumstances. Non-Fiduciary Retirement Plan Consulting Services Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940, certain services should not be considered fiduciary services for ERISA purposes when we are not acting as a fiduciary to the plan under ERISA section 3(21)(A)(ii). The exact suite of services will be listed and detailed in the Qualified Retirement Plan Agreement. Non-fiduciary services may include participant education consistent with DOL Interpretive Bulletin 96-1, participant enrollment support, qualified plan development support (including assistance reviewing and selecting a third-party administrator), periodic due diligence reviews of plan fees/expenses and service providers, fiduciary file set-up support, and WealthPlan Investment Management LLC Page 8 Form ADV Part 2A: Firm Brochure benchmarking/operational analysis support. Securities and other investments bear different types and levels of risk. Upon request, we can discuss investments and strategies that we believe may tend to reduce risks for a particular client’s circumstances and plan participants. Clients and plan participants must understand that higher rates of return often entail higher risk. Based upon discussions with the client, we will attempt to identify the balance of risks and rewards that is appropriate; however, it is still the client’s responsibility to ask questions if the client does not fully understand investment risks. We cannot be sure that investments will be profitable or that losses will not occur. Past performance is an important consideration but is not necessarily an accurate predictor of future performance. We will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), any change to required disclosure information as soon as practicable, but no later than sixty (60) days from the date we are informed of the change (subject to extraordinary circumstances). We will disclose information required under ERISA Regulation Section 2550.408b-2(c)(vi)(A) within thirty (30) days following receipt of a written request from the responsible plan fiduciary or plan administrator (subject to extraordinary circumstances). If we make an unintentional error or omission in required ERISA disclosures, we will disclose the correct information as soon as practicable, but no later than thirty (30) days from the date we learn of the error or omission. Sponsored Investment Advisory Platforms Clients may gain access to our asset management services through programs or investment platforms sponsored by unaffiliated investment advisers and/or broker-dealers (each, a “Platform”). Through these Platforms, clients establish an account directly with the Platform sponsor. We may be available to clients for selection as an independent money manager, sub-adviser, or co-adviser. Many Platform terms and conditions are determined by the sponsor. The sponsor’s financial professional typically obtains financial data from the client, assists in determining suitability, and helps the client set investment objectives. The sponsor provides necessary information to us and is responsible for delivering our disclosure brochure and, depending on the program, our client agreement. We may or may not be responsible for executing transactions in the client’s account depending on the Platform structure. Clients accessing our services through a Platform may impose reasonable restrictions on their accounts. Collective Investment Trust – Sub-Adviser A collective investment trust (“CIT”) is a pooled investment vehicle exempt from registration as a mutual fund under the Investment Company Act of 1940 and is only available to qualified retirement plans. We serve as sub-adviser to the WealthPlan Dividend Aristocrat Portfolio for participation solely by eligible employee benefit trusts pursuant to a Declaration of Trust that qualifies as a group trust (the “Trust”). Matrix Trust Company (“Matrix” or the “Trustee”) serves as the CIT trustee and administrator, hires and fires the investment adviser to the CIT, and selects the qualified custodian. As sub-adviser, we provide investment advice and management services to the Trustee. Some retirement plans investing in the CIT could also be clients of WealthPLAN Investment Management. This is a conflict of interest. To mitigate this conflict, we have chosen to offer two share classes of the WealthPlan Dividend Aristocrat Portfolio. For those employee benefit trusts for which we are the adviser, we earn no fee as the sub-adviser to the CIT. We earn a sub-advisory fee solely in situations in which we are not the adviser of the employee benefit trust. Where a plan is otherwise a client of WealthPLAN Investment Management, we may perform retirement plan services (including fiduciary consulting services), except for selecting, monitoring, or recommending the CIT, and we may receive a fee for plan-level services. The plan sponsor is responsible for selecting and monitoring the CIT. The investment management fee paid by the CIT to us may be higher or lower than the fee we typically receive from a plan for plan-level services. Any increases in CIT assets will increase total WealthPlan Investment Management LLC Page 9 Form ADV Part 2A: Firm Brochure management fees paid to us; accordingly, any retirement plan utilizing our retirement plan services should conduct its own independent investigation and evaluation of the CIT. The CIT currently comprises our sole collective investment fund client. We maintain limited power of attorney to act on a discretionary basis when managing CIT investments; we are responsible for investment selection, asset allocation, and asset management decisions for the CIT, and we do not have authority to disburse assets or securities from the CIT. Financial Institution Consulting Services We provide investment consulting services to certain broker-dealer customers (“Brokerage Customers”) who provide written consent requesting to receive our consulting services. Brokerage Customers enter into a written agreement with us prior to a financial consultation taking place. These consulting services are provided to the financial institution and do not involve the provision of individualized investment advice to the institution’s retail customers. Retirement Plan Rollover Recommendations To the extent we recommend you roll over your account from a current retirement plan to an individual retirement account (“Rollover IRA”) managed by our firm, our IARs have a conflict of interest because we can earn increased advisory fees if you roll assets into a Rollover IRA managed by our firm, and we will earn fewer advisory fees if you do not. This means our recommendation could be influenced by our economic incentive and not exclusively by whether moving the IRA is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our IARs will (i) provide investment advice regarding rollovers consistent with applicable fiduciary status, (ii) not recommend investments resulting in unreasonable compensation to WealthPLAN Investment Management in connection with a rollover, and (iii) fully disclose compensation received by the firm and supervised persons and material conflicts related to rollover recommendations, and refrain from materially misleading statements regarding rollovers. To the extent we provide advice as a participant in a retirement plan regarding whether to maintain investments and/or proceeds in the retirement plan, roll over proceeds to a Rollover IRA, or make a distribution from the retirement plan, we acknowledge our fiduciary obligations with respect to that advice, and our IARs will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use, based on the client’s objectives, risk tolerance, financial circumstances, and needs, without regard to the financial or other interests of WealthPLAN Investment Management or affiliated personnel. Tailoring Advisory Services to Individual Needs of Clients Our advisory services are provided based on your individual needs. When we provide asset management services, you can impose reasonable restrictions on accounts we manage, including specific investment selections and sectors. We work with you through interviews and questionnaires to determine investment objectives and suitability information. Our financial planning services are also provided based on your individual needs and are delivered through a similar process. We will not enter into an advisory relationship with a prospective client whose objectives are incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. When managing accounts under our asset management services, we typically manage accounts in accordance with one or more investment models. When accounts are managed using models, investment selections are based on the underlying model and we do not develop customized portfolio holdings for each client. However, the determination to use a particular model or models is always based on each client’s individual investment goals, objectives, and mandates. WealthPlan Investment Management LLC Page 10 Form ADV Part 2A: Firm Brochure We may recommend and exercise discretion to utilize unaffiliated sub-adviser(s) to manage accounts or portions of accounts. We conduct due diligence and monitor sub-adviser performance relative to appropriate peers and/or benchmarks. We are available to answer questions regarding any portion of your account managed by a sub-adviser and act as the communication conduit between you and the sub-adviser. If the sub-adviser is registered as an investment adviser, a complete description of services and fees will be disclosed in the sub-adviser’s Form ADV Part 2A (or applicable appendix) provided to the client. Box Spread Liquidity Solution We offer a liquidity solution for eligible clients involving an exchange-traded options strategy commonly known as a “box spread.” This structure is intended to allow clients to obtain cash without selling their current investment positions. We facilitate these transactions but do not act as the lender. Liquidity is provided by unrelated market participants through regulated options exchanges and cleared by the Options Clearing Corporation (“OCC”). We receive compensation for providing this service, as described in Item 5 and Item 14. Client Assets Managed by WealthPLAN Investment Management As of December 31, 2025, WealthPLAN Investment Management had regulatory assets under management (“RAUM”) of $2,141,973,245.45 managed on a discretionary basis and $43,265,966.53 managed on a non-discretionary basis, for total RAUM of $2,185,239,311.98. The firm also advises on an additional approximately $1.8 billion of assets in retirement plans. Item 5 – Fees and Compensation In addition to the information provided in Item 4 – Advisory Business, this section describes the fees and compensation arrangements for WealthPlan Investment Management LLC (“WealthPLAN Investment Management” or “WPIM”). Clients should note that lower fees for comparable services may be available from other sources. The exact fees and terms applicable to a client will be outlined in the written agreement between the client and WPIM. Financial Planning and Consulting Fees WPIM can charge a fixed fee and/or an hourly fee for financial planning and consulting services. These fees are negotiable and vary depending on the scope and complexity of the services provided and the professional rendering the services. Flat fees generally range up to $5,000, and hourly fees generally range between $100 and $300. The applicable fee will be disclosed in the written agreement executed by the client. With client authorization, financial planning or consulting fees may be deducted from a client’s non- retirement investment account, as reflected on custodial account statements. Financial planning and consulting services may be provided on a one-time or recurring basis, as specified in the client’s written agreement. Prior to engaging WPIM for financial planning or consulting services, the client and the firm must enter into a written agreement setting forth the terms and conditions of the engagement, including the amount of the fee. Fees are generally due upon delivery of the financial plan or completion of the agreed-upon services. Financial planning services are provided pursuant to an ongoing agreement and may be terminated by either party upon written notice. Upon termination, any prepaid but unearned fees will be refunded to the client based on the time and effort completed prior to termination. Any fees owed to WPIM upon termination will be billed at that time. No refunds will be made after delivery of the agreed-upon services. WPIM will not charge fees in excess of $1,200 more than six months in advance of services to be rendered. Clients receive full disclosure of all fee arrangements in the applicable agreement. WPIM can charge an additional $150 for ongoing access to the eMoney® financial planning software WealthPlan Investment Management LLC Page 11 Form ADV Part 2A: Firm Brochure platform. This optional fee may be offered to both financial planning clients and asset management clients and will be disclosed in advance. Asset Management Services WPIM provides discretionary asset management services for an annual fee that will not exceed 2.00% of assets under management. The specific fee schedule applicable to a client will be outlined in the advisory agreement. Fees are negotiable based on factors such as account size, complexity, and services provided. Asset management fees are generally billed quarterly in advance, calculated on a pro-rata basis using the value of the account(s) as of the last day of the prior quarter. Fees are typically deducted directly from client account(s) pursuant to client authorization. In limited cases, WPIM may agree to invoice clients directly. Fees are generally assessed on cash and cash equivalents unless otherwise agreed to in writing. Adjustments are made for deposits and withdrawals in accordance with the advisory agreement. As part of this billing process: 1. The qualified custodian sends account statements at least quarterly showing account values and disbursements, including advisory fees; 2. Clients authorize WPIM to deduct advisory fees from the account or to invoice the custodian; and 3. If WPIM provides a copy of an invoice to the client, it will include a legend encouraging the client to compare the invoice with the custodian’s statement. Clients incur brokerage expenses and transaction costs charged by the qualified custodian, including commissions, ticket charges, and other execution-related fees. WPIM does not receive any portion of such fees. Clients may also incur third-party expenses related to investments held in the account, including mutual fund sales loads, 12b-1 fees, internal fund expenses, surrender charges, annuity fees, retirement plan fees, and custodian fees. Advisory fees charged by WPIM are separate from and in addition to these costs. WPIM does not receive any portion of mutual fund internal expenses unless otherwise disclosed. Proprietary Strategies and Strategist Fees WealthPlan Investment Management, LLC (“WPIM”) develops, maintains, and provides proprietary investment strategies and model portfolios (the “Strategies”) that may be implemented by investment adviser representatives or affiliated or unaffiliated advisory firms in client accounts. In these arrangements, WPIM serves as the investment Strategist and receives a strategist or model fee in connection with the use of its Strategies. This strategist fee is paid by the investment adviser representative and is not charged directly to the client, is not billed to or deducted from client accounts, and does not increase the advisory fee paid by the client to WPIM. Conflicts of Interest – WPIM as Strategist Because WPIM receives a strategist fee when its proprietary Strategies are selected or retained, WPIM has a financial incentive for its Strategies to be used instead of other available investment options, including third-party strategies. This creates a conflict of interest. The Firm addresses this adviser-level conflict through supervision, suitability review, and oversight of strategy selection and implementation to help ensure that investment decisions are made in the client’s best interest. Adviser-Level Conflicts Related to Strategist Fees In these arrangements, the investment adviser representative or advisory firm bears the cost of the strategist fee payable to WPIM. As a result, the adviser has a financial incentive to consider the cost of the strategist fee when selecting, retaining, or replacing investment strategies. This creates an additional conflict of interest. Institutional Intelligent Portfolios® (Schwab) WealthPlan Investment Management LLC Page 12 Form ADV Part 2A: Firm Brochure Clients utilizing Institutional Intelligent Portfolios® (“IIP”) are charged an annual advisory fee by WPIM that will not exceed 1.50% of assets under management. Fees are assessed quarterly in advance based on the value of assets in the account as of the last day of the prior billing period. Fees are negotiable and disclosed in the advisory agreement. Fees are deducted from the client’s account pursuant to client authorization. In limited circumstances, WPIM may invoice the client directly. Fees are pro-rated for partial billing periods as applicable. Clients receive custodian statements reflecting fee deductions and may compare those statements with any invoice provided by WPIM. Held-Away Account Management Fees In certain instances, WPIM manages client assets held away from its primary custodians through third-party platforms. The platform fee is generally 0.25% of assets under management; however, this fee is paid by WPIM and does not result in higher fees to the client compared to assets custodied with WPIM’s recommended custodians. Variable Sub-Account Management Services WPIM provides variable sub-account management services without charging an advisory fee. Clients remain subject to fees charged by the insurance company issuing the variable annuity or variable life fees, sub-account including mortality and expense charges, administrative insurance contract, management fees, exchange fees, and surrender charges. WPIM does not receive or share in these fees. Clients should review the applicable insurance prospectus for details. Termination of Services Asset Management Services, Institutional Intelligent Portfolios®, Variable Sub-Account Management Services, and Held-Away Account Management Services may be terminated by either party for any reason upon 30 days’ written notice, unless otherwise specified in the agreement. Any prepaid but unearned fees are refunded as of the effective termination date. Retirement Plan Services For retirement plan sponsor clients, WPIM charges an annual fee calculated as a percentage of plan assets. Fees generally range from 0.01% to 2.00%, depending on plan size, complexity, services provided, and representative involvement. Fees may be billed quarterly in advance or in arrears, as specified in the agreement. Fees are prorated for partial periods. Clients may elect to have fees deducted from plan assets or billed directly. WPIM does not reasonably expect to receive additional compensation for retirement plan services. If any additional compensation is received, it will be disclosed and offset against stated fees as required. Sponsored Investment Advisory Platforms Clients participating in sponsored investment advisory platforms pay WPIM an annual advisory fee generally ranging from 0.05% to 1.00% of assets managed. Depending on the platform, WPIM’s fee may be charged separately or included in the overall program fee. Fees are calculated and collected by the platform sponsor and remitted to WPIM. WPIM does not participate in platform or sponsor fees. Financial Institution Consulting Services WPIM provides investment consulting services to certain brokerage customers pursuant to written agreements. Consulting fees generally range from 0.19% to 1.50% of assets under management and are calculated quarterly in arrears. Initial fees are paid following completion of one full calendar quarter after execution of the agreement. Private Funds WealthPlan Investment Management LLC Page 13 Form ADV Part 2A: Firm Brochure If a client elects to invest in a private fund recommended by WPIM, the client will incur fees and expenses at the fund level as disclosed in the fund’s offering documents. WPIM does not receive advisory, sub- advisory, management, performance, or other compensation from private funds recommended to clients. Accordingly, no fee offset applies between the client’s advisory fee paid to WPIM and any fund- level fees. Box Spread Liquidity Solution When WPIM facilitates a box spread liquidity transaction, WPIM may receive a structuring or facilitation fee paid directly by the client, either as a flat amount or a percentage of transaction proceeds. This compensation creates a conflict of interest because WPIM has an incentive to recommend the strategy when it results in additional compensation. WPIM manages this conflict by fully disclosing the compensation, obtaining written client consent, and recommending the strategy only when it is determined to be in the client’s best interest based on the client’s financial profile and objectives. Item 6 – Performance-Based Fees and Side-By-Side Management Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation of the assets held in a client’s account. Item 6 is not applicable to this Disclosure Brochure because we do not charge or accept performance-based fees. Item 7 – Types of Clients WealthPlan Investment Management provides investment advice to the following types of clients: Individuals • • High net worth individuals • Pension and profit-sharing plans • Trusts, estates, or charitable organizations • Corporations or business entities other than those listed above • Broker Dealers • Other investment adviser firms You are required to execute a written agreement with WealthPlan Investment Management specifying the particular advisory services in order to establish a client arrangement with WealthPlan Investment Management. Minimum Investment Amounts Required Generally our firm does not have a minimum requirement for our services, however, for the Institutional Intelligent Portfolios®, clients eligible to enroll in the Program include individuals, IRAs, and revocable living trusts. Clients that are organizations (such as corporations and partnerships) or government entities, and clients that are subject to the Employee Retirement Income Security Act of 1974, are not eligible for the Program. The minimum investment required to open an account in the Program is $5,000. The Program Disclosure Brochure describes related minimum required account balances for maintenance of the account, automatic rebalancing, and tax-loss harvesting. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis WealthPlan Investment Management LLC Page 14 Form ADV Part 2A: Firm Brochure Methods of Analysis WPIM uses a combination of qualitative and quantitative investment analysis in managing client portfolios, which may include, among other things: • Fundamental analysis (review of financial statements, issuer fundamentals, and economic conditions); • Quantitative and statistical analysis; • Asset allocation and portfolio construction models; • Risk management and diversification analysis; and • Research, models, or recommendations provided by unaffiliated third-party investment strategists, model providers, or sub-advisers (“Strategists”). Detailed descriptions of specific investment strategies are provided to clients separately and may change over time based on market conditions, client objectives, and portfolio construction considerations. WPIM may rely on information obtained from third-party sources that are believed to be reliable; however, WPIM cannot guarantee the accuracy or completeness of such information. Investment Strategies WPIMs investment strategies vary depending on the services provided and the strategy selected. Strategies can be implemented directly by WPIM or, in certain cases, by unaffiliated Strategists or Sub- Advisers selected and monitored by WPIM. Strategy descriptions may be provided through separate materials or appendices incorporated by reference into the client’s advisory agreement. Strategy availability, composition, and implementation can change over time based on market conditions, client suitability, or changes in available investment options. WPIM may invest client assets in a wide range of securities and instruments, including but not limited to: • Mutual funds and exchange-traded funds (“ETFs”); • Individual equity and fixed income securities; • Cash and cash equivalents; • Options and other derivative instruments; • Managed futures and alternative strategies; and • Securities components of variable annuities and variable life insurance contracts. Use of Third-Party Strategists and Sub-Advisers WPIM may utilize unaffiliated Strategists or Sub-Advisers to assist in implementing certain investment strategies or managing portions of a client’s portfolio. When a Strategist is used, WPIM retains responsibility for selecting, monitoring, and, where applicable, replacing the Strategist. WPIM evaluates Strategists based on factors such as investment philosophy, strategy design, performance history, risk characteristics, and suitability for client objectives. The use of a Strategist does not guarantee performance and may introduce additional risks, including operational and implementation risk. Derivatives and Options Strategies Certain strategies utilized by WPIM involve the use of options and other derivative instruments. These strategies may be used for risk management, income generation, liquidity management, or to capture specific market characteristics. Derivatives can involve complex transactions, embedded leverage, and pricing dynamics that differ from traditional securities. Risks associated with derivatives and options include, but are not limited to, market risk, liquidity risk, volatility risk, pricing risk, execution risk, counterparty risk, and the risk of loss greater than the amount invested in the underlying instrument. Derivative strategies are not suitable for all clients and are implemented only when consistent with a client’s objectives and risk tolerance. Synthetic Financing / Box Spread Strategies For eligible clients, WPIM may facilitate an exchange-traded options strategy commonly referred to as a “box spread.” This strategy is designed to create a synthetic exposure that may allow a client to access liquidity without selling existing investment positions. Box spread transactions are executed on regulated options exchanges and cleared through the Options Clearing Corporation (“OCC”). WPIM does not act as a lender, does not extend credit, and does not engage in margin lending or securities lending through this strategy. Liquidity is provided by unrelated market participants through the options market. While the strategy may have economic characteristics similar to financing, it involves derivatives and is subject to market, execution, counterparty, liquidity, tax, and regulatory risks. The WealthPlan Investment Management LLC Page 15 Form ADV Part 2A: Firm Brochure strategy may not be appropriate for all clients and may result in losses. Private Funds WPIM may recommend private investment funds to eligible clients when consistent with a client’s objectives and financial circumstances. WPIM does not exercise discretionary authority to invest client assets into private funds. Any investment in a private fund requires the client’s affirmative decision to subscribe through execution of the fund’s governing and offering documents, which control the terms of the investment. Private fund investments involve additional risks, including limited liquidity, restrictions on transfers and redemptions, valuation uncertainty, leverage, complex fee structures, reliance on the fund manager or general partner, and limited transparency compared to publicly traded securities. Private funds are generally suitable only for investors who meet applicable eligibility requirements and who can bear the economic risk of a long-term, illiquid investment. Risk of Loss All investment strategies involve risk, and no strategy can guarantee a profit or protect against loss in all market conditions. Market conditions, interest rates, economic events, issuer-specific developments, and other factors may negatively impact portfolio performance. Clients may lose some or all of the value of their investments. Past performance is not indicative of future results. Clients should be prepared to bear the risk of loss and should consider their ability to withstand fluctuations in account value. WPIM encourages clients to promptly notify the firm of any changes in financial condition, objectives, or risk tolerance so that strategies may be reviewed and adjusted as appropriate. • For additional details about private placement offerings and red flags associated with such offerings, please visit http://www.sec.gov/oiea/investor-alerts- bulletins/ib_privateplacements.html#.VDane410yUk. Item 9 – Disciplinary Information We are required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of our advisory business or the integrity of our management. We do not have any required disclosures to add to this Item. Item 10 – Other Financial Industry Activities and Affiliations WealthPlan Investment Management LLC (“WealthPLAN Investment Management” or “WPIM”) is registered as an investment adviser with the United States Securities and Exchange Commission. WPIM is not registered as a broker-dealer, futures commission merchant, commodity pool operator, or commodity trading advisor, and it does not engage in securities underwriting or investment banking activities. Affiliations and Related Entities WPIM is a wholly owned subsidiary of WealthPLAN Group LLC. Certain affiliates under common ownership may be engaged in financial services or related business activities. These relationships may present potential conflicts of interest; however, WPIM seeks to manage such conflicts through disclosure, policies and procedures, and fiduciary oversight. WPIM does not have any affiliated custodians, broker-dealers, or clearing firms. Affiliated Investment Advisers WealthPlan Investment Management, LLC is under common ownership with WealthPlan Partners, LLC, an SEC-registered investment adviser. Both firms are wholly owned subsidiaries of WealthPLAN Group LLC and operate as separate legal entities with separate advisory agreements, compliance programs, and client relationships. Certain investment adviser representatives may be associated with both firms. When an individual is acting WealthPlan Investment Management LLC Form ADV Part 2A: Firm Brochure Page 16 as an investment adviser representative, advisory services are provided solely through the firm with which the client has entered into an advisory agreement. Clients of WealthPlan Investment Management do not automatically become clients of WealthPlan Partners, and vice versa. This affiliation presents potential conflicts of interest, including the incentive for an adviser representative to recommend one advisory platform over another. WealthPlan Investment Management addresses these conflicts through disclosure, supervision, and policies designed to ensure that advisory recommendations are made in the client’s best interest based on the client’s specific circumstances and needs. Investment Adviser Representatives and Outside Business Activities Certain investment adviser representatives (“IARs”) of WPIM may be registered representatives of a broker- dealer and may engage in securities brokerage activities in that capacity. In addition, IARs may engage in other outside business activities, including insurance-related activities or consulting services. When applicable, such activities and the related compensation are disclosed in the individual IAR’s Form ADV Part 2B (Brochure Supplement). When IARs are dually registered or engage in other business activities, conflicts of interest may arise due to differing compensation structures or incentives. WPIM addresses these conflicts through disclosure, supervision, and policies designed to ensure that advisory recommendations are made in the client’s best interest. Private Funds and Pooled Investment Vehicles WPIM or its affiliates may serve as investment adviser or sub-adviser to pooled investment vehicles, including collective investment trusts (“CITs”) and private investment funds. In these roles, WPIM provides portfolio management services pursuant to separate advisory or sub-advisory agreements and does not act as the sponsor, general partner, managing member, or trustee of such vehicles unless otherwise disclosed. WPIM may recommend private investment funds to eligible clients when consistent with the client’s investment objectives and financial circumstances. WPIM does not exercise discretionary authority to invest client assets into any private fund. Any investment in a private fund requires the client’s affirmative decision to subscribe through execution of the fund’s offering and subscription documents, which govern the terms, risks, fees, and liquidity of the investment. WPIM does not receive advisory, sub-advisory, management, performance, or other compensation from private funds recommended to clients. As a result, no fee offset applies between the client’s advisory fee paid to WPIM and any fund-level fees or expenses. Collective Investment Trusts WealthPlan Investment Management serves as a sub-adviser to a collective investment trust (“CIT”) that is available solely to qualified retirement plans. In this capacity, WPIM provides discretionary investment management services to the trustee of the CIT pursuant to a separate sub-advisory agreement. WPIM does not serve as the trustee, sponsor, or administrator of the CIT. Certain retirement plans investing in the CIT may also receive advisory or consulting services from WPIM, which presents a potential conflict of interest. WPIM mitigates this conflict through disclosure, structural safeguards, and by limiting its role in the selection, monitoring, and recommendation of the CIT for plans to which WPIM provides other retirement plan services, as described elsewhere in this brochure. Financial Institution Consulting Services WealthPlan Investment Management provides investment consulting services to certain financial institutions and brokerage customers pursuant to separate written consulting agreements (“Financial Institution Consulting Services”). These services may include investment research, portfolio consulting, or related advisory support and are provided independently of the firm’s retail investment advisory services. Compensation for Financial Institution Consulting Services is paid by the financial institution or brokerage WealthPlan Investment Management LLC Page 17 Form ADV Part 2A: Firm Brochure customer and is disclosed in the applicable consulting agreement. Clients of WealthPlan Investment Management do not pay additional fees as a result of these arrangements, and participation in or availability of Financial Institution Consulting Services does not affect the advisory services provided to retail clients. This activity presents a potential conflict of interest to the extent it could create an incentive to maintain or expand institutional relationships. WealthPlan Investment Management addresses this conflict through disclosure, supervision, and policies designed to ensure that all investment advice provided to clients is based solely on the client’s individual circumstances and best interests. Implementing policies and procedures designed to promote fair and equitable treatment of clients; and Conflicts of Interest and Mitigation WPIM’s roles as an adviser to individual clients and as an adviser or sub-adviser to pooled investment vehicles create potential conflicts of interest, including the incentive to recommend products or strategies with which WPIM has a professional affiliation. WPIM addresses these conflicts by: • Disclosing affiliations and potential conflicts to clients; • Requiring affirmative client consent for investments in private funds; • Conducting suitability reviews before making recommendations; • • Monitoring advisory activities to ensure compliance with fiduciary obligations. Clients are under no obligation to invest in any pooled investment vehicle or strategy recommended by WPIM, and declining to do so will not affect the advisory services provided. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Summary WealthPlan Investment Management, LLC (“WealthPlan Investment Management” or the “Firm”) has adopted a Code of Ethics in compliance with Section 204A of the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The Code of Ethics is designed to reflect the Firm’s fiduciary obligations to its clients and to promote high standards of ethical conduct among all supervised persons. The Code of Ethics addresses, among other things, the Firm’s fiduciary duties, personal securities transactions by supervised persons, the protection of confidential information, and compliance with applicable federal securities laws. A copy of the Code of Ethics is available to clients and prospective clients upon request. Standards of Conduct WealthPlan Investment Management owes a fiduciary duty to its clients and seeks to act at all times in the best interests of clients. Supervised persons are required to conduct themselves in a manner consistent with this duty and must avoid activities, interests, or relationships that might interfere with making decisions in the best interests of clients. The Code of Ethics requires supervised persons to: • Act with honesty, integrity, and professionalism; • Place client interests ahead of their own personal interests; • Avoid conflicts of interest where possible and disclose conflicts when they cannot be avoided; and • Comply with applicable federal securities laws. Personal Securities Transactions The Code of Ethics governs personal securities transactions by supervised persons. Supervised persons are generally permitted to buy or sell securities for their personal accounts, subject to certain restrictions and reporting requirements designed to prevent conflicts of interest and misuse of client information. These requirements include, among other things: • Initial and annual holdings reports; • Quarterly transaction reports; and WealthPlan Investment Management LLC Page 18 Form ADV Part 2A: Firm Brochure • Pre-clearance requirements for certain securities or transactions, as applicable. Supervised persons are prohibited from using material, non-public information obtained in connection with their employment or affiliation with the Firm for personal gain or in a manner that disadvantages clients. Participation or Interest in Client Transactions WealthPlan Investment Management and its supervised persons may buy or sell the same securities that are recommended to or purchased for clients. This creates a potential conflict of interest, as supervised persons could benefit from market activity occurring as a result of client transactions. To address this conflict, the Firm has adopted policies and procedures designed to ensure that: • Client transactions receive priority over personal transactions; and • Personal trading does not disadvantage client accounts. The Firm does not permit supervised persons to engage in trading practices designed to manipulate prices or otherwise unfairly benefit personal accounts at the expense of clients. Allocation of Investment Opportunities When investment opportunities are limited or suitable for more than one client account, WealthPlan Investment Management seeks to allocate such opportunities in a fair and equitable manner consistent with its fiduciary obligations. Allocation decisions are made in accordance with the Firm’s policies and procedures and are intended to treat clients fairly over time. Outside Business Activities and Other Roles Supervised persons may engage in outside business activities, including activities related to financial services, subject to disclosure, review, and approval by the Firm. These activities may include service as an investment adviser representative, consulting activities, or other professional roles. WealthPlan Investment Management reviews outside business activities to identify and manage potential conflicts of interest and to ensure that such activities do not interfere with supervised persons’ duties to clients. Sub-Advisory and Pooled Investment Vehicle Activities WealthPlan Investment Management may serve as a sub-adviser to pooled investment vehicles, including collective investment trusts (“CITs”) and private funds, and may also recommend or allocate client assets to investment strategies managed by unaffiliated third-party sub-advisers. These arrangements present potential conflicts of interest, including incentives related to asset growth, compensation structures, or the selection of investment strategies. The Firm addresses these conflicts through disclosure, due diligence, ongoing monitoring, and supervisory oversight, and by adhering to policies designed to ensure that investment decisions are made in the best interests of clients. Liquidity and Structured Transaction Services In connection with facilitating certain liquidity or structured transactions, including exchange-traded options strategies such as box spreads, the Firm may receive compensation separate from its asset-based advisory fees. This compensation arrangement creates a potential conflict of interest. The Firm manages this conflict through disclosure, client consent where required, and policies designed to ensure that any such recommendation is made in the client’s best interest based on the client’s financial circumstances and objectives. Gifts, Entertainment, and Other Benefits The Code of Ethics contains provisions regarding the receipt and giving of gifts and entertainment. Supervised persons are prohibited from offering or accepting gifts or entertainment that could influence, or appear to influence, the Firm’s investment decisions or recommendations. Gifts and entertainment are subject to reporting and approval requirements in accordance with the Firm’s policies. WealthPlan Investment Management LLC Page 19 Form ADV Part 2A: Firm Brochure Confidentiality and Use of Information Supervised persons are required to maintain the confidentiality of client information and may not disclose or use confidential information except as permitted by law or as necessary to provide advisory services. The Firm has adopted policies designed to safeguard client information and to comply with applicable privacy and data protection requirements. Enforcement and Sanctions Violations of the Code of Ethics may result in disciplinary action, up to and including termination of employment or association with the Firm. The Firm enforces the Code of Ethics through supervision, periodic reviews, and internal compliance monitoring. Availability of the Code of Ethics A copy of the Firm’s Code of Ethics is available to clients and prospective clients upon request. Requests should be directed to WealthPlan Investment Management at the contact information provided in this Disclosure Brochure. Item 12 – Brokerage Practices WealthPlan Investment Management, LLC (“WealthPlan Investment Management” or the “Firm”) has the authority to recommend broker-dealers and custodians to be used for the execution of securities transactions for client accounts. Clients may direct the Firm to use a particular broker-dealer or custodian; however, the Firm reserves the right to decline such direction if it determines that the directed brokerage arrangement would not be in the client’s best interest. The Firm’s primary recommended custodian is Charles Schwab & Co., Inc. (“Schwab”), a registered broker- dealer and member of FINRA and SIPC. The Firm may also recommend or work with other broker-dealers and custodians as appropriate based on the client’s circumstances, account type, or investment strategy. Clients must enter into an agreement directly with the selected broker-dealer or custodian. The broker- dealer or custodian maintains physical custody of client funds and securities and is responsible for executing transactions and providing account statements. Factors Considered in Selecting Broker-Dealers In selecting broker-dealers and custodians, the Firm considers a range of factors, including but not limited to: • Financial strength and stability; • Execution capability and reliability; • Commission and transaction cost structures; • Custody, clearance, and settlement services; • Technology platforms and reporting capabilities; • Responsiveness and quality of service; and • Overall ability to meet the needs of the client. The Firm does not select broker-dealers solely based on commission rates. Rather, the Firm seeks to determine whether the overall relationship represents best execution for the client. Best Execution WealthPlan Investment Management has a duty to seek best execution for client transactions. Best execution does not necessarily mean the lowest possible commission cost but rather execution that the Firm believes to be most favorable under the circumstances, taking into account factors such as price, speed, efficiency, and reliability of execution. The Firm periodically reviews its brokerage arrangements to evaluate execution quality and overall reasonableness. WealthPlan Investment Management LLC Page 20 Form ADV Part 2A: Firm Brochure Soft Dollar Benefits The Firm does not receive research or other benefits in exchange for directing client brokerage transactions (“soft dollars”) within the meaning of Section 28(e) of the Securities Exchange Act of 1934. The Firm does not consider the receipt of soft dollar benefits when selecting broker-dealers for client transactions. Directed Brokerage Clients may request that the Firm direct brokerage transactions to a specific broker-dealer or custodian. Directed brokerage may result in higher transaction costs, less favorable execution, or limitations on the Firm’s ability to aggregate trades. The Firm will inform clients of the potential consequences of directed brokerage arrangements. The Firm may decline to accept directed brokerage arrangements that materially impair its ability to manage the account effectively or to seek best execution. Trade Aggregation and Allocation When appropriate and consistent with client objectives and applicable restrictions, the Firm may aggregate transactions for multiple client accounts to seek more efficient execution or reduced transaction costs. Aggregated trades are allocated among participating accounts in a manner the Firm believes to be fair and equitable over time. Not all accounts are eligible for aggregation, including accounts with directed brokerage arrangements or accounts managed by third-party sub-advisers. Third-Party Sub-Advisers When the Firm selects unaffiliated third-party sub-advisers with discretionary authority, those sub-advisers are responsible for selecting broker-dealers and executing transactions for the portion of client assets they manage, subject to their own best execution obligations and brokerage practices. The Firm conducts due diligence and ongoing monitoring of third-party sub-advisers, including review of their brokerage practices. Institutional Intelligent Portfolios® For clients participating in the Institutional Intelligent Portfolios® program sponsored by Schwab Wealth Investment Advisory, Inc. (“SWIA”), Schwab and its affiliates are responsible for trade execution through an automated investment engine. The Firm does not have discretion to select broker-dealers or negotiate commissions for accounts managed under this program. Clients should refer to the Institutional Intelligent Portfolios® Disclosure Brochure for additional information regarding brokerage and execution practices applicable to the program. Collective Investment Trusts and Private Funds When the Firm serves as a sub-adviser to a collective investment trust (“CIT”) or private fund, brokerage practices are governed by the fund’s governing documents and overseen by the fund sponsor, trustee, or general partner, as applicable. The Firm does not select custodians or broker-dealers for client-level accounts in connection with these pooled investment vehicles unless otherwise disclosed. Liquidity and Structured Transactions In connection with facilitating certain structured liquidity transactions, including exchange-traded options strategies such as box spreads, transactions are executed on regulated options exchanges and cleared through the Options Clearing Corporation (“OCC”). Broker-dealers, clearing firms, and market participants involved in these transactions are independent third parties. The Firm does not act as a lender and does not custody client assets in connection with these transactions. Brokerage for Retirement Plan Accounts WealthPlan Investment Management LLC Page 21 Form ADV Part 2A: Firm Brochure For retirement plan accounts, brokerage arrangements are governed by the plan’s governing documents and the applicable service agreements. When acting as an ERISA Section 3(38) investment manager or providing discretionary investment management services, the Firm may have authority to select broker- dealers for plan assets, subject to applicable fiduciary standards. Brokerage Compensation WealthPlan Investment Management does not receive any portion of brokerage commissions or transaction fees charged by broker-dealers or custodians. Clients bear brokerage commissions, transaction fees, and other charges imposed by broker-dealers, custodians, or third parties in connection with transactions in their accounts. Conflicts of Interest The Firm’s brokerage practices may present conflicts of interest, including incentives to recommend custodians that provide favorable service, technology, or operational support. The Firm addresses these conflicts through disclosure, supervision, and policies designed to ensure that brokerage decisions are made in the best interests of clients. Summary Brokerage practices are an important component of the Firm’s fiduciary obligations. WealthPlan Investment Management seeks to implement brokerage arrangements that are reasonable, transparent, and consistent with its duty to seek best execution for clients. Item 13 – Review of Accounts Periodic Reviews WealthPlan Investment Management, LLC (“WealthPlan Investment Management” or the “Firm”) provides ongoing investment advisory services to clients on either a discretionary or non-discretionary basis, as specified in the applicable advisory agreement. Accounts are reviewed on a regular and ongoing basis consistent with the nature of the services provided and the client’s investment objectives. Reviews are conducted to evaluate, among other things: • Asset allocation and investment strategy alignment; • Performance relative to objectives and appropriate benchmarks; • Risk exposure and portfolio composition; and • Consistency with client-imposed restrictions or mandates. The frequency of reviews may vary based on factors such as account size, investment strategy, market conditions, client circumstances, and whether the account is managed using internal strategies, third-party sub-advisers, or automated platforms. Triggering Events In addition to periodic reviews, accounts may be reviewed in response to material changes, including but not limited to: • Changes in a client’s financial situation, investment objectives, or risk tolerance; • Significant market or economic events; • Client-initiated requests for review or changes to account restrictions; or • Changes in the composition, performance, or availability of investment strategies or third-party sub- advisers. Clients are encouraged to notify the Firm promptly of any material changes that may affect their investment objectives or circumstances. Third-Party Sub-Advisers For accounts or portions of accounts managed by unaffiliated third-party sub-advisers, WealthPlan WealthPlan Investment Management LLC Page 22 Form ADV Part 2A: Firm Brochure Investment Management conducts ongoing monitoring of the sub-adviser’s performance, investment process, and adherence to stated strategies. Reviews of third-party sub-advisers may include: • Performance evaluation relative to benchmarks and peers; • Qualitative assessment of investment philosophy and process; • Review of material changes to personnel, ownership, or operations; and • Compliance and risk considerations. While third-party sub-advisers may have discretionary authority over designated assets, WealthPlan Investment Management retains responsibility for oversight and for determining whether continued use of a sub-adviser remains appropriate for the client. Institutional Intelligent Portfolios® For clients participating in the Institutional Intelligent Portfolios® program, portfolio reviews are conducted in accordance with the program’s structure. Portfolios are managed using an automated investment engine that performs ongoing monitoring, rebalancing, and tax-loss harvesting (if applicable). WealthPlan Investment Management reviews client accounts within the program periodically to confirm continued suitability of the selected investment strategy and alignment with the client’s objectives, taking into account changes communicated by the client. Retirement Plan Accounts For retirement plan clients, account reviews are conducted in accordance with the scope of services provided, which may include discretionary management, fiduciary consulting, or non-fiduciary services. Reviews may involve evaluation of plan investment options, model portfolios, or designated assets, as applicable. The frequency and nature of reviews for retirement plan accounts are governed by the applicable service agreement and may include periodic meetings, performance reporting, and monitoring of investment options relative to plan objectives and benchmarks. Held-Away Accounts For held-away accounts managed through third-party platforms, account reviews are conducted based on information made available through the platform. The Firm’s ability to review and monitor such accounts may be limited by the access and data provided by the platform or plan sponsor. Reports and Communications Clients typically receive account statements directly from the qualified custodian at least quarterly. In addition, WealthPlan Investment Management may provide clients with periodic performance reports or summaries, either electronically or in written form, depending on the services provided and the client’s preferences. Performance reports, when provided, are generally prepared using information supplied by custodians, third-party platforms, or other service providers. Clients are encouraged to review custodian statements carefully and to promptly notify the Firm of any discrepancies. Investment Management’s Review Responsibility Account reviews are conducted by WealthPlan investment adviser representatives and/or investment management personnel. The specific individuals responsible for account reviews may vary depending on the nature of the account, the services provided, and internal supervisory assignments. Item 14 – Client Referrals and Other Compensation Referral Arrangements WealthPlan Investment Management LLC Page 23 Form ADV Part 2A: Firm Brochure WealthPlan Investment Management, LLC (“WealthPlan Investment Management” or the “Firm”) does not compensate unaffiliated third parties for client referrals, nor does the Firm receive compensation for referring clients to unaffiliated advisers, broker-dealers, or other service providers, unless otherwise disclosed in this brochure. To the extent the Firm enters into any referral arrangements subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), such arrangements will comply with the requirements of the SEC’s Marketing Rule, including disclosure and, where applicable, written agreements. Custodian and Platform Support The Firm recommends Charles Schwab & Co., Inc. (“Schwab”) as its primary custodian. Schwab provides custody, execution, clearing, and reporting services for client accounts. Schwab may also provide the Firm with access to technology, practice management resources, and educational materials designed to support the Firm’s advisory business. These services may benefit the Firm and its supervised persons but are not provided as compensation for referrals or for directing client transactions to Schwab. Clients do not pay higher advisory fees as a result of these arrangements, and the Firm does not receive cash payments from Schwab in connection with client referrals. Institutional Intelligent Portfolios® For clients participating in the Institutional Intelligent Portfolios® program sponsored by Schwab Wealth Investment Advisory, Inc. (“SWIA”), Schwab and its affiliates provide technology and administrative services that facilitate the operation of the program. The Firm does not receive referral fees or other compensation from Schwab or SWIA in connection with client participation in the program. Clients should refer to the Institutional Intelligent Portfolios® Disclosure Brochure for additional information regarding compensation and platform arrangements related to the program. Third-Party Sub-Advisers WealthPlan Investment Management may engage unaffiliated third-party sub-advisers to manage client assets or portions of client assets. Sub-advisers are compensated from the advisory fee charged by the Firm or directly by the client, as disclosed in the applicable advisory agreement and sub-adviser disclosures. The Firm does not receive compensation from sub-advisers in connection with selecting or recommending their services. To the extent compensation arrangements create potential conflicts of interest, such conflicts are disclosed and managed through policies and procedures designed to ensure that investment decisions are made in the best interests of clients. Financial Institution Consulting Services WealthPlan Investment Management provides investment consulting services to certain broker-dealers and financial institutions pursuant to separate consulting agreements. Compensation for these services is paid by the financial institution or brokerage customer and is not contingent upon the referral of retail advisory clients to the Firm. These arrangements present a potential conflict of interest to the extent they could create incentives to maintain or expand institutional relationships. The Firm addresses this conflict through disclosure, supervision, and policies designed to ensure that advisory recommendations to retail clients are not influenced by institutional consulting relationships. Liquidity and Structured Transaction Compensation In connection with facilitating certain liquidity or structured transactions, including exchange-traded options strategies such as box spreads, the Firm may receive compensation in the form of structuring or facilitation fees paid directly by clients. The Firm does not act as a lender and does not receive compensation from lending counterparties or market participants in connection with these transactions. WealthPlan Investment Management LLC Page 24 Form ADV Part 2A: Firm Brochure This compensation arrangement creates a potential conflict of interest because the Firm has a financial incentive to recommend transactions that result in additional compensation. The Firm manages this conflict through disclosure, client consent where required, and policies designed to ensure that any recommendation is made in the client’s best interest. Collective Investment Trusts and Private Funds When the Firm serves as a sub-adviser to collective investment trusts (“CITs”) or private funds, compensation is paid pursuant to the governing documents of the pooled investment vehicle. The Firm does not receive referral compensation in connection with client investments in such vehicles. Any potential conflicts of interest associated with these arrangements, including those related to asset growth or compensation structures, are disclosed and managed through supervision, structural safeguards, and policies designed to protect client interests. Marketing Rule Compliance Any testimonials, endorsements, or third-party ratings used by the Firm in marketing materials will comply with the SEC’s Marketing Rule. Required disclosures will be provided, and any compensation arrangements related to such marketing activities will be disclosed as required. WealthPlan Investment Management LLC Page 25 Form ADV Part 2A: Firm Brochure Item 15 – Custody Deduction of Advisory Fees: WealthPlan Investment Management, LLC (“WealthPlan Investment Management” or the “Firm”) does not maintain custody of client funds or securities, except as described below. Client assets are maintained by independent qualified custodians selected by the client or recommended by the Firm. Qualified Custodians Client funds and securities are held at qualified custodians, such as Charles Schwab & Co., Inc. (“Schwab”), which are registered broker-dealers and members of FINRA and SIPC. Clients receive account statements directly from the qualified custodian at least quarterly. These statements reflect all transactions, holdings, and account balances. Clients are encouraged to review custodian statements carefully and to promptly notify the Firm of any discrepancies. Fee Deduction Authority The Firm is deemed to have custody of client funds solely because it is authorized to deduct advisory fees directly from client accounts. This limited authority is obtained pursuant to written authorization from the client. To mitigate the risks associated with fee-deduction custody: • The qualified custodian sends account statements directly to clients at least quarterly; • Clients provide written authorization permitting fee deductions; • The Firm provides clients with an invoice or fee calculation showing the amount of the fee deducted; and • The Firm includes a legend encouraging clients to compare the fee invoice with custodian statements. The Firm does not take physical possession of client funds or securities. Third-Party Sub-Advisers When unaffiliated third-party sub-advisers are engaged with discretionary authority, those sub-advisers do not have custody of client assets. Client assets remain held at the qualified custodian selected by the client. Sub-advisers may be authorized to place trades but do not have authority to withdraw or transfer client funds or securities. Retirement Plan Accounts For retirement plan clients, plan assets are held by plan custodians or trustees selected by the plan sponsor. WealthPlan Investment Management LLC Page 26 Form ADV Part 2A: Firm Brochure When the Firm acts as an ERISA Section 3(38) investment manager or provides discretionary investment management services, the Firm may have authority to direct investment transactions but does not have authority to withdraw or disburse plan assets except for authorized fee payments. Institutional Intelligent Portfolios® For clients participating in the Institutional Intelligent Portfolios® program sponsored by Schwab Wealth Investment Advisory, Inc. (“SWIA”), client assets are held at Schwab. Trading is executed through an automated investment engine administered by SWIA. The Firm does not have custody of client assets and does not have authority to withdraw or transfer client funds or securities beyond authorized advisory fee deductions, if applicable. Collective Investment Trusts and Private Funds When the Firm serves as a sub-adviser to collective investment trusts (“CITs”) or private funds, custody of fund assets is maintained by the trustee, custodian, or prime broker designated by the pooled investment vehicle. The Firm does not have authority to withdraw or disburse assets of the pooled investment vehicle. Any authority exercised by the Firm with respect to pooled investment vehicles is limited to discretionary investment management pursuant to the applicable sub-advisory agreement. Standing Letters of Authorization (SLOAs) To the extent the Firm accepts standing letters of authorization (“SLOAs”) that permit third-party transfers of client funds, such arrangements are administered in accordance with SEC guidance and do not result in the Firm having custody of client assets, provided the Firm complies with applicable safeguards, including client authorization and custodian verification. No Access to Client Credentials The Firm does not maintain possession of client login credentials or other information that would allow the Firm to access or withdraw client funds directly from custodial accounts, except as permitted for limited trading or fee-deduction authority. WealthPlan Investment Management LLC Page 27 Form ADV Part 2A: Firm Brochure Item 16 – Investment Discretion WealthPlan Investment Management, LLC (“WealthPlan Investment Management” or the “Firm”) provides investment advisory services on both a discretionary and non-discretionary basis, as specified in the applicable advisory agreement with each client. Discretionary Authority When clients grant discretionary authority, WealthPlan Investment Management has the authority to determine the specific securities to be bought or sold, the quantity of securities to be purchased or sold, and the timing of transactions without obtaining prior client approval for each transaction. Discretionary authority is granted by the client through a written advisory agreement and, where applicable, separate custodial or platform documentation. Clients may impose reasonable restrictions on discretionary authority, which must be provided to the Firm in writing and accepted by the Firm. Discretionary authority may include, but is not limited to: • Selecting, purchasing, selling, or holding securities; • Rebalancing portfolios; • Allocating assets among investment strategies or models; and • Selecting and terminating third-party sub-advisers or investment strategies, where authorized. Discretionary authority does not include the authority to subscribe client assets to private funds or other pooled investment vehicles, which require affirmative client consent and separate documentation. Non-Discretionary Authority For accounts managed on a non-discretionary basis, WealthPlan Investment Management provides investment recommendations, but the client retains final decision-making authority over all investment transactions. Transactions are executed only after client approval. Third-Party Sub-Advisers When authorized by the client, WealthPlan Investment Management may select unaffiliated third-party sub- advisers to manage all or a portion of a client’s account. In these arrangements: • WealthPlan Investment Management may have discretion to hire, monitor, and terminate sub- advisers without obtaining client consent for each change; • Sub-advisers may have discretionary authority to manage designated assets within the account; and • WealthPlan Investment Management retains responsibility for oversight, due diligence, and ongoing monitoring of the sub-adviser. The scope of discretionary authority related to sub-advisers is described in the client’s advisory agreement and applicable disclosures. Model-Based and Platform-Managed Accounts For accounts managed using model portfolios, automated investment platforms, or sponsored advisory programs, discretionary authority is exercised in accordance with the structure of the applicable program. For clients participating in the Institutional Intelligent Portfolios® program sponsored by Schwab Wealth Investment Advisory, Inc. (“SWIA”), discretionary authority over portfolio construction and ongoing rebalancing is exercised through an automated investment engine administered by SWIA. WealthPlan Investment Management retains discretion to select the appropriate investment strategy for the client and to make changes to the selected strategy based on the client’s objectives and circumstances. Retirement Plan Accounts For retirement plan clients, discretionary authority is exercised in accordance with the scope of services WealthPlan Investment Management LLC Form ADV Part 2A: Firm Brochure Page 28 elected by the plan sponsor. When acting as an ERISA Section 3(38) investment manager, WealthPlan Investment Management has discretionary authority over plan investments as specified in the applicable service agreement. For non-discretionary retirement plan consulting engagements, WealthPlan Investment Management provides investment recommendations only, and the plan sponsor or fiduciary retains ultimate decision- making authority. Collective Investment Trusts and Private Funds When serving as a sub-adviser to collective investment trusts (“CITs”) or private funds, WealthPlan Investment Management exercises discretionary investment authority over the assets of the pooled investment vehicle in accordance with the governing documents of the fund and the applicable sub-advisory agreement. This authority does not extend to custody, disbursement, or administrative functions of the pooled investment vehicle. Client Limitations and Restrictions Clients may place reasonable restrictions on the management of their accounts, including restrictions on certain securities, asset classes, or strategies. The Firm must acknowledge and agree to such restrictions in writing. Item 17 – Voting Client Securities WealthPlan Investment Management, LLC (“WealthPlan Investment Management” or the “Firm”) does not vote proxies on behalf of individual advisory clients. Clients retain the right and responsibility to vote proxies for securities held in their accounts. Proxies are generally delivered directly to clients by the account custodian, issuer, or transfer agent. The Firm does not provide proxy voting services for client accounts and does not maintain proxy voting authority over client- held securities. No Client Proxy Voting Policies Because the Firm does not vote proxies for client accounts, it has not adopted proxy voting policies or procedures applicable to client accounts, and clients may not delegate proxy voting authority to the Firm. Collective Investment Trust Proxy Voting In its capacity as a sub-adviser to a collective investment trust (“CIT”), WealthPlan Investment Management may participate in proxy voting for securities held by the CIT, as authorized under the governing documents of the trust and the applicable sub-advisory agreement. Proxy voting for the CIT is conducted solely at the pooled-vehicle level and is separate from, and unrelated to, any proxy voting rights associated with individual client accounts. Proxy voting authority for the CIT does not extend to underlying plan participants or advisory clients. Third-Party Sub-Advisers and Platforms For accounts or investment strategies managed by unaffiliated third-party sub-advisers, platforms, or sponsored programs (including Institutional Intelligent Portfolios®), proxy voting authority is governed by the applicable agreements and disclosures of those programs. WealthPlan Investment Management does not exercise proxy voting authority for client accounts in these arrangements. Retirement Plan Accounts For retirement plan clients, proxy voting authority is governed by the plan’s governing documents and service agreements. WealthPlan Investment Management does not vote proxies for retirement plan assets unless acting solely within a pooled investment vehicle (such as a CIT) and expressly authorized to do so WealthPlan Investment Management LLC Page 29 Form ADV Part 2A: Firm Brochure under the fund’s governing documents. Class Action Claims In October of 2023, we began offering class action litigation monitoring and securities claim filing services through an independent third party, Chicago Clearing Corporation ("CCC"). You are included in this service unless you choose to opt out. You may change your opt-out election at any time by notifying us in writing. If you participate in this service, CCC will retain 15% of each claim recovery you receive. We have the right to change the provider of this service. If we do, we will notify you and send you another opt-out election form. Because we provide this service through CCC, we no longer monitor class action suits or process claim forms on your behalf (whether you participate in the service CCC provides or not). We are not responsible or liable for: (a) any assistance we provide to CCC concerning monitoring or processing class action claims or (b) any CCC act in monitoring or processing such claims. Item 18 – Financial Information Financial Condition WealthPlan Investment Management, LLC (“WealthPlan Investment Management” or the “Firm”) does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. The Firm maintains adequate financial resources to fulfill its obligations to clients and to operate its advisory business in a manner consistent with applicable regulatory requirements. Bankruptcy WealthPlan Investment Management has not been the subject of a bankruptcy petition during the past ten (10) years. Advance Fee Practices Certain advisory services provided by WealthPlan Investment Management may involve the payment of fees in advance of services being rendered, including asset-based advisory fees billed quarterly in advance and fixed or flat fees for financial planning or consulting services. To the extent required by applicable regulations, advance fees are subject to the following safeguards: • Fees billed in advance are disclosed in the applicable advisory agreement; • Fees are calculated based on agreed-upon terms and account values, where applicable; • Clients may terminate the advisory agreement in accordance with its terms; and • Any unearned fees are promptly refunded upon termination of the advisory relationship. The Firm does not require prepayment of advisory fees in excess of amounts permitted under applicable federal and state regulations. No Balance Sheet Delivery Required Because WealthPlan Investment Management does not require prepayment of advisory fees in excess of $1,200 more than six months in advance, and does not otherwise meet the conditions requiring delivery of a balance sheet under Form ADV Part 2A, the Firm is not required to deliver a balance sheet to clients. WealthPlan Investment Management LLC Page 30 Form ADV Part 2A: Firm Brochure