WELCH FINANCIAL PLANNING, LLC

I T E M 1 : C O V E R P AG E I T E M 1: C O V E R P A G E Welch Financial Planning & Insurance, LLC 1790 38th Street Suite 205 Boulder, CO 80301 Welchfp.com 303.939.8766 February 24, 2026 ADV 2A BROCHURE This brochure provides information about the qualifications and business practices of Welch Financial Planning, LLC, which does business as Welch Financial Planning & Insurance (“WFP”). If you have any questions about the contents of this brochure, please contact us at 303-939-8766. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration (e.g. “registered investment advisor”) does not imply a certain level of skill or training. Additional information about Welch Financial Planning & Insurance, LLC also is available on the SEC’s website at www.advisorinfo.sec.gov. You can search this site by a unique identifying number, known as an IARD number. The IARD number for WFP is CRD #329418.  I T E M 2 : M A T E R I A L C H A N G E S Pursuant to United States Securities and Exchange Commission (“SEC”) rules, Welch Financial Planning, LLC will ensure that clients receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after the Firm’s fiscal year end, December 31. This means that if there were any material changes over the past year, clients will receive a summary of those changes no later than April 30. At that time, Welch Financial Planning & Insurance, LLC will also offer a copy of its most current disclosure brochure and may also provide other ongoing disclosure information about material changes as necessary. If there are no material changes over the past year, no notices will be sent. The following list reflects material changes since our previous filing made March 3, 2025: • There are no material changes to disclose. Clients and prospective clients can always receive the most current disclosure brochure for Welch Financial Planning, LLC at any time by contacting their investment advisor representative. 2 | Welch Financial Planning, LLC | 2A Brochure | February 2026  I T E M 3 : T A B L E O F C O N T E N T S Item 1 : Cover Page .............................................................................................................................................................. 1 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 ..................................................................... 10 Item 7 Types of Clients ..................................................................................................................................................... 10 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss .............................................................. 10 Item 9 Disciplinary Information ..................................................................................................................................... 18 Item 10 Other Financial Industry Activities and Affiliations ................................................................................ 18 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 19 Item 12 Brokerage Practices ........................................................................................................................................... 20 Item 13 Review of Accounts ........................................................................................................................................... 23 Item 14 Client Referrals and Other Compensation ................................................................................................. 23 Item 15 Custody .................................................................................................................................................................. 24 Item 16 Investment Discretion ...................................................................................................................................... 25 Item 17 Voting Client Securities ................................................................................................................................... 25 Item 18 Financial Information ........................................................................................................................................ 26 Privacy Policy ....................................................................................................................................................................... 26 3 | Welch Financial Planning, LLC | 2A Brochure | February 2026  I T E M 4 : A D V I S O R Y B U S I N E S S Firm Description This Disclosure document is being offered to you by Welch Financial Planning, LLC (“WFP,” or “Firm”) about the investment advisory services we provide. It discloses information about our services and the way those services are made available to you, the client. We are an investment management firm located in Boulder, Colorado. WFP was registered with the SEC in January 2024. Tron Welch is the managing member of the firm and also serves as the Chief Compliance Officer of WFP. We are committed to helping clients build, manage, and preserve their wealth, and to provide guidance for clients to achieve their stated financial goals. We specialize in retirement investing and income generation. We will offer an initial complimentary meeting upon our discretion; investment advisory services are initiated only after you and WFP execute an Investment Management Agreement. Types of Advisory Services Investment Management Services We manage advisory accounts on a discretionary and non-discretionary basis. Once we determine a client’s profile, income need, and investment plan, we execute the day-to-day transactions with or without prior consent, depending on the client’s agreement with our firm. Account supervision is guided by the client’s written profile and investment plan. We may accept accounts with certain restrictions if circumstances warrant. We primarily allocate client assets among various mutual funds, exchange-traded funds (“ETFs”), cash, individual debt (bonds) and equity securities in accordance with their stated investment objectives. In some cases, our Firm does utilize pre-built portfolios for clients based on their risk tolerance and time horizon. In personal discussions with clients, we determine their objectives, time horizons, risk tolerance and liquidity and income needs. As appropriate, we also review their prior investment history, as well as family composition and background. Based on client needs, we develop the client’s personal profile and investment plan. We then create and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us immediately if circumstances have changed with respect to their goals and income needs. As determined through our Firm’s initial due diligence with the client, we will determine if clients are seeking an actively managed investment strategy for their account(s). Our Firm will provide ongoing investment review and management services. This approach requires us to periodically review client portfolios. With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet your financial objectives. We trade these portfolios based on the combination of our market views and your objectives, using our investment philosophy and strategies as described in Item 8 of this Brochure. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of securities. If a non-discretionary relationship is in place, calls will be placed to the client presenting the recommendation made including a rebalancing recommendation and only upon your authorization will any action be taken on 4 | Welch Financial Planning, LLC | 2A Brochure | February 2026  your behalf. Our clients should note that being in a discretionary or non-discretionary account does not affect the management of the accounts. It is the decision of the client on what type of account they elect to open with our Firm – a discretionary account without prior notification of investment trades or a non- discretionary account as described above. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. Periods of Inactivity Welch Financial has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Welch Financial 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, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Welch Financial determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Welch Financial will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Financial Planning Services For wealth management clients that meet our minimum requirement of $1,000,000 of investable assets, we include financial planning as part of our investment advisory services. For individuals that do not qualify for our investment management services, on-going and stand-alone financial planning/coaching services are offered. A periodic review and summary of financial planning and coaching is delivered to those who opt for this service. The services are agreed to between the Client and WFP using a separate Financial Planning Agreement. Through the financial planning process, our team strives to engage our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With the unique goals and circumstances of each family in mind, our team will offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and family legacy objectives. Our team partners with our client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets, and periodic updates. Our specific services in preparing your plan may include: • PERSONAL: We can review family records, budgeting, personal liability, estate information and financial goals. • • • TAX & CASH FLOW: We can analyze the client's income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability. Keep in mind, WFP is not a tax services Firm and clients should consult a tax professional for specific tax questions and advice. INVESTMENTS: We can analyze investment alternatives and their effect on the client's portfolio. INSURANCE: We can review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. • RETIREMENT: We can analyze current strategies and investment plans to help the client achieve his or her retirement goals. • DEATH & DISABILITY: We can review the client's cash needs at death, income needs of surviving dependents, estate planning and disability income. 5 | Welch Financial Planning, LLC | 2A Brochure | February 2026  • ESTATE: Some personnel that are appropriately licensed can assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. A written evaluation of each client's initial situation or Financial Plan is provided to the client. Our financial planning and consulting services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. Clients have the sole responsibility for determining whether to implement our financial planning and consulting recommendations. To the extent that the client would like to implement any of our investment recommendations through WFP or retain us to actively monitor and manage your investments, the client must execute a separate written investment advisory services agreement with WFP. If requested by client, a written financial plan is presented to the client within three (3) months of the contract date, provided that all information needed to prepare the written financial plan has been accurately and promptly provided by the client. Estate Planning Services Welch Financial uses Wealth.com to provide a holistic estate planning solution that allows clients to create, manage and administrate estate plans through a technology platform. Wealth.com facilitates an optional hybrid model where clients can start the process digitally, but still receive a human experience by consulting live with one of the local Trust and Estate attorneys. Welch Financial purchases an annual license and access to the Wealth.com platform. Wealth.com allows clients to create estate planning documents to action the legacy objectives that our firm will design together. Once referred to Wealth.com, client enters the Wealth.com platform and is guided through the document creation process by Wealth.com, not by Welch Financial. Though advisors can refer clients to the Wealth.com platform, Welch Financial and its advisors are not involved with the drafting of the legal documents and do not have the ability to make selections for the client. With Advisor only access to Wealth.com, Welch Financial and its advisor representatives can receive read-only visibility of the client account. This allows our advisors to assist clients in completing the process of creating and monitoring for optimization opportunities. Tax Planning and Preparation Our firm’s affiliated entity, Welch Tax Services, LLC, offers tax planning and preparation for individuals and business owners. These services are provided to the client for a separate fee and separate agreement directly with Welch Tax Services, LLC. The accounting services performed by these tax professionals will be separate and distinct from our investment advisory services. Our Firm is not compensated for the referral of clients to these accounting firms. Consulting Services We also provide clients investment advice on a more-limited basis on one-or-more isolated areas of concern such as estate planning, real estate, retirement planning, or any other specific topic. Additionally, we provide advice on non-securities matters about the rendering of estate planning, insurance, real estate, and/or annuity advice or any other business advisory / consulting services for equity or debt investments in privately held businesses. Participation Account Management (Discretionary) – Pontera We use a third-party platform, Pontera, to facilitate management of held away assets such as defined contribution plan participant accounts (401(k), 403(b), 457, etc.), with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades, however, our Firm has our own advisor log-in credentials to initiate and direct any trades in the client’s account. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to 6 | Welch Financial Planning, LLC | 2A Brochure | February 2026  connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Educational Seminars/Workshops The Firm provides an informative series of educational seminars and workshops periodically throughout the year. Supplemental materials are provided to enhance the learning experience. Wrap Fee Program versus Portfolio Management Program The Firm does not offer a Wrap Fee Program. Assets Under Management As of December 31, 2025, the Firm had $198,095,637 of regulatory assets under management. $198,095,637 are discretionary assets under management. $0 are non-discretionary assets under management. I T E M 5 F E E S A N D C O M P E N S A T I O N Individually Managed Accounts Clients receive investment management services through WFP. Fees will be calculated as a percentage of assets under management (AUM) based on the average daily balance of account(s) and deducted from Client account(s) in arrears on a monthly basis. Unless otherwise agreed upon and stated in the Investment Management Agreement, fees are assessed on all assets under management, including securities, cash, margin and money market balances. Each of these are considered categories within the asset allocation for the client’s investment strategy. Our fee schedule is: Annual Fees Total Assets Under Management Assets Up to $250,000 1.50% From $250,001 - $500,000 1.25% From $500,001-$1,000,000 1.00% From $1,000,001-$3,000,000 0.75% Over $3,000,000 0.75% (flat) Our fee schedule is blended. This means an account valued at $500,000 will pay 1.50% on the first $250,000 and then 1.25% on the remaining $250,000. The fee is negotiable based on the size and number of the account(s) managed. The fee is calculated and collected monthly in arrears, meaning the Firm collects the management fee at the end of each calendar month. The fee calculation is based on the custodian’s reported average daily account balance for the month. This amount is multiplied by the fee percentage and divided by 12. Cash balances and 7 | Welch Financial Planning, LLC | 2A Brochure | February 2026  investments in money market funds, demand deposit accounts, or certificates of deposit held in the account are included in the fee calculations. Unless instructed by the client, we will aggregate asset amounts in accounts from the same household together to determine the advisory fee for all accounts. We would do this, for example, where we also service accounts on behalf of minor children, individual and joint accounts for a spouse, and/or other types of related accounts. This consolidation practice is designed to allow the client to benefit from an increased asset total, which could potentially cause the account(s) to be assessed a lower advisory fee. Either WFP or you may terminate the management agreement immediately upon written notice to the other party. The management fee will be pro-rated to the date of termination for the month in which the cancellation notice was given and then refunded. The Client will be asked to authorize us with the ability to instruct the custodian to withdraw our management fee directly from your account. The Client may terminate this authorization at any time. Participation Account Management (Discretionary) – Pontera Fees We charge an annual advisory fee for services provided to these held away accounts, which is deducted on a quarterly basis. Fees are based on the value of the assets within these held away accounts. All advisory fee calculations for the held away discretionary account services are facilitated through a third-party nonaffiliated service, Pontera. Client may opt to pay the Pontera fee directly or can elect to pay this fee from their qualified account(s) at Schwab. Financial Planning Fees For clients engaged in our investment management services, our financial planning services are included in the advisory fees described above. For clients only engaging our Firm for financial planning services only, financial planning is offered under a separate agreement and separate fee. Fees may vary based on the extent and complexity of your individual or family circumstances and the amount of your assets under our management. Our fee will be agreed in advance of services being performed and negotiated with you. The fee will be determined based on factors including the complexity of your financial situation, agreed upon deliverables, and whether you intend to implement any recommendations through WFP. Financial Planning fees may be fixed, hourly, quarterly or annually. The fixed fees range from $2,500 to $20,000. Hourly fees range from $350 to $500/hour. For on- going, financial planning services, the fee is defined in the financial planning agreement. The specific fee for your financial plan will be discussed with you and specified in your planning agreement with WFP. Financial planning fees may be paid via personal check or through AdvicePay, a third party, unaffiliated ACH and credit card service as described below. Typically, we complete a plan within a month and will present it to you within 90 days of the contract date, if you have provided us all information needed to prepare the financial plan. Fifty percent (50%) of the financial planning fees are due upon execution of the financial planning agreement. The remainder is due at the time the financial plan and/or the coaching services are delivered to you. You may choose to terminate the financial planning agreement by providing us with written notice. Upon termination, fees will be prorated to the date of termination and any earned portion of the fee will be billed to you based on the hours that our firm has spent on creating your financial plan prior to termination. The hourly rate used for this purpose is $350/hour. The hourly rate would be stated in your executed Financial Planning Agreement. We will not require prepayment of more than $1,200 in fees per client, six (6) or more months in advance of providing any services. In no case are our fees based on, or related to, the performance of your funds or investments. 8 | Welch Financial Planning, LLC | 2A Brochure | February 2026  Estate Planning Services Estate planning document creation services through wealth.com are offered for a separate fee. Clients who utilize the estate planning services offered through Wealth.com will be charged a negotiated flat fee, as defined in the financial planning agreement. Third-Party ACH and Credit Card Payments - AdvicePay Fees for Financial Planning and Discretionary Management of Held Away Accounts (Pontera) can be invoiced and processed through a third-party nonaffiliated service, AdvicePay. With AdvicePay, Clients will be asked to set up their bank account or credit card at AdvicePay to enable credit card or ACH payments. While AdvicePay allows firms like WFP to receive payments directly from the client’s credit card or bank account, it does not give WFP access to the bank account itself, nor to any of the client’s credit card or bank account information. WFP is not able to initiate any additional payments via AdvicePay as agreed upon and outlined in the Agreement. Educational Seminars/Workshops The Firm provides an informative series of educational seminars and workshops periodically throughout the year. A third-party marketing firm does charge $49/per class to attend these sessions. Our Firm does not receive any compensation from this workshop fee. Consulting Fees WFP provides consulting services for clients who need advice on a limited scope of work. WFP will negotiate consulting fees with you. Fees may vary based on the extent and complexity of the consulting project. Fees will be billed as services are rendered. Either party may terminate the agreement. Upon termination, fees will be prorated to the date of termination and any unearned portion of the fee will be refunded to you as described above. Additional Fees and Expenses In addition to the advisory fees paid to WFP, clients may also incur certain charges imposed by other third parties, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges may include charges imposed directly by a mutual fund, exchange fund, or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), foreign exchange tax odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. WFP’s brokerage practices are described at length in Item 12, below. There are certain securities or investments a client wishes to purchase or hold in their account. These investment products may carry fees from the delivering firm to the Custodian. Custodians may also charge an additional fee for selecting securities and/or alternative investments to be included in the holdings of their account. Our Firm will communicate in writing to the client on the Advisory Agreement or Addendum if our firm will be reimbursing these “holding” fees. The reimbursement of these unique situations is based on the total assets in the client portfolio and client relationship. For some of the fee reimbursements, certain custodians do not allow our firm to directly reimburse additional fees directly into a client account. In those cases, the client reimbursement is processed and recorded with WFP’s monthly billing statement. Regulatory Fees To facilitate the execution of trades, regulatory Trading Activity Fees (TAF) are added to applicable sales transactions. The Securities and Exchange Commission (SEC) regulatory fee is assessed on client accounts for sell transactions, and a FINRA fee is assessed on client accounts for sell transactions, for certain covered securities. This fee is not charged by our Firm but is accessed and collected by the custodian. The Custodian that our Firm uses is a FINRA member firm. These fees recover the costs incurred by the SEC and FINRA, for supervising and regulating the securities markets and securities professionals. The fee rates vary depending on the type of transaction and the size of that transaction. For more information on the SEC and FINRA fees, please visit their websites: 9 | Welch Financial Planning, LLC | 2A Brochure | February 2026  • www.sec.gov/fast-answers/answerssec31htm.html • www.finra.org/industry/trading-activity-fee I T E M 6 P E R F O R M A N C E -B A S E D F E E S A N D S I D E- B Y -S I D E M A N A G E M E N T The Firm does not charge or accept performance-based fees. I T E M 7 T Y P E S O F C L I E N T S The Firm provides investment advice to many different types of Clients. These Clients generally include individuals, trusts, estates, charitable organizations, corporations, and other types of business entities. Minimum Account Size The Firm has a minimum account size requirement of $1,000,000. In certain circumstances account size requirement may be waived at the discretion of WFP. I T E M 8 M E T H O D S O F A N A L Y S I S , I N V E S T M E N T S T R A T E G I E S A N D R I S K O F L O S S Our investment process is not one-size-fits-all but is driven by your custom financial plan. For many accounts, we utilize a “Bucket System,” which segregates your money by short-, medium-, and long-term goals; we invest funds in an appropriate portfolio for each time horizon. This protects short-term funds while enabling funds for your future to grow to reduce the probability of running out of funds later in life. As IRS rules and regulations evolve, we evaluate the impact of long- and short-term liabilities, then adjust your path accordingly. The Firm may use the following methods when considering investment strategies and recommendations. Fundamental Review A fundamental analysis is a method of evaluating a company or security by attempting to measure its intrinsic value. Fundamental analysis attempts to determine the true value of a company or security by looking at all aspects of the company or security, including both tangible factors (e.g., machinery, buildings, land, etc.) and intangible factors (e.g., patents, trademarks, “brand” names, etc.). Fundamental analysis also involves examining related economic factors (e.g., overall economy and industry conditions, etc.), financial factors (e.g., company debt, interest rates, management salaries and bonuses, etc.), qualitative factors (e.g., management expertise, industry cycles, labor relations, etc.), and quantitative factors (e.g., debt-to-equity and price-to-equity ratios). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price with the aim of determining what sort of position to take with that security (e.g., if underpriced, the security should be bought; if overpriced the security should be sold). Fundamental analysis uses real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for many types of securities. Technical Review A technical analysis is a method of evaluating securities that analyzes statistics generated by market activity, such as past prices and volume. Technical analysis does not attempt to measure a security's intrinsic value, but instead uses past market data and statistical tools to identify patterns that can 10 | Welch Financial Planning, LLC | 2A Brochure | February 2026  suggest future activity. Historical performance of securities and the markets can indicate future performance. Quantitative Analysis We use mathematical ratios and other performance appraisal methods in an attempt to obtain more accurate measurements of a model manager’s investment acumen, idea generation, consistency of purpose and overall ability to outperform their stated benchmark throughout a full market cycle. Additionally, we perform periodic measurements to assess the authenticity of returns. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Economic Review An economic analysis determines the economic environment over a certain time horizon. This involves following and updating historic economic data such as U.S. gross domestic product and consumer price index as well as monitoring key economic drivers such as employment, inflation, and money supply for the world’s major economies. Asset Allocation Rather than focusing primarily on security selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Long-Term Purchases Long-term purchases are securities that are purchased with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Long-term purchases may be affected by unforeseen changes in the company in which a Client is invested or in the overall market. Long-term trading is designed to capture market rates of both return and risk. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Due to its nature, the long-term strategy can expose Clients to various other types of risk that will typically surface at various intervals during the time the Client owns the investments. These risks include, but are not limited to, inflation (purchasing power) risk, interest rate risk, economic risk, and political/regulatory risk. Short-Term Purchases Short-term purchases are securities that are purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short-term price fluctuations. Short-term trading generally holds greater risk. Frequent trading can affect investment performance due to increased brokerage fees and other transaction costs and taxes. Strategic Asset Allocation Asset allocation is a combination of several different types of investments; typically, this includes stocks, bonds, and cash equivalents among various asset classes to achieve diversification. The objective of asset allocation is to manage risk and market exposure while still positioning a portfolio to meet financial objectives. Risk of Loss 11 | Welch Financial Planning, LLC | 2A Brochure | February 2026  Investing inherently involves risk up to and including loss of the principal sum. Further, past performance of any security is not necessarily indicative of future results. Therefore, future performance of any specific investment or investment strategy based on past performance should not be assumed as a guarantee. The Firm does not provide any representation of or guarantee that the financial goals of Clients will be achieved. The potential return or gain and potential risk or loss of an investment varies, in general, with the type of product invested in. Below is an overview of the types of products available on the market and the associated risks of each: General Risks. Investing in securities always involves risk of loss that the Client should be prepared to bear. The Firm does not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses due to market corrections or declines. The Firm cannot offer any guarantees or promises that the Client’s financial goals and objectives can or will be met. Past performance is in no way an indication of future performance. The Firm also cannot assure that third parties will satisfy their obligations in a timely manner or perform as expected or marketed. General Market Risk. Investment returns will fluctuate based upon changes in the value of the portfolio securities. Certain securities held may be worth less than the price originally paid for them, or less than they were worth at an earlier time. Common Stocks. Investments in common stocks, both directly and indirectly through investment in shares of ETFs, may fluctuate in value in response to many factors, including, but not limited to, the activities of the individual companies, general market and economic conditions, interest rates, and specific industry changes. Such price fluctuations subject certain strategies to potential losses. During temporary or extended bear markets, the value of common stocks will decline, which could also result in losses for each strategy. Portfolio Turnover Risk. High rates of portfolio turnover could lower the performance of an investment strategy due to increased costs and may result in the realization of capital gains. If an investment strategy realizes capital gains when it sells its portfolio investments, it will increase taxable distributions to you. High rates of portfolio turnover in a given year would likely result in short-term capital gains, and under current tax law, the Client would be taxed on short-term capital gains at ordinary income tax rates, if held in a taxable account. Non-Diversified Strategy Risk. Some investment strategies may be non-diversified (e.g., investing a greater percentage of portfolio assets in a particular issuer and owning fewer securities than a diversified strategy). Accordingly, each such strategy is subject to the risk that a large loss in an individual issuer will cause a greater loss than it would if the strategy held a larger number of securities or smaller positions sizes. Model Risk. Financial and economic data series are subject to regime shifts, meaning past information may lack value under future market conditions. Models are based upon assumptions that may prove invalid or incorrect under many market environments. The Firm may use certain model outputs to help identify market opportunities and/or to make certain asset allocation decisions. There is no guarantee any model will work under all market conditions. For this reason, WFP includes model related results as part of our investment decision process, but the Firm often weighs professional judgment more heavily in making trades or asset allocations. 12 | Welch Financial Planning, LLC | 2A Brochure | February 2026  ETF Risks, including Net Asset Valuations and Tracking Error. An ETF's performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depository Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. Clients should be aware that to the extent they invest in ETF securities they will pay two levels of advisory compensation – advisory fees charged by Advisor plus any advisory fees charged by the issuer of the ETF. This scenario may cause a higher advisory cost (and potentially lower investment returns) than if a Client purchased the ETF directly. An ETF typically includes embedded expenses that may reduce the ETF's net asset value, and therefore directly affect the ETF's performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Expenses of the ETF may include investment advisor management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Inflation, Currency, and Interest Rate Risks. Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. In addition, the relative value of the U.S. dollar- denominated assets primarily managed by the Firm may be affected by the risk that currency devaluations affect Client purchasing power. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. The Client’s investment in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to convert Client’s investment to cash or other assets. limited partnerships, Real Estate Legislative and Tax Risk. Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: changes in investment advisor or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that could affect interest income, income characterization and/or tax reporting obligations, particularly for options, Investment Trust, Exchange Traded swaps, master Products/Funds/Securities. The Firm does not engage in tax planning, and in certain circumstances a Client may incur taxable income on their investments without a cash distribution to pay the tax due. Clients and their personal tax advisors are responsible for how the transactions in their account are reported to the IRS or any other taxing authority. 13 | Welch Financial Planning, LLC | 2A Brochure | February 2026  Foreign Investing and Emerging Markets Risk. Foreign investing involves risks not typically associated with U.S. investments, and the risks may be exacerbated further in emerging market countries. These risks may include, among others, adverse fluctuations in foreign currency values, as well as adverse political, social, and economic developments affecting one or more foreign countries. In addition, foreign investing may involve less publicly available information and more volatile or less liquid securities markets, particularly in markets that trade a small number of securities, have unstable governments, or involve limited industry. Investments in foreign countries could be affected by factors not present in the U.S., such as restrictions on receiving the investment proceeds from a foreign country, foreign tax laws or tax withholding requirements, unique trade clearance or settlement procedures, and potential difficulties in enforcing contractual obligations or other legal rules that jeopardize shareholder protection. Foreign accounting may be less transparent than U.S. accounting practices and foreign regulation may be inadequate or irregular. Information Security Risk. The Firm may be susceptible to risks to the confidentiality and security of its operations and proprietary and customer information. Information risks, including theft or corruption of electronically stored data, denial of service attacks on our website or websites of our third-party service providers, and the unauthorized release of confidential information are a few of the more common risks faced by us and other investment advisors. Data security breaches of our electronic data infrastructure could have the effect of disrupting our operations and compromising our customers' confidential and personally identifiable information. Such breaches could result in an inability of us to conduct business, potential losses, including identity theft and theft of investment funds from customers, and other adverse consequences to customers. The Firm has taken and will continue to take steps to detect and limit the risks associated with these threats. Artificial Intelligence and Machine Learning - Certain service providers utilized by the Firm to service client accounts have artificial intelligence components, such as our client relationship management system that utilizes artificial intelligence to summarize client meeting notes. The use of artificial intelligence and machine learning includes increased risk of data inaccuracies and security vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our clients, our Firm performs periodic due diligence of our service providers for assurance that the service providers have appropriate controls in place to protect our clients’ information and to limit data inaccuracies when artificial intelligence is used by the service provider. Tax Risks. Tax laws and regulations applicable to an account with WFP may be subject to change and unanticipated tax liabilities may be incurred by an investor as a result of such changes. In addition, Clients may experience adverse tax consequences from the early assignment of options purchased for a Client's account. Clients should consult their own tax advisors and counsel to determine the potential tax-related consequences of investing. Advisory Risk. There is no guarantee that WFP’s judgment or investment decisions on behalf of any particular account will necessarily produce the intended results. The Firm’s judgment may prove to be incorrect, and an account might not achieve its investment objectives. In addition, it is possible that WFP may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to accounts’ custodians’ software. The Firm and its representatives are not responsible for any account losses unless caused by WFP breaching our fiduciary duty. 14 | Welch Financial Planning, LLC | 2A Brochure | February 2026  Dependence on Key Employees. An account’s success depends, in part, upon the ability of WFP’s key professionals to achieve the targeted investment goals. The loss of any of these key personnel could adversely impact the ability to achieve such investment goals and objectives of the account. Concentration Risk. The risk of amplified losses that may occur from having a large portion of your holdings in a particular investment, asset class or market segment relative to your overall portfolio. Securities Lending Risk. Securities lending involves the risk that the fund loses money because the borrower fails to return the securities in a timely manner or at all. The fund could also lose money if the value of the collateral provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events could also trigger adverse tax consequences for the fund. Alternative Investments. Investments classified as "alternative investments" may include a broad range of underlying assets including, but not limited to, hedge funds, private equity, venture capital, and registered, publicly traded securities. Alternative investments are speculative, not suitable for all clients and intended for only experienced and sophisticated investors who are willing to bear the high risk of the investment, which can include: loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices; lack of liquidity in that there may be no secondary market for the fund and none expected to develop; volatility of returns; potential for restrictions on transferring interest in the fund; potential lack of diversification and resulting higher risk due to concentration of trading authority with a single advisor; absence of information regarding valuations and pricing; potential for delays in tax reporting; less regulation and typically higher fees than other investment options, such as mutual funds. The SEC requires investors be accredited to invest in these more speculative alternative investments. Investing in a fund that concentrates its investments in a few holdings may involve heightened risk and result in greater price volatility. Exchange Funds. An exchange fund allows you to substitute or replace a concentrated stock position with a diversified basket of stocks of the same value, reducing portfolio risk and putting off tax consequences until later. Typically, exchange funds are structured as private placement limited partnerships, or limited liability companies, which means that usually only accredited investors with over $5 million in net worth can participate. They also have high minimum investment requirements, often $500,000 (or more) worth of shares in the stock being exchanged. Exchange funds are not registered securities, so they don’t need to follow the SEC’s requirements for information disclosure. Exchange funds usually require that you hold on to your partnership shares for at least seven years before redemption (completing the swap of your concentrated position into a basket of stocks) without penalty. Redeeming partnership shares early could mean a return of your concentrated stock rather than shares of the diversified fund you were seeking. Exchange funds give you the ability to swap your stock for the fund’s partnership shares tax-free. To maintain eligibility for this preferential tax treatment, exchange funds are required to keep a 20% minimum of total gross assets in certain illiquid qualifying investments to help minimize portfolio volatility. Often, these qualifying investments might be commodities or real estate, which can potentially be riskier than traditional stock holdings. Cybersecurity Risk - In addition to the Material Investment Risks listed above, investing involves various operational and “cybersecurity” risks. These risks include both intentional and unintentional events at our Firm or one of its third-party counterparties or service providers, that may result in a loss or corruption of data, result in the unauthorized release or other misuse of confidential information, and generally compromise our firm’s ability to conduct its business. A cybersecurity breach may also result in a third-party obtaining unauthorized access to our clients’ information, 15 | Welch Financial Planning, LLC | 2A Brochure | February 2026  including social security numbers, home addresses, account numbers, account balances, and account holdings. Our Firm has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because different or unknown threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because our Firm does not directly control the cybersecurity systems of our third-party service providers. There is also a risk that cybersecurity breaches may not be detected. Commodities Risk - Exposure to commodities in Adviser Clients accounts is in non-physical form, such as ETFs or mutual funds, there are risks associated with the movement in commodity prices and the ability of the fund or trust manager to respond or deal with those price movements. There also may be initial charges as well as annual management fees associated with the fund or trust. Structured Notes - Structured products are designed to facilitate highly customized risk- return objectives. While structured products come in many different forms, they typically consist of a debt security that is structured to make no interest payments but a principal payments based upon various assets, rates, or formulas. Many structured products include an embedded derivative component. Structured products may be structured in the form of a security, in which case these products may receive benefits provided under federal securities law, or they may be cast as derivatives, in which case they are offered in the over-the-counter market and are subject to no regulation. Investment in structured products includes significant risks, including valuation, liquidity, price, credit/issuer default, and market risks. One common risk associated with structured products is a relative lack of liquidity due to the highly customized nature of the investment. Moreover, the full extent of returns from the complex performance features is often not realized until maturity. As such, structured products tend to be more of a buy-and-hold investment decision rather than a means of trading in and out of a position with speed and efficiency. Another risk with structured products is the credit quality and related default risk of the issuer. Although the cash flows are derived from other sources, the products themselves are legally considered to be the issuing financial institution’s liabilities. The vast majority of structured products are from investment-grade issuers, but that does not eliminate default risk by the issuer.. Also, there is a lack of pricing transparency. Welch Financial will value structured notes at the price determined by the client’s custodian, it will not attempt to assess the value of structured notes independently for the purposes of client reporting and billing. There is no uniform standard for pricing, making it harder to compare the net- of-pricing attractiveness of alternative structured product offerings than it is, for instance, to compare the net expense ratios of different mutual funds or commissions among broker-dealers. Welch Financial will purchase Structured Notes on a discretionary basis in client portfolios only when the investment is suitable for the client, without notifying the client in advance of the specific terms and conditions of each note. Interval Fund Risk - Where suitable, our Firm may utilize interval funds in client portfolios. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals at the fund sponsor’s sole discretion. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund 16 | Welch Financial Planning, LLC | 2A Brochure | February 2026  value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund's shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client's investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. The fund sponsor determines the fund price which investors will transact at based solely on its internal policies and procedures for valuing the non-traded assets withing the fund. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct WFP, in writing, not to employ any or all such strategies for the client's account. Certain Traded Interval Funds can be purchased by WFP directly with the Client’s custodian without any prior authorization from the client. In these cases, WFP will purchase these interval funds on a discretionary basis only when it deems the investments to be suitable for the client. In other cases, certain Non-Traded Interval Funds required the client to execute fund documents in order to invest. In these situations, WFP will not be able to purchase the Non-Traded Interval Funds on a discretionary basis. Both Traded and Non-Traded Interval Funds are subject to all of the risks and limitations outlined above. Leveraged ETF Fund- Our advisors may recommend the use of products that are meant to be held for a single day or less. If an adviser is recommending the purchase or holding for a period longer than one day, it is imperative that the adviser does so only in the best interest of the client. Advisers will consider the following before making these recommendations: Review the product prospectus and understand how the specific product works and how it fits into your investment strategy. If using a product inconsistent with its stated purpose, exercise due care in monitoring and disclose the associated risks to clients, including that the adviser is not trading the products according to the purpose for which they were designed. A product with unpredictable returns, regardless of the size of the holding in clients’ accounts, is generally not appropriate for most investors because of its speculative nature. An unpredictable inverse or leveraged ETF does not support a “hedge” or “over allocation” strategy, respectively. Our advisors will carefully document the suitability of these products for client accounts based on the products and the clients’ risk profiles. Option Risk. Variable degree of risk. Transactions in options carry a high degree of risk. Purchasers and sellers of options should familiarize themselves with the type of option (i.e., put or call) which they contemplate trading and the associated risks. Traders of options should calculate the extent to which the value of the options must increase for the position to become profitable, taking into account the premium and all transaction costs. • The purchaser of options may offset or exercise the options or allow the options to expire. The exercise of an option results either in a cash settlement or in the purchaser acquiring or delivering the underlying interest. If the option is on a future, the purchaser will acquire a futures position with associated liabilities for margin (see the section on Futures below). If the purchased options expire worthless, the purchaser will suffer a total loss of the investment. In purchasing deep out-of-the-money options, the purchaser should be aware that the chance of such options becoming profitable ordinarily is remote. • Selling ("writing" or "granting") an option generally entails considerably greater risk than purchasing options. Although the premium received by the seller is fixed, the seller may sustain a loss well in excess of that amount. The seller will be liable for additional margin to maintain the position if the market moves unfavorably. The seller will also be exposed to the risk of the 17 | Welch Financial Planning, LLC | 2A Brochure | February 2026  purchaser exercising the option and the seller being obligated to either settle the option in cash or to acquire or deliver the underlying interest. If the option is on a future, the seller will acquire a position in a future with associated liabilities for margin (see the section on Futures below). If the option is "covered" by the seller holding a corresponding position in the underlying interest or a future or another option, the risk may be reduced. If the option is not covered, the risk of loss can be unlimited. • Certain exchanges in some jurisdictions permit deferred payment of the option premium, exposing the purchaser to liability for margin payments not exceeding the amount of the premium. The purchaser is still subject to the risk of losing the premium and transaction costs. When the option is exercised or expires, the purchaser is responsible for any unpaid premium outstanding at that time. I T E M 9 D I S C I P L I N A R Y I N F O R M A T I O N Neither the firm nor its representatives have any history of discipline. I T E M 1 0 O T H E R F I N A N C I A L I N D U S T R Y A C T I V I T I E S A N D A F F I L I A T I O N S Licensed Insurance Agents Some of WFP’s financial professionals are licensed insurance agents and recommend the purchase of certain insurance-related products on a commission basis. The recommendation by a WFP financial professional that a client purchase or sell an insurance commission product presents a conflict of interest, as the receipt of a commission may provide an incentive to recommend investment products based on commission received, rather than on a particular Client’s need. Clients are not under any obligation to purchase or sell any commission products from a WFP financial professional. Tax Services The Firm has an affiliated entity, Welch Tax Services, LLC which provides tax preparation and planning services. The Firm recommends its services to investment advisory clients. It charges separate fees from investment advisory fees. The adviser has an incentive to recommend tax services and this incentive creates a conflict of interest between your interests and the Firm. Clients should note that they have the right to decide whether or not to engage the services of our IARs. Further, clients should note they have the right to decide whether to act on the recommendations and the right to choose any professional to execute the advice for any tax services through our IAR or any licensed tax agent not affiliated with our Firm. We recognize the fiduciary responsibility to place your interests first and have established policies in this regard to avoid any conflicts of interest. Registration as a Broker/Dealer or Broker/Dealer Representative The Firm is not registered and does not have an application pending to register, as a broker-dealer. Registration as a Futures Commission Merchant, Commodity Pool Operator The Firm and its management persons are not registered and do not have an application pending to register as a futures commission merchant, commodity pool operator/advisor. Selection of Other Advisor The Firm does not recommend or select other investment advisors for its Clients. 18 | Welch Financial Planning, LLC | 2A Brochure | February 2026  I T E M 1 1 C O D E O F E T H I C S , P A R T I C I P A T I O N O R I N T E R E S T I N C L I E N T T R A N S A C T I O N S A N D P E R S O N A L T R A D I N G According to federal and state law, an investment advisor is considered a fiduciary. As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts. In addition, an investment advisor has a duty of utmost good faith to act solely in the best interest of each of its clients. The Firm and its representatives have a fiduciary duty to all Clients. The fiduciary duty of WFP and its representatives toward its Clients is considered the core underlying principle for WFP’s Code of Ethics and represents the expected basis for all dealings our representatives have with our Clients. The Firm has the responsibility to ensure that the interests of its Client are placed ahead of its own investment interests, as well as the investment interests of its representatives. All representatives will conduct business in an honest, ethical, and fair manner. All representatives will comply with all federal and state securities laws at all times. Full disclosure of all material facts and potential conflicts of interest will be provided to Clients prior to services being conducted. All representatives have a responsibility to avoid circumstances that might negatively affect or appear to affect their duty of complete loyalty to our Clients. The Firm and its financial professionals may purchase or sell securities that are also recommended to Clients. This practice may create a situation where WFP and its financial professionals are able to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. Practices such as “scalping” (i.e., the practice whereby the owner of shares of a security recommends that security for investment and then immediately sells it at a profit upon the rise in the market price which follows the recommendation) could take place if WFP did not have adequate policies in place to detect such activities. In addition, these procedures are designed to help detect insider trading, “front-running” (i.e., personal trades executed prior to those of WFP’s Clients) and other potentially abusive practices. The Firm has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of WFP’s “Access Persons,” who are persons who have access to the Firm’s nonpublic information. This policy requires that Access Persons provide the Chief Compliance Officer with a written report of their current securities holdings as part of the process of becoming an Access Person. Additionally, each Access Person provides the Chief Compliance Officer with a written or electronic report of the Access Person’s current securities holdings at least once each 12-month period thereafter on a date WFP selects. The Firm and its financial professionals may purchase or sell securities at or around the same time as those securities are recommended to Clients. This practice creates a situation where we are able to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. The Firm has a personal securities transaction policy in place to monitor the personal securities holdings of each WFP Access Person. We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things, personal trading, gifts, the prohibition against the use of inside information and other situations where there is a possibility for conflicts of interest. The Code of Ethics is designed to protect our clients by deterring misconduct, educate personnel regarding the firm’s expectations and laws governing their conduct, remind personnel that they are in a position of trust and must act with complete propriety at all times, protect the reputation of WFP, guard against violation of the securities laws, and establish procedures for personnel to follow so that we may determine whether their personnel are complying with the firm’s ethical principles. We have established the following restrictions in order to ensure our firm’s fiduciary responsibilities: 1. No director, officer or employee of WFP shall prefer his or her own interest to that of the advisory client. 19 | Welch Financial Planning, LLC | 2A Brochure | February 2026  2. We maintain a list of all securities holdings and anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed on a regular basis by an appropriate officer/individual of WFP. 3. We emphasize the unrestricted right of the client to decline to implement any advice rendered, except in situations where we are granted discretionary authority of the client’s account. 4. We emphasize the unrestricted right of the client to select and choose any broker-dealer (except in situations where we are granted discretionary authority) he or she wishes. 5. We require that all individuals act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 6. Any individual not in observance of the above may be subject to termination. You may request a complete copy of our Code by contacting us at the address, telephone or email on the cover page of this Part 2; Attn: Chief Compliance Officer. I T E M 1 2 B R O K E R A G E P R A C T I C E S The Custodians and Brokers the Firm Uses The Firm does not maintain custody of your assets that the Firm manages, although may be deemed to have custody of your assets if Client gives the Firm authority to withdraw assets from your account (see Item 15— Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker- dealer or bank. The Firm recommends that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer and member SIPC, as the qualified custodian. The Firm is independently owned and operated and is not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when the Firm instructs them to. While the Firm recommends that Client use Schwab as custodian/broker, Client will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). Client should consider these conflicts of interest when selecting your custodian. The Firm does not open an account for you, although the Firm may assist Client in doing so. Even though your account is maintained at Schwab, and The Firm anticipates that most trades will be executed through Schwab, the Firm can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). How the Firm selects brokers/custodians: The Firm seeks to recommend Schwab, a custodian/broker that will hold your assets and execute transactions. When considering whether the terms that Schwab provides are, overall, most advantageous to Client when compared with other available providers and their services, the Firm considers a wide range of factors, including: • Combination of transaction execution services and asset custody services (generally, without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.) • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices 20 | Welch Financial Planning, LLC | 2A Brochure | February 2026  • Availability of other products and services that benefit us, as discussed below (see “Products and services available to us from Schwab”) Your Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge Client separately for custody services but is compensated by charging us commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. In addition to commissions, Schwab charges us a flat dollar amount as a “prime broker” or “trade away” fee for each trade that the Firm has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation the Firm pays the executing broker-dealer. Because of this, to minimize your trading costs, the Firm has Schwab execute most trades for your account. The Firm is not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although the Firm is not required to execute all trades through Schwab, the Firm has determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How the Firm selects brokers/custodians”). By using another broker or dealer, Client may pay lower transaction costs. Products and Services Available to Us From Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (the Firm doesn’t have to request them) and at no charge to us. The following is a more detailed description of Schwab’s support services: Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which the Firm might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit Client and Client accounts. Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit Client or Client accounts. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting 21 | Welch Financial Planning, LLC | 2A Brochure | February 2026  Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and related compliance needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third-party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment for our personnel. If Client did not maintain Client accounts with Schwab, the Firm would be required to pay for these services from our own resources. Our Interest in Schwab’s Services The availability of these services from Schwab benefits us because the Firm does not have to produce or purchase them. The Firm doesn’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that the Firm receives these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. The Firm believes, however, that taken in the aggregate, our recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How the Firm selects brokers/custodians”) and not Schwab’s services that benefit only the Firm. Trade Errors We have implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes the trade error, the client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client will be made whole, and we will absorb any loss resulting from the trade error if the error was caused by the Firm. If the error is caused by the Custodian, the Custodian will be responsible for covering all trade error costs. Our Firm will never benefit or profit from trade errors. Brokerage for Client Referrals The Firm does not receive client referrals from any custodian or third party in exchange for using that custodian or third party. Directed Brokerage We do not routinely require that you direct us to execute transactions through a specified broker dealer. Additionally, we typically do not permit you to direct brokerage. We place trades for your account subject to our duty to seek best execution and other fiduciary duties. Trade Aggregation The Firm may aggregate transactions in equity and fixed income securities for a client with other clients to improve the quality of execution. When transactions are aggregated, the actual prices applicable to the aggregated transactions will be averaged, and your account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. We may determine not to aggregate transactions, for example, based on the size of the trades, the number of client’s accounts, the timing of the trades, the liquidity of the securities or the discretionary or non-discretionary nature of the 22 | Welch Financial Planning, LLC | 2A Brochure | February 2026  trades. If we do not aggregate orders, purchasing securities around the same time may receive a less favorable price than other clients. This means that the practice of not aggregating may cost the Client more money. I T E M 1 3 R E V I E W O F A C C O U N T S Period Reviews The Firm regularly reviews and evaluates Client accounts for compliance with each Client’s investment objectives, policies, and restrictions. The Firm analyzes rates of return and allocation of assets to determine model strategy effectiveness. Such reviews are conducted by the Chief Compliance Officer of WFP and shall occur at least once on a quarterly basis. Intermittent Review Factors Intermittent reviews may be triggered by substantial market fluctuation, economic or political events, or changes in the Client’s financial status (such as retirement, termination of employment, relocation, inheritance, etc.). Clients are advised to notify WFP promptly if there are any material changes in their financial situation, investment objectives, or in the event they wish to place restrictions on their account. Reports Clients may receive confirmations of purchases and sales in their accounts and will receive, at least quarterly, statements containing account information such as account value, transactions, and other relevant information. Clients may also run customized reports at any time through the WFP Client Portal offered through the third-party portfolio software system engaged by our firm. The available reports include positions, returns, and capital gains. Confirmations and statements are prepared and delivered by the custodian. I T E M 1 4 C L I E N T R E F E R R A L S A N D O T H E R C O M P E N S A T I O N Client Referrals The Firm receives financial compensation for referring clients to outside third party relationships who provide insurance for property and casualty insurance sales, and/or Medicare. These referral arrangements are a conflict of interest because WFP has a financial incentive to refer Clients to third-party independent insurance agents. WFP addresses this conflict by having policies and procedures in place to ensure that any referrals to third parties are suitable and appropriate and in the best interest of the Client. The Client is under no obligation to purchase insurance products from third parties. Other Compensation The Firm receives an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. Clients do not pay more for assets maintained at Schwab as a result of these arrangements. However, the Firm benefits from the referral arrangement because the cost of these services would otherwise be borne directly by us. Client should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12—Brokerage Practices). Marketing-expense reimbursements are typically the result of informal expense sharing arrangements in which product sponsors may underwrite costs incurred for marketing such as advertising, publishing and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are typically made by those sponsors for whom sales have been made or it is anticipated sales will be made. 23 | Welch Financial Planning, LLC | 2A Brochure | February 2026  In cases where we have not disclosed above, there may be instances when our Firm may be asked to recommend a financial professional, such as an attorney, accountant, or mortgage broker. Our Firm does not receive compensation in such cases. Our Firm does not receive any direct compensation in return for any referrals made to individuals or firms in our professional network. Clients must independently evaluate these firms or individuals before engaging in business with them and clients have the right to choose any financial professional to conduct business. Individuals and firms in our financial professional network may refer clients to our Firm. Again, our Firm does not pay any direct compensation in return for any referrals made to our Firm. Our Firm recognizes the fiduciary responsibility to place your interests first and has established policies in this regard to mitigate any conflicts of interest. The Firm does not pay another person or entity for referring or soliciting Clients for WFP. I T E M 1 5 C U S T O D Y Custodian of Assets Custody means holding, directly or indirectly, client funds or securities or having any authority to obtain possession of them. The Firm does not have direct custody of any Client funds and/or securities. The Firm will not maintain physical possession of Client funds and securities. Instead, Client funds and securities are held by a qualified custodian. While WFP does not have physical custody of Client funds or securities, payments of fees may be paid by the custodian from the custodian brokerage account that holds Client funds pursuant to the Client’s account application. In certain jurisdictions, the ability of WFP to withdraw its management fees from the Client’s account may be deemed custody. Prior to permitting direct debit of fees, each Client provides written authorization permitting fees to be paid directly from the custodian. As part of the billing process, the Client’s custodian is advised of the amount of the fee to be deducted from that Client’s account. On at least a quarterly basis, the custodian is required to send to the Client a statement showing all transactions within the account during the reporting period. The custodian does not calculate the amount of the fee to be deducted and does not verify the accuracy of WFP’s advisory calculation. Therefore, it is important for Clients to carefully review their custodial statements to verify the accuracy of the calculation. Clients should contact WFP directly if they believe that there may be an error on their statement. Certain Client accounts subject to WFP’s services may be held at a custodian that is not directly accessible by the Firm (“Held Away Accounts”). The Firm may, but is not required to, manage these Held Away Accounts using the Pontera Order Management System. Pontera allows us to view and manage these assets on a discretionary or non-discretionary basis. To manage the Held Away Account, a client must agree to the Pontera End User Terms and Conditions and Privacy Policy and must further agree to keep us appraised of any changes to the client’s usernames and passwords for the Held Away Accounts so that we can promptly update the client’s credentials using the Pontera system. The Client also must agree to promptly address any requests to update applicable login credentials when requested by the Pontera system. In the event of any delay by a client to update applicable login credentials, the client must acknowledge in the advisory agreement that WFP will not have access to view or manage the Held Away Account, which may result in investment losses or inadvertently incorrect valuations be used in the billing process under the investment management agreement. The Firm will not be responsible for any losses arising from a client’s delays in updating login credentials through the Pontera system and the Firm will be under no obligation to credit any 24 | Welch Financial Planning, LLC | 2A Brochure | February 2026  fees for valuations made in good faith during period when WFP did not have access to any Held Away Account in calculating its fees under the investment management agreement. Standing Letters of Authorization Our authority to direct client requests, utilizing standing instructions, for wire transfer of funds for first-party money movement and third-party money movement (checks and/or journals, ACH, Fed-wires). The SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisors Act of 1940 (“Advisors Act”). The letter provided guidance on the Custody Rule as well as clarified that an Advisor who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our Firm has adopted the following safeguards in conjunction with our custodians. The firm has elected to meet the SEC’s seven conditions to avoid the surprise custody exam, as outlined below: 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. I T E M 1 6 I N V E S T M E N T D I S C R E T I O N For discretionary accounts, prior to engaging the Firm to provide portfolio management services, clients will enter a written Agreement with the Firm granting us the authority to supervise and direct, on an on-going basis, investments in accordance with the client’s investment objective and guidelines. In addition, the Client will need to execute additional documents required by the Custodian to authorize and enable the Firm, in its sole discretion, without prior consultation with or ratification by you, to purchase, sell, or exchange securities in and for Client accounts. The Firm will be authorized to buy, sell, exchange and trade any stocks, bonds or other securities or assets, determine the amount of securities to be bought or sold, and place orders with the custodian. Any limitations to such discretionary authority will be communicated to the Firm in writing by you, the Client. I T E M 1 7 V O T I N G C L I E N T S E C U R I T I E S The Firm does not perform proxy voting services on the client’s behalf. Clients are encouraged to read through the information provided with the proxy voting documents and to make a determination based on the information provided. Upon the client’s request, Firm representatives may provide limited clarifications of the issues presented in the proxy voting materials based on his or her understanding of issues presented in the proxy voting materials. However, clients have the ultimate responsibility for making all proxy voting decisions. Except as required by applicable law, WFP will not be obligated to render advice or take any action 25 | Welch Financial Planning, LLC | 2A Brochure | February 2026  on behalf of clients with respect to assets presently or formerly held in their accounts that become the subject of any legal proceedings, including bankruptcies. From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. WFP has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. WFP also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, WFP has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. I T E M 1 8 F I N A N C I A L I N F O R M A T I O N Balance Sheet Requirement The Firm is not the qualified custodian for client funds or securities and does not require prepayment of fees more than $1,200 per client for six (6) months or more in advance. Financial Condition The Firm does not have any financial impairment that would preclude the Firm from meeting contractual commitments to Clients. Bankruptcy Petition The Firm has not been the subject of a bankruptcy petition at any time. P R I V A C Y P O L I C Y Our Firm collects nonpublic personal information about Clients from information provided on applications or other forms, as well as from information regarding Client transactions with our Firm, our affiliates, or others. In accordance with Regulation S-P, our Firm does not disclose any nonpublic personal information about current or former Clients to third parties, except as permitted or required by law, or as necessary to service Client accounts. Access to Client information is restricted to Firm personnel who require such information to provide investment advisory services. Our Firm maintains physical, electronic, and procedural safeguards designed to protect Client information in compliance with federal standards and Regulation S-P. Our Firm provides a copy of its Privacy Policy to Clients at the time of account opening, upon request, and annually if the Policy is amended. 26 | Welch Financial Planning, LLC | 2A Brochure | February 2026