Weinberger Asset Management, Inc.

Weinberger Asset Management, Inc. Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Weinberger Asset Management, Inc. If you have any questions about the contents of this brochure, please contact us at (310) 442- 8472 or by email at: aweinberger@wamasset.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Weinberger Asset Management, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Weinberger Asset Management, Inc.’s CRD number is 106176. Item 1: Cover Page 10866 Wilshire Blvd, Ste 830 Los Angeles, CA 90024 (310) 442-8472 aweinberger@wamasset.com https://www.wamasset.com Registration does not imply a certain level of skill or training. Version Date: 03/20/2026 1  Item 2: Material Changes Material changes relate to Weinberger Asset Management, Inc.’s policies, practices, or conflicts of interest only. The following material changes have been made to this brochure since the last annual updating amendment filed on March 25, 2025:  On 05/01/2025, we changed our address from 11661 San Vicente Boulevard, Suite 820, Los Angeles, CA 90049 to 10866 Wilshire Blvd, Ste 830, Los Angeles, CA 90024. All other contact information remains the same.  The content of this brochure has been amended to remove duplicative information and sub- headers and to clarify and consolidate disclosures. Other than our address change noted above, there were no material changes made to this brochure. We encourage you to review our entire ADV brochure for important information. If you have any questions or if you would like to receive a copy of our current brochure free of charge at any time, contact us at (310) 442-8472 or aweinberger@wamasset.com. 2  Item 3: Table of Contents Item 1: Cover Page ........................................................................................................................................................................1 Item 2: Material Changes .............................................................................................................................................................2 Item 3: Table of Contents ............................................................................................................................................................3 Item 4: Advisory Business ...........................................................................................................................................................4 Item 5: Fees and Compensation ..................................................................................................................................................7 Item 6: Performance-Based Fees and Side-By-Side Management .......................................................................................8 Item 7: Types of Clients ...............................................................................................................................................................9 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ........................................................9 Item 9: Disciplinary Information ............................................................................................................................................. 12 Item 10: Other Financial Industry Activities and Affiliations ........................................................................................... 12 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................ 12 Item 12: Brokerage/Custodian Practices ................................................................................................................................. 13 Item 13: Reviews of Accounts ................................................................................................................................................... 14 Item 14: Client Referrals and Other Compensation ............................................................................................................. 14 Item 15: Custody .......................................................................................................................................................................... 15 Item 16: Investment Discretion ................................................................................................................................................ 15 Item 17: Voting Client Securities (Proxy Voting) .................................................................................................................. 15 Item 18: Financial Information ................................................................................................................................................. 16 3  Item 4: Advisory Business Weinberger Asset Management, Inc. (hereinafter “WAM”) is a corporation organized in the State of California. The firm was formed in November 1993, and the principal owner is Alexander Weinberger, President & Chief Compliance Officer. Portfolio Management Services WAM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. WAM meets with the client to gather information regarding the client’s current situation (income, tax levels, risk tolerance levels, etc.) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: Investment strategy   Asset allocation  Risk tolerance determination  Asset selection  Regular portfolio monitoring WAM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. WAM will request discretionary authority from clients to select securities and execute transactions without permission from the client prior to each transaction. WAM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of WAM’s economic, investment or other financial interests. To meet its fiduciary obligations, WAM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, WAM’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is WAM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Use of Other Advisers As part of our overall portfolio management services, from time to time, we may recommend that clients use the services of one or more unaffiliated, independent third-party managers (“sub-advisers”) to manage clients’ investment portfolios. Some or all of the assets in the client’s account(s) may be managed using one or more model portfolios developed by these sub-advisers. All sub-advisers recommended by our firm must either be registered as investment advisers or exempt from registration requirements in the jurisdiction in which the client resides. When recommending a particular sub-adviser, model portfolio, or program, the client's best interest will be the main determining factor. Other factors that we take into consideration include, but are not limited to, the sub-adviser’s performance history, methods of analysis, fees, the client’s financial needs, investment goals, risk tolerance, and investment objectives. 4  We will regularly monitor the sub-adviser’s performance to ensure their management and investment style remains aligned with the client’s investment goals and objectives. In some cases, the client may be required to execute a separate advisory agreement or trading authorization with the sub-adviser. Additionally, we have engaged another investment adviser at our expense to assist us with back-office services, including placing trades through the account custodian based on our allocation instructions. In such cases, the client will not pay additional fees for these back-office services. Retirement Plan Services WAM offers services to sponsors of defined benefit or defined contribution plans based upon the plan’s specific needs and negotiated between the plan sponsor and WAM. Such services may include one or more of the following services as agreed upon between the plan sponsor and WAM.  Plan Level Ongoing Services offered on a discretionary basis (ERISA 3(38) Services) include preparation of an investment policy statement (IPS), discretionary investment management, selection of a qualified default investment alternative (QDIA), performance monitoring and reporting of investments, education services to plan fiduciaries, counseling services to plan fiduciaries on increasing participant retirement readiness, participant investment education services, participant enrollment services, concierge services, requests for proposals/plan vendor search, benchmarking services, and/or assistance in identifying plan fees.  Plan Level Ongoing Services offered on a non-discretionary basis (ERISA 3(21) Services) include advice regarding development of an investment policy statement (IPS), non-discretionary investment advice to the plan, non-discretionary advice on a qualified default investment alternative (QDIA), education services to plan fiduciaries, counseling services to plan fiduciaries on increasing participant retirement readiness, participant investment education services, participant enrollment services, concierge services, requests for proposals/plan vendor search, benchmarking services, and/or assistance in identifying plan fees.  Participant Level Ongoing Services offered include individualized investment adviser for plan participants as agreed upon by between the plan sponsor and WAM. IRA Rollover Considerations As a normal extension of financial advice, we provide education or recommendations related to the rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and retirement plans. The complexity of these choices may lead an investor to seek assistance from us. An Associated Person who recommends a rollover of plan assets into an Individual Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and expenses will increase for the investor as a result because our advisory fee will apply to assets rolled over to an IRA, and outlined ongoing services will be extended to these assets. 5  Written Acknowledgement of Fiduciary Status 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 and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. 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. Client-Imposed Investment Restrictions We consider liquidity needs and other client-specific needs. We tailor our advisory services to individual client needs. Consistent with this approach, clients may restrict both certain types of investments and investments in certain types of securities. If the restrictions prevent WAM or a recommended sub- adviser from properly servicing the client account, or if the restrictions would require WAM to deviate from its standard suite of services, WAM reserves the right to end the relationship Regulatory Assets Under Management As of February 9, 2026, WAM managed $503,567,038 of client assets on a discretionary basis. 6  Item 5: Fees and Compensation Portfolio Management Fees ANNUAL FEE AGGREGATE VALUE OF ASSETS UNDER MANAGEMENT On the first $1,000,000 1.25% On the next $1,000,0001 – $2,500,000 1.00% On the next $2,500,001 – $5,000,000 0.80% On the next $5,000,001 – $10,000,000 0.70% On the next 10,000,001 – $25,000,000 0.60% On amounts of $25,000,001 or more 0.50% WAM’s fees are generally negotiable based on the above-tiered fee schedule. Other arrangements may be negotiated such as a flat annual percentage across all assets under management. The advisory fee is payable quarterly in advance and is calculated using the market value of the assets in the account as of the last business day of the prior billing period, with payment collected within ten (10) days after the end of each quarter. Fees are withdrawn directly from the client's accounts with client's written authorization. Notwithstanding the foregoing, advisory fees for the initial period shall be collected in arrears, calculated using the market value of the Account as of the last business day of the initial billing period. The initial period fee may be waived at WAM’s discretion. WAM relies upon the custodian’s calculation of the market value of the account for purposes of calculating all advisory fees due. The agreed-upon fee schedule will be set forth in the Investment Advisory Agreement executed between the client and WAM. The client shall have five (5) business days from the effective date of the Investment Advisory Agreement to terminate the Agreement (on written notice delivered to WAM) without incurring any advisory fees or penalties of any kind. Otherwise, either party may terminate the Investment Advisory Agreement upon ten (10) days prior written notice to the other party. WAM may elect, in its sole discretion, to combine the account values of the client and the client’s family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for the client and the client’s minor children, joint accounts with the client’s spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in the client paying a reduced advisory fee based on the available breakpoints in the above-stated fee schedule. Billing on Cash Positions The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time, such positions could miss market advances and, depending upon current yields, the firm’s advisory fee could exceed the interest paid by the client’s cash or cash equivalent positions. 7  Periods of Portfolio Inactivity The firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply during these periods, and there can be no assurance that investment decisions made by the firm will be profitable or equal any specific performance level(s). Sub-Advisory Fees Typically, the fees charged by sub-advisers are not negotiable and will be separate and distinct from our fees. We do not share in the fee charged by sub-advisers. Fees greater than 2.5% are considered to exceed industry standards; therefore, in no case will the total combined annual advisory fee paid to us and paid to a sub-adviser exceed 2.5% of assets under management. Fees will be pro-rated for any partial billing period. The custodian holding the client’s account will deduct our fees, the sub-adviser’s fees, and any other custodial fees directly from the client’s designated account, provided the client has granted written authorization for the direct deduction. Generally, sub-advisory fees are due quarterly, in advance or arrears, depending on the sub-adviser selected. Upon termination of the selected sub-adviser, any pre- paid, unearned fees will be prorated and refunded to the client promptly. Any fees accrued but not yet assessed to the account will be assessed through the termination date and billed accordingly. The custodian will not determine whether the fee is properly calculated. It is your responsibility to verify the accuracy of the fee calculation. In some cases, the custodian will deduct the fee based on the sub- advisory agreement. In all cases, the custodian will provide the client with a statement, at least quarterly, indicating all amounts dispersed from the account, including the amount of the advisory fees paid. We will also receive a copy of your account statements from the custodian. Clients are encouraged to review all statements for accuracy. If you have a question or if you did not receive an expected statement, please contact us or the account custodian immediately. Other Fees and Expenses Clients are responsible for the payment of all third-party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees charged by WAM. Please see Item 12 of this brochure regarding broker-dealer/custodian. To fully understand the total cost the client will incur, clients should review all the fees charged by mutual funds, exchange traded funds, us, sub-advisers, and others. Item 6: Performance-Based Fees and Side-By-Side Management WAM does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 8  Item 7: Types of Clients WAM generally provides advisory services to the following types of clients:  Individuals  High-Net-Worth Individuals  Pension and Profit-Sharing Plans  Charitable Organizations  Corporations or Business Entities There is no account minimum for any of WAM’s services. Certain model portfolios and accounts managed by sub-advisers may be subject to different minimum investment requirements; therefore, participation in some models or platforms may be limited to clients who meet those minimum requirements. We will only recommend sub-advisers and/or investments for which the client meets any minimum requirements. Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Methods of Analysis, Investment Strategies, and Associated Risks WAM’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis, and Technical analysis. Charting analysis involves the use of patterns in performance charts. WAM uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. The risk involved in using this method is that only past performance data is considered, and past performance may not be indicative of future results. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. The risks with this strategy are two-fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes investors can optimize a portfolio by balancing expected return and risk through diversification—seeking the highest return for a given risk (or the lowest risk for a given 9  return). Risks include that results can be unreliable because they depend heavily on historical inputs and assumptions (e.g., stable correlations and normally distributed returns), which may break down in real markets—especially during periods of stress—leading to underestimation of downside risk and overly confident allocations. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis involves the analysis of past market data: primarily price and volume. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. General Investment Risks Cybersecurity Risks: Our firm and our service providers face cybersecurity breach risks, including deliberate attacks or unintentional events that can disrupt systems, corrupt or steal data, and misappropriate confidential information. A breach may interfere with transaction processing, valuation calculations, or trading, potentially causing client losses. Clients may also incur significant costs (e.g., forensic investigations, enhanced security, identity theft, unauthorized use or disclosure of information, and litigation). Any breach could subject our firm to civil liability and regulatory inquiries or action, and could expose clients to losses from misuse of their personal information. Although we maintain business continuity and security measures, no system can eliminate all risks or identify every threat. Similar cyber risks may also affect issuers, investment companies, and other advisers in which clients invest, which could adversely impact their value and a client’s investment. Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety of factors including the global response of regulators and governments to address and mitigate the worldwide effects of such events. Workforce reductions, travel restrictions, governmental responses and policies, and macroeconomic factors could negatively impact investment returns. Risks Associated with Specific Security Types Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. 10  Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions, and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt, and structured products, such as mortgage and other asset-backed securities, although individual bonds are most common. Fixed income markets can be volatile and are subject to interest rate risk (bond prices typically fall as rates rise), inflation risk, liquidity risk, call risk, and credit and default risk for issuers and counterparties. Treasury inflation-protected securities have minimal default risk but may still experience price declines. Foreign fixed income investments also carry additional risks associated with non-U.S. markets. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, like stocks. ETFs can include, but are not limited to, real estate funds (including REITs), precious metals ETFs, options hedged investments, digital asset ETFs. Note that WAM does not recommend investment in digital assets, but will accommodate a client’s request via ETF if requested. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest, and the possibility of inadequate regulatory compliance. Environmental, Social, and Governance Investment Criteria Risks: If a portfolio applies environmental, social, and governance (ESG) criteria, it may forgo buying securities that appear economically attractive or sell securities that may otherwise be advantageous to hold in order to meet ESG objectives. Applying ESG criteria may also change the portfolio’s exposure to certain issuers, industries, sectors, or regions, which can help or hurt performance depending on what is in or out of favor. ESG approaches and screening methodologies vary widely among advisers, so one adviser’s ESG conclusions may differ from—or conflict with—those of other ESG evaluators. In addition, ESG analysis relies on issuer and third-party data that may be subjective, incomplete, unverified, or otherwise unreliable. Selection of Other Advisers As discussed in Item 4 of this brochure, WAM may recommend the use of one or more sub-advisers in the management of a client’s account. The primary risk associated with using sub-advisers is that while a particular sub-adviser may have demonstrated a certain level of success in the past; it may not be able to replicate that success in future markets. In addition, there is also a risk that a sub-adviser may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. To mitigate this risk, we seek sub-advisers with proven track records that have demonstrated a consistent level of performance and success over time and we regularly monitor each sub-adviser’s adherence to the desired investment strategy(ies) or model(s) chosen for a client’s account and the continued suitability of the selected investment strategy(ies) or model(s) for each client. A sub-adviser’s past performance is not a guarantee of future results and certain market and economic risks exist that may adversely affect an account’s performance that could result in capital losses in your account. 11  Item 9: Disciplinary Information WAM does not have any reportable disciplinary events. Item 10: Other Financial Industry Activities and Affiliations Marriage Financial Solutions LLC (MFS) is under common control with WAM. MFS provides guidance to individuals navigating transitional marital issues, such as divorce and death of a spouse. Advice is financial in nature, and may include discussions regarding savings and expense management; however, it does not involve advice regarding securities or the advisability of investing in securities. MFS may recommend the services of WAM to its clients if such services are appropriate for the client. This creates a conflict of interest, as the owners of WAM will benefit based on the compensation the client pays to MFS for such services. Clients of MFS are under no obligation to use services of WAM. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading WAM has adopted a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. WAM's Code of Ethics is available free of charge upon request to any client or prospective client. WAM does not recommend that clients buy or sell any security in which a related person to WAM or WAM has a material financial interest. From time to time, representatives of WAM may buy or sell securities for themselves that they also recommend or trade on behalf of clients. This may provide an opportunity for representatives of WAM to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. WAM will always document any transactions that could be construed as conflicts of interest and will never engage place the interest of WAM or its representatives ahead of those of its clients. Although they would not necessarily be aware of the timing of trades being considered by the sub- adviser prior to the transaction being placed by the sub-adviser, this could be considered a conflict of interest with clients. Where WAM or any persons associated with WAM are aware that the sub-adviser is considering specific transactions for client accounts on a specific trading day where there is a potential material conflict, they will ensure that client interests are placed ahead of those of WAM and of its representatives. 12  Item 12: Brokerage/Custodian Practices Custodians/broker-dealers will be recommended based on WAM’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and WAM may also consider the market expertise and research access provided by the broker-dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in WAM's research efforts. WAM will never charge a premium or commission on transactions, though clients may be assessed costs imposed by the broker-dealer/custodian. WAM recommends Schwab Institutional, a division of Charles Schwab & Co., Inc. Research and Other Soft-Dollar Benefits While WAM has not entered into any formal soft dollar program in which soft dollars are used to pay for third-party services, WAM may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and WAM does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. WAM benefits by not having to produce or pay for the research, products, or services, and WAM will have an incentive to recommend a broker-dealer based on receiving research or services. Clients Directing Which Broker/Dealer/Custodian to Use WAM permits clients to direct it to execute transactions through a specified broker-dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to WAM to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; the client may be unable to participate in block trades (unless WAM is able to engage in “step- outs”); and trades for the client and other directed accounts may be executed after trades for other accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. If you engage us for portfolio management services, we will assist you with opening an account with Schwab. We are independently owned and operated and are not affiliated with any sub-adviser or recommended broker-dealers or custodians. The selected broker-dealer or custodian will hold your assets in a brokerage account and will buy and sell securities when the sub-adviser, we, and/or you instruct them to. While the selected sub-adviser may recommend or require that you use a particular broker-dealer or custodian, you will decide whether to do so and will open your account with the relevant broker-dealer or custodian by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. If you do not wish to place your assets with a recommended or required broker-dealer or custodian, then the selected sub-adviser may not be able to manage or supervise your account. 13  If WAM buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, WAM would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. WAM would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). However, sub-advisers may aggregate trades for client accounts across models. When WAM does not aggregate client transactions, each client’s trades are placed separately. As a result, clients may receive different execution prices, pay different transaction costs, or experience different execution timing than other clients trading in the same security. WAM cannot assure that this practice will always result in the most favorable pricing for all clients. Item 13: Reviews of Accounts All client accounts for WAM's advisory services provided on an ongoing basis are reviewed at least quarterly by Alexander B Weinberger, President, Chief Compliance Officer, and Portfolio Manager, in accordance with clients’ respective investment policies and risk tolerance levels. Mr. Weinberger will regularly review accounts managed by sub-advisers, along with periodic statements provided to the client by account custodians. Under normal circumstances, he will contact the client at least annually, or more often as agreed upon with each client, to review the client’s financial situation and objectives, communicate information to the sub-adviser managing the account as necessary, and assist the client in understanding and evaluating the services provided by the sub- adviser. Clients will be expected to notify our firm of any changes in their financial situation, investment objectives, or account restrictions. Additional reviews may be provided when client circumstances change or upon client request. Reviews may be triggered by material market, economic, or political events, or by changes in the client's financial situation (such as retirement, termination of employment, physical move, or inheritance). As noted above, the custodian provides a quarterly report detailing the assets held, asset value, and calculation of fees, In addition, WAM prepares a market overview and client performance report for clients on a quarterly basis. WAM also prepares reports for clients in preparation for client meetings which contain performance and financial planning topics. Sub-advisers typically do not provide additional written reports directly to clients. Item 14: Client Referrals and Other Compensation Other than the benefits received from custodial arrangements described in Item 12 of this brochure, WAM does not receive any economic benefit, directly or indirectly, from any third party for advice rendered to WAM's clients. 14  WAM does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When WAM calculates and debits its advisory fees directly from client accounts at the client's custodian, WAM will be deemed to have limited custody of the client's assets and must have written authorization from the client to do so. We will send an invoice to the custodian indicating the amount of the fee to be deducted from the client’s account(s) and paid to WAM. When the sub-adviser calculates its fee, it will send an invoice to the custodian indicating the amount of the fee to be deducted from the client’s account(s) and paid to the sub-adviser. The custodian will not determine whether the fee is properly calculated. It is the client’s responsibility to verify the accuracy of the fee calculation. In some cases, the custodian will calculate and deduct the fee based on the sub-advisory agreement. In all cases, the custodian will provide the client with a statement, at least quarterly, indicating all amounts dispersed from the account, including the amount of the advisory fees paid. We will also receive a copy of client account statements from the custodian. Clients are encouraged to review all statements for accuracy and should contact WAM or the custodian with any questions or if they have not received an expected statement. Item 16: Investment Discretion WAM provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, WAM and any selected sub-advisers manage the client’s account and make investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. As noted in Item 4 of this brochure, in some instances, WAM’s, or the sub-advisor’s, discretionary authority may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to WAM). Item 17: Voting Client Securities (Proxy Voting) WAM will not ask for, nor accept, voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. 15  Item 18: Financial Information Registered investment advisers are required in this Item 18 to provide clients with certain financial information or disclosures about their financial condition. WAM has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 16