WELLTH ADVISORY SERVICES, LLC

WELLth Advisory Services, LLC 25434 Prairiewood Lane Shorewood, IL 60404 Phone: 866-777-4015 Fax: 866-777-4015 www.srpre@re.com Registered Investment Advisor Firm Brochure Form ADV Part 2A December 12, 2025 This brochure provides informa@on about the qualifica@ons and business prac@ces of WELLth Advisory Services, LLC, a registered investment advisor. If you have any ques@ons about the contents of this brochure, please contact us at 866-777-4015. The informa@on in this brochure has not been approved or verified by the United States Securi@es and Exchange Commission (“SEC”) or by any state securi@es authority. informa@on about WELLth Advisory Services, LLC Addi@onal is also available on the SEC’s website at www.advisorinfo.sec.gov. You may search this site by our iden@fying number known as a CRD number. The CRD number for WELLth Advisory Services, LLC is 330537. Registra@on with the SEC or any state securi@es authority does not imply a certain level of skill or training. You are encouraged to review this brochure and brochure supplements for our firm’s associates for more informa@on on the qualifica@ons of our firm and its employees. Page 1 of 25 CRD # 330537  Item 2: Material Changes WELLth Advisory Services, LLC amends its disclosure brochure on an annual basis. To receive a copy of our most recent brochure at any @me during the year, please call WELLth Advisory Services, LLC at 866-777-4015, and a copy will be sent to you. You may also obtain a copy of the most current brochure and addi@onal informa@on on our firm from www.advisorinfo.sec.gov under Investment Advisor Search. If applicable, this sec@on will contain a summary of material changes to the informa@on in our brochure since the last annual update of this brochure. This filing includes updates to: • • • Item 5 – Fees and Compensa@on updated to include the fees that may be charged by WELLth Advisory Services affiliates. Item 10 – Other Financial Industry Ac@vi@es and Affilia@ons updated to disclose affiliated en@@es and disclosure language with regards to conflicts of interest. Item 14 – Client Referrals and Other Compensa@on updated to include language with regards to affiliate compensa@on arrangements. Page 2 of 25 CRD # 330537  Item 3: Table of Contents Item 2: Material Changes .................................................................................................. 2 Item 4: Advisory Business ................................................................................................. 4 Retirement Plan Services .................................................................................................................... 4 Wealth Management Services ............................................................................................................ 5 Use of Subadvisors ............................................................................................................................ 8 Item 5: Fees and Compensation ........................................................................................ 9 Retirement Plan Services .................................................................................................................... 9 Wealth Management Services ............................................................................................................ 9 Item 6: Performance Based Fees ..................................................................................... 13 Item 7: Types of Clients .................................................................................................. 13 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 13 Item 9: Disciplinary Information ...................................................................................... 15 Item 10: Other Financial Industry Activities and APiliations .............................................. 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................................................................................................................... 17 Item 12: Brokerage Practices ........................................................................................... 18 Item 13: Review of Accounts ........................................................................................... 21 Item 14: Client Referrals and Other Compensation .......................................................... 22 Item 15: Custody ............................................................................................................ 23 Item 16: Investment Discretion ....................................................................................... 24 Item 17: Voting Client Securities ..................................................................................... 24 Item 18: Financial Information ........................................................................................ 24 Page 3 of 25 CRD # 330537  Item 4: Advisory Business WELLth Advisory Services, LLC is registered as an investment advisor with the SEC. WELLth Advisory Services, LLC is organized as a limited liability company under the laws of the state of Nevada and has been in business since 2024. WELLth Advisory Services, LLC (some@mes referred to herein as “we,” “us” or “WELLth Advisory Services”) is owned by SRP Holdings Group, LLC, a Nevada corpora@on. The WELLth Advisory Services main office is located at 25434 Prairiewood Lane, Shorewood, Illinois 60404. The WELLth Advisory Services Senior Management Team consists of Jeff Cullen, Chief Execu@ve Officer; Deane Mayerhofer, Chief Opera@ng Officer; and Sarah Hughes, Chief Compliance Officer. WELLth Advisory Services recognizes that the advisor’s role should extend beyond investment guidance and ojen requires a variety of coordinated financial service strategies to create a roadmap to achieving financial goals for their clients. We support this effort by providing our Investment Advisory Representa@ves (“IARs”) with the tools and resources to meet client needs and objec@ves. Re#rement Plan Services We approach client service with a collabora@ve style delivered by a dedicated plan consultant team in our regional offices. This team is further supported by specialists who are specifically focused in the areas of ERISA Compliance, Investment Research, Provider Analysis, Fee Benchmarking, Employee Educa@on, and Execu@ve Benefits. We wake up every day with a renewed and unparalleled commitment to excellence that is supported by the latest technology, deep research capabili@es, opera@onal efficiencies, and a crajsman-like focus on detail. We adhere to opera@ng principles and values that emphasize independence, work ethic, and a laser-like focus on the needs of our clients. WELLth Advisory Services, through its affiliated IARs, provides consul@ng and advisory services to both ERISA and Non-ERISA employer sponsored re@rement plans, including, but not limited to, 401(k), 457(b), 457(f), 403(b), Simple IRA, SEP IRA, nonqualified, deferred compensa@on, pension and profit-sharing plans (collec@vely, “Plans” or individually, “Plan”) on both a one-@me and/or ongoing basis. WELLth Advisory Services offers a suite of detailed engagement agreements which are customized for each client rela@onship and executed by the Plan’s designated fiduciary upon conclusion of a careful review, which, at @mes, includes the client’s independent legal counsel. Through its agreements, WELLth Advisory Services is engaged to provide investment advisory services on either a nondiscre@onary basis (serving as a “fiduciary” as defined by Sec@on 3(21)(A)(ii) of the Employee Re@rement Income Security Act of 1974 (“ERISA”)); or on a discre@onary basis and thus will serve as an “Investment Manager” as defined by Sec@on 3(38) of ERISA. Certain other addi@onal services available from WELLth Advisory Services would be considered non-fiduciary by defini@on and func@on and are explicitly detailed within the Plan’s service agreement with us. For non-discre@onary services, WELLth Advisory Services and its IARs will act in a solely advisory capacity and will not have or exercise any discre@onary authority or control rela@ve to the management or investment of the assets of the respec@ve Plan. For discre@onary services, WELLth Advisory Services and its IARs will be designated as the Investment Manager to the Plan and assume responsibility for the investment selec@on and asset management for the Plan’s investment menu made available to the Plan par@cipants from which to choose. In all cases, WELLth Advisory Services will not serve as the “named fiduciary” of the Plan as that term is defined under ERISA Sec@on 3(16). Our agreements offer our clients the opportunity to select one or more of the following services in various engagement categories: The Plan-level Fiduciary Services that are provided under the Agreement include: • Non-Discre=onary Fiduciary Services may include: Page 4 of 25 CRD # 330537  Investment Policy Statement. o o Ongoing Investment Selec@on and Recommenda@ons. o Ongoing Investment Monitoring. o Qualified Default Investment Alterna@ve Assistance. o Non-Discre@onary Crea@on of Model Poroolios. • Discre=onary Fiduciary Services may include: Investment Policy Statement. o o Ongoing Investment Discre@on and Selec@on. o Ongoing Investment Monitoring. o Qualified Default Investment Alterna@ve. o Discre@onary Crea@on of Model Poroolios. • The Plan-level Non-Fiduciary Services may include: o Service Provider Liaison. o Educa@on Services to Plan Commipee. o Plan Search Support/Vendor Analysis. o Benchmarking Services. o Assistance Iden@fying Plan Fees. o Plan Design Consul@ng. o Plan Review. • Par=cipant-level Services may include: o Par@cipant Enrollment. o Par@cipant Educa@on. o Par@cipant Advice. o Financial Wellness Program. Based on the needs of the client, the agreement will specify the services on a client-by-client basis. Wealth Management Services WELLth Advisory Services offers investment advisory, poroolio management, and financial planning services to individuals and families. Our investment recommenda@ons primarily include mutual funds, exchange-traded funds, and separate account managers inves@ng in exchange-listed equity securi@es. The advice provided by WELLth Advisory Services is tailored to the unique objec@ves of each client. We work with clients to formulate an investment strategy ajer discussing risk tolerance, @me horizon, and projected future liquidity needs, current holdings, tax considera@ons, personal market views and other factors. This strategy provides guidance to formulate suitable investment and financial recommenda@ons. We meet with clients as needed to review poroolio performance, discuss current issues, and reassess goals and investment plans. Client input, involvement and decision-making are cri@cal to the planning process and implementa@on of investment decisions. WELLth Advisory Services also offers financial plans. These financial planning services are based on the client’s financial situa@on at the @me the financial informa@on is disclosed by the client to WELLth Advisory Services. Clients are advised that certain assump@ons may be made with respect to interest and infla@on rates and the use of past trends and performance of the market and economy. Because clients’ financial situa@ons, goals, objec@ves, or needs change, clients are encouraged to no@fy us promptly if they wish to update their financial plan. WELLth Advisory Services also offers discre@onary management services to our individual clients. Regardless of whether our authority is discre@onary or non-discre@onary, clients may impose reasonable restric@ons on inves@ng in certain securi@es or types of securi@es. Page 5 of 25 CRD # 330537  WELLth Advisory Services may provide advisory services through certain programs sponsored by LPL Financial LLC (“LPL”), a registered investment adviser and broker-dealer. Below is a brief descrip@on of each LPL custodied advisory program available to WELLth Advisory Services, LLC. For more informa@on regarding the LPL programs, including more informa@on on the advisory services and fees that apply, the types of investments available in the programs and the poten@al conflicts of interest presented by the programs please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. The asset management program sponsors u@lized by WELLth Advisory Services include, but are not limited to the LPL Financial, LLC (“LPL”) sponsored advisory programs listed below: Manager Access Select Program MAS offers clients the ability to par@cipate in the Separately Managed Account Plaoorm (the “SMA Plaoorm”) or the Model Poroolio Plaoorm (the “MP Plaoorm”). In the SMA Plaoorm, WELLth Advisory Services will assist client in iden@fying a third party poroolio manager (“SMA Poroolio Manager”) from a list of SMA Poroolio Managers made available by LPL, and the SMA Poroolio Manager manages client’s assets on a discre@onary basis. WELLth Advisory Services will provide ini@al and ongoing assistance regarding the SMA Poroolio Manager selec@on process. In the MP Plaoorm, clients authorize LPL to direct the investment and reinvestment of the assets in their accounts, in accordance with the selected model poroolio provided by LPL’s Research Department or a third-party investment adviser. Clients should review the MAS Program Brochure for more detailed informa@on, available at lpl.com/disclosures.html. A minimum account value of $25,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Op=mum Market PorAolios Program (OMP) OMP is a professionally managed mutual fund asset alloca@on program in which LPL and WELLth Advisory Services provide ongoing investment advice and management. WELLth Advisory Services obtains the necessary financial data from the client, assists the client in determining the suitability of the program and assists the client in serng an appropriate investment objec@ve. WELLth Advisory Services selects a model poroolio of mutual funds comprised of Op@mum Funds Class I shares, designed by LPL’s Research Department consistent with the client’s stated investment objec@ve. Clients grant LPL discre@onary trading authority to sell previously purchased securi@es and purchase and sell Op@mum Funds to track the model poroolio. Clients should review the OMP Program Brochure for more detailed informa@on, available at lpl.com/disclosures.html. LPL generally requires a minimum account value of $1,000 for OMP, but addi@onal contribu@ons may be required for account sizes below $10,000. In certain instances, LPL will permit a lower minimum account size. Personal Wealth PorAolios Program (PWP) PWP is a unified managed account program in which LPL and WELLth Advisory Services provide ongoing investment advice and management to clients. WELLth Advisory Services obtains the necessary financial data from the client and assists the client in serng an appropriate investment objec@ve. Client authorizes WELLth Advisory Services on a discre@onary basis to select an asset alloca@on model poroolio designed by LPL (“Poroolio”). WELLth Advisory Services then selects third party investment advisers (“PWP Advisors”) who will provide investment models within each asset class of the Poroolio. Clients authorize LPL to invest in accordance with the poroolio and models. Clients should review the PWP Program Brochure for more detailed informa@on, available at lpl.com/disclosures.html. A minimum account value of $250,000 is required for PWP. In certain instances, LPL will permit a lower minimum account size. Model Wealth PorAolios Program (MWP) Page 6 of 25 CRD # 330537  MWP is a unified managed account program in which LPL and WELLth Advisory Services provide ongoing investment advice on a discre@onary basis. WELLth Advisory Services obtains the necessary financial data from the client, assists the client in determining the suitability of the program and assists the client in serng an appropriate investment objec@ve. WELLth Advisory Services selects one or more model poroolios of securi@es (each, a “Poroolio”) designed by LPL’s Research Department, a third-party investment strategist, or WELLth Advisory Services (each, a “Poroolio Strategist”), consistent with the client’s stated investment objec@ve. These Poroolios may contain mutual funds, ETFs, exchange-traded notes (“ETNs”), closed-end funds, equi@es, or fixed-income securi@es. WELLth Advisory Services provides ongoing advice on the selec@on or replacement of a Poroolio based on the client’s individual needs and may choose more than one Poroolio to be managed within a single MWP account. A Poroolio also may be comprised of one or more underlying models. Clients grant WELLth Advisory Services discre@on to choose among the available models designed by the Poroolio Strategists, which may include WELLth Advisory Services and its IARs. The Poroolio Strategist is responsible for selec@ng the securi@es within a Poroolio and for making changes to the securi@es selected. Each Poroolio Strategist provides its model poroolio to LPL, and LPL makes the decisions on how to implement the model on behalf of clients. Clients should review the MWP Program Brochure for more detailed informa@on, available at lpl.com/disclosures.html. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the poroolio(s) selected and the account’s alloca@on amongst poroolios. The lowest minimum for a poroolio is $10,000. In certain instances, a lower minimum for a poroolio is permiped. Client understands that the account will not be invested according to a model poroolio un@l the applicable asset minimums for that model poroolio have been reached. Guided Wealth PorAolios (GWP) GWP is an advisor-enhanced digital advice program that offers clients the ability to par@cipate in a centrally managed investment program, which is made available to users and clients through a web-based, interac@ve account management portal. Clients are required to maintain an ac@ve profile in the account management portal to par@cipate in the program. Clients select from one of the following goals for their account: re@rement, major purchase, or general inves@ng. Based on informa@on provided by the client, the client is assigned a model poroolio constructed by LPL. WELLth Advisory Services determines the suitability of the Program for the client and an appropriate investment alloca@on track for the client. Clients authorize LPL on a discre@onary basis to purchase and sell securi@es based upon the model poroolio. Program securi@es currently include a limited universe of ETFs but may include mutual funds in the future. Clients should review the GWP Program Brochure for more detailed informa@on, available at lpl.com/disclosures.html. A minimum account value of $5,000 is required to enroll in GWP. Strategic Wealth Management (SWM) Under the consolidated SWM program, SWM clients pay transac@on charges for the purchase and sale of certain securi@es in their SWM accounts, unless their WELLth Advisory Services elects to pay transac@on charges on their behalf. Clients should be aware that WELLth Advisory Services pays LPL transac@on charges for those transac@ons. The transac@on charges paid by WELLth Advisory Services vary based on the type of transac@on (e.g., mutual fund, equity or ETF) and for mutual funds based on whether or not the mutual fund pays 12b-1 fees, asset-based service fees and/or recordkeeping fees to LPL. The amount of these transac@on charges is set forth in the SWM Account Agreement and the accompanying fee schedule (available here - hpps://www.lpl.com/disclosures.html). Being subject to transac@on charges results in higher fees and expenses and, as a result, reduces investment returns. Because WELLth Advisory Services has elected to pay the transac@on charges in SWM accounts on behalf of the Client, there is a conflict of interest in cases where the mutual fund is offered at both $0 and $26.50, or where transac@on fees vary based on the type of transac@on. Clients should understand that the cost to Advisor of transac@on charges may be a factor that WELLth Advisory Services considers when deciding which securi@es to select and how frequently to place transac@ons in a SWM account. WELLth Advisory Services determines the account fee for each client within the SWM program, subject to a maximum account fee of 3.00%. SWM does not require a minimum account size. Page 7 of 25 CRD # 330537  Poten=al Conflicts of Interest Transac@ons in LPL advisory program accounts are generally made through LPL as the execu@ng broker-dealer. WELLth Advisory Services receives compensa@on as a result of a client’s par@cipa@on in an LPL program. Depending on, among other things, the size of the account, changes in its value over @me, the ability to nego@ate fees or commissions, and the number of transac@ons, the amount of this compensa@on may be more or less than what WELLth Advisory Services would receive if the client par@cipated in other programs, whether through LPL or another sponsor, or paid separately for investment advice, brokerage, and other services. WELLth Advisory Services receives compensa@on as a result of a client’s par@cipa@on in an LPL program. Depending on, among other things, the type and size of the account, type of securi@es held in the account, changes in its value over @me, the ability to nego@ate fees or commissions, the historical or expected size or number of transac@ons, and the number and range of supplementary advisory and client-related services provided to the client, the amount of this compensa@on may be more or less than what the WELLth Advisory Services would receive if the client par@cipated in other programs, whether through LPL or another sponsor, or paid separately for investment advice, brokerage and other services. The account fee may be higher than the fees charged by other investment advisers for similar services. Clients should consider the level and complexity of the advisory services to be provided when nego@a@ng the account fee (or the advisor fee por@on of the account fee, as applicable) with WELLth Advisory Services. Please refer to the relevant LPL Form ADV program brochure for a more detailed discussion of conflicts of interest for each LPL Financial sponsored advisory program. Use of Subadvisors WELLth Advisory Services may u@lize the services of subadvisors to manage client assets. A subadvisor is a third- party asset management firm that manages all or a por@on of a client’s poroolio. This approach allows us to leverage the specialized exper@se and investment strategies of subadvisors, providing our clients with access to a broader range of investment opportuni@es. Selec=on and Monitoring of Subadvisors We undertake a rigorous process to select subadvisors, which includes both quan@ta@ve and qualita@ve analysis. Factors considered include the subadvisor’s investment philosophy, performance track record, risk management process, and the experience and stability of their management team. Once selected, subadvisors are subject to ongoing monitoring and evalua@on to ensure their performance and adherence to investment guidelines meet our standards. Role and Responsibili=es Subadvisors have discre@on over investment decisions within the guidelines set forth in their respec@ve subadvisory agreements. They are responsible for day-to-day management of the assets allocated to them, including decisions regarding the purchase, sale, and @ming of investment transac@ons. However, we retain overall responsibility for the management of the client’s poroolio and the ac@ons of the subadvisor. Fees and Compensa=on The fees charged by subadvisors are typically included in the overall management fee we charge to clients. In some cases, subadvisors may charge a separate fee, which will be disclosed to clients prior to engaging the subadvisor’s services. All fees associated with the use of subadvisors will be clearly outlined in the client agreement and any amendments thereto. Disclosure and Conflicts of Interest Page 8 of 25 CRD # 330537  We disclose all material rela@onships with subadvisors and any poten@al conflicts of interest. We have policies and procedures in place to manage and mi@gate any such conflicts. Our objec@ve is to ensure that our use of subadvisors serves the best interests of our clients. Clients are encouraged to review the subadvisor's Form ADV Part 2A for detailed informa@on about their services, fees, and any poten@al conflicts of interest. Termina=on of Subadvisor Rela=onships We reserve the right to terminate our rela@onship with any subadvisor at our discre@on. Reasons for termina@on may include, but are not limited to, performance issues, changes in the subadvisor’s personnel or ownership, or a determina@on that the subadvisor is no longer a good fit for our clients’ investment needs. Clients will be no@fied of any such changes and provided with informa@on regarding the impact on their poroolio. Assets Under Management and Advisement As of March 31, 2025, WELLth Advisory Services manages a total of $23,574,040,155 regulatory assets under management, which includes $7,241,106,603 of discre@onary assets under management, and $16,332,933,553 of non-discre@onary assets under management. Item 5: Fees and CompensaAon WELLth Advisory Services charges the fees iden@fied below, but fees are nego@able on a client-by-client basis. Re#rement Plan Services The WELLth Advisory Services fee and billing procedures are described in the Agreement between the client and WELLth Advisory Services; these fees are nego@able. As a result, we do not have a standard fee schedule that applies to all Clients. The only fees received by WELLth Advisory Services are those fees described in the Agreement. The Agreement provides for asset-based, flat fee, hybrid, and project-based fee billing. Clients receive an invoice or, alterna@vely, they may elect to pay the fee directly or instruct their custodian to pay the fee from plan assets without receipt of an invoice. Unless specifically nego@ated with the Sponsor, asset-based fees do not include the value of any assets invested in Plan par@cipants' self-directed brokerage accounts ("SDBAs") nor par@cipant loans or other investments that may be defined as excluded investments from the arrangement, as iden@fied in the agreement with the Client. Fees may be paid on a monthly or quarterly basis, to be determined by WELLth Advisory Services and its clients, which may be limited by the capabili@es of the plaoorm that Client selects (e.g., recordkeeper capabili@es). Fees are due upon receipt of statement, if applicable. When billed as an asset-based fee in advance, Fees will be based on the value of Plan assets at the beginning of the current period. When in arrears, Fees will be based on the value of Plan assets at the end of the period. For some services, fees must be paid directly by Client and not from plan assets due to the nature of the services (e.g., seplor-related services and associated fees). These services are clearly iden@fied on the agreement between client and Sponsor. Wealth Management Services Direct Asset Management Fees: Maximum Annual Fee Assets Under Management $1,000,000 or Under $1,001,000 to $2,000,000 2.0% 1.5% Over $2,000,001 1.0% Page 9 of 25 CRD # 330537  Fees for LPL Advisory Programs The account fee charged to the client for each LPL advisory program is negotiable, subject to the following maximum account fees: Manager Access Select OMP PWP MWP GWP 2.95%* 2.5% 2.95% ** 2.65%*** 1.35%**** * The Manager Access Select (“MAS”) account fee consists of an advisory fee of up to 2.35% annually and a manager fee of up to 0.60%. See the MAS program brochure for more informa@on. ** The PWP account fee consists of an advisory fee of up to 2.35% annually and a manager fee of up to 0.60%. See the PWP program brochure for more informa@on. *** The MWP account fee consists of an advisory fee of up to 2.35% and a manager fee of up to 0.60%. See the MWP program brochure for more informa@on. **** GWP clients are charged an account fee consis@ng of an LPL program fee of 0.35% and an advisor fee of up to 1.00%. LPL Research currently serves as the sole poroolio strategist and does not charge a fee for its services. Account fees are payable quarterly in advance. LPL serves as program sponsor, co-investment adviser and broker- dealer for the LPL advisory programs. WELLth Advisory Services and LPL may share in the account fee and other fees associated with program accounts. Associated persons of WELLth Advisory Services may also be registered representa@ves of LPL. GWP Educa@onal Tool provides access to sample recommenda@ons at no charge to users. However, if users decide to implement sample recommenda@ons by execu@ng trades, they will be charged fees, commissions, or expenses by the applicable broker or advisor, as well as underlying investment fees and expenses. For clients that are billed on a quarterly basis, fees will be calculated based upon the ending market value of the plan assets as of the last day of the prior quarter Clients may authorize the investment provider or custodian to pay compensa@on directly to WELLth Advisory Services by deduc@ng the advisory fee directly from the client’s account. As part of this process, the client understands and acknowledges the following: • • • • The independent custodian sends statements at least quarterly to the client reflec@ng the market values for each security included in the assets and all disbursements in the client’s account including the amount of the advisory fees paid to WELLth Advisory Services; The client provides authoriza@on permirng WELLth Advisory Services to be directly paid by these terms; For accounts u@lizing LPL as the custodian, LPL will perform the billing and will take instruc@on from the client to calculate and deduct advisory fees. For accounts that are not held at LPL, we generally send a copy of our invoice to the independent custodian at the same @me we send the invoice to our client; The invoice includes a legend that urges the client to compare informa@on provided in their statements with those from the qualified custodian in account opening no@ces and subsequent statements sent to the client. For advisory accounts custodied at LPL, unless otherwise instructed by the Advisor, LPL will deduct Advisor’s fee quarterly in advance; however, for the ini@al fee deduc@on, LPL will deduct the Advisor’s fee at the beginning of the quarter following the establishment of the Account and will include a prorated fee for the ini@al quarter in addi@on Page 10 of 25 CRD # 330537  to the quarterly Advisor fee for the upcoming quarter. Subsequent fee deduc@ons will be made at the beginning of each quarter based on the value of the Account assets as of the close of business on the last business day of the preceding quarter. Addi@onal deposits and withdrawals will be added or subtracted from the assets, which may lead to an adjustment of the Advisor’s fee. If LPL is no@fied by Advisor or the client of the termina@on or deac@va@on of the Account’s advisory account status at LPL, LPL will process a prorated refund of Advisor’s fees that were prepaid based upon the number of days remaining in the quarter ajer the no@ce of termina@on to LPL. For clients who choose to be billed in advance, if the client wishes to terminate our services, we will refund the unearned por@on of our advisory fee to the client. Clients will be required to contact us in wri@ng in order to terminate our services. Upon receipt of a client’s leper of termina@on, we will proceed to close out or remove our access to the client’s account and process a pro-rated refund of unearned advisory fees. Hourly and Fixed Fee Financial Planning Fees: WELLth Advisory Services will charge on an hourly or fixed fee basis for financial planning and consul@ng services. The total es@mated fee will be based on the @me, scope, and complexity of our engagement with clients. Generally, Financial Planning fees are fixed based on an es@mated number of hours but in some cases financial planning may be offered on an actual hourly basis. The fee for financial planning can be based on an hourly or fixed rate depending on the nature of the planning but generally $250 to $30,000. Fixed fees are generally paid 50% in advance with the balance due upon comple@on. Hourly fees are generally charged as they incur. The applicable fee is determined by the scope and complexity of a par@cular Client’s financial situa@on as well as the amount of @me and exper@se required. In some case a fee greater or lesser than the typical fee range may be warranted. In the case of fixed fee financial planning, payment for services will be according to individual arrangement. In general, a por@on of the fee is paid in advance with the balance paid upon the comple@on and presenta@on of the project. In all cases, we will not require a retainer exceeding $1,200.00 if services cannot be undertaken within 6 (six) months. Third-party Asset Management Program Sponsor Fees: IARs may recommend the use of other independent investment advisors or third-party asset management program sponsors that provide specialized investment advisory services to meet the needs and objec@ves of certain WELLth Advisory Services clients. These advisors will charge advisory fees independent of WELLth Advisory Services. A por@on of the advisory fee will be paid to WELLth Advisory Services. Clients u@lizing the services of third-party asset managers will receive documenta@on from the manager including an asset management agreement and disclosure of services to be provided and fees to be charged. The client will receive a disclosure brochure from WELLth Advisory Services and from the independent manager. Accounts managed by third-party asset managers will be subject to the terms of the specific agreement and cancella@on policy of the par@cular third-party asset manager. Addi=onal Fees and Expenses: WELLth Advisory Services’ fees are exclusive of brokerage commissions, transac@on fees, and other related costs and expenses which will be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third-party investment and other third par@es such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differen@als, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securi@es transac@ons. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addi@on to WELLth Advisory Services’ fee. Page 11 of 25 CRD # 330537  WELLth Advisory Services’ may markup the cost of Peopled, Inc. incurred by clients. Peopled, Inc. is a technology company that develops sojware and tools used to support recruitment, talent matching, and related human-capital func@ons. Its solu@ons are designed to automate or enhance hiring workflows and may integrate with third-party HR plaoorms. Peopled operates within the broader human-capital technology sector and does not provide investment advisory services. Refer to Item 14 (Client Referrals and Other Compensa@on) for more informa@on. Other than the previously disclosed situa@ons, WELLth Advisory Services’ affiliated en@@es, ownership interests, and outside business ac@vi@es described elsewhere in this Brochure do not affect the advisory fees charged to clients, and no por@on of WELLth Advisory Services fees is increased, passed through, or otherwise influenced by any compensa@on or revenue received by such affiliates. Commissionable Securi=es Sales: Certain investment adviser representa@ves of WELLth Advisory Services are also associated with LPL Financial as broker-dealer registered representa@ves (“Dually Registered Persons”). In their capacity as registered representa@ves of LPL Financial, certain Dually Registered Persons may earn commissions for the sale of securi@es or investment products that they recommend for brokerage clients. They do not earn commissions on the sale of securi@es or investment products recommended or purchased in advisory accounts through WELLth Advisory Services. Clients have the op@on of purchasing many of the securi@es and investment products we make available to you through another broker-dealer or investment adviser. However, when purchasing these securi@es and investment products away from WELLth Advisory Services, you will not receive the benefit of the advice and other services we provide. While LPL Financial does not par@cipate in, or influence the formula@on of, the investment advice WELLth Advisory Services provides, certain supervised persons of WELLth Advisory Services are Dually Registered Persons. Dually Registered Persons are restricted by certain FINRA rules and policies from maintaining client accounts at another custodian or execu@ng client transac@ons in such client accounts through any broker-dealer or custodian that is not approved by LPL Financial. As a result, the use of other trading plaoorms must be approved not only by WELLth Advisory Services, but also by LPL Financial. Clients should also be aware that for accounts where LPL Financial serves as the custodian, WELLth Advisory Services is limited to offering services and investment vehicles that are approved by LPL Financial, and may be prohibited from offering services and investment vehicles that may be available through other broker-dealers and custodians, some of which may be more suitable for a client’s poroolio than the services and investment vehicles offered through LPL Financial. Clients should understand that not all investment advisers require that clients custody their accounts and trade through specific broker-dealers. Clients should also understand that LPL Financial is responsible under FINRA rules for supervising certain business ac@vi@es of WELLth Advisory Services and its Dually Registered Persons that are conducted through broker-dealers and custodians other than LPL Financial. LPL Financial charges a fee for its oversight of ac@vi@es conducted through these other broker-dealers and custodians. This arrangement presents a conflict of interest because WELLth Advisory Services has a financial incen@ve to recommend that you maintain your account with LPL Financial rather than with another broker-dealer or custodian to avoid incurring the oversight fee. Page 12 of 25 CRD # 330537  Item 6: Performance Based Fees WELLth Advisory Services does not charge fees based on a share of capital gains or on capital apprecia@on of the assets of a client and therefore does not simultaneously manage performance based and non-performance-based accounts. Item 7: Types of Clients WELLth Advisory Services works with the following types of clients: Individuals and high net worth individuals. Pension, re@rement, and profit-sharing plans. • • • Corpora@ons, Limited Liability Companies and/or other Ins@tu@ons. In general, WELLth Advisory Services does not have a minimum amount to open and maintain an account, however certain third-party asset managers and IARs may require a minimum investment in order to open a managed account. The specific amounts are detailed in the third-party asset managers’ agreements or in the WELLth Advisory Services agreement, as nego@ated by the client and WELLth Advisory Services. Accounts below the stated minimums may be accepted on an individual basis at the discre@on of WELLth Advisory Services and the plaoorm sponsor. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss WELLth Advisory Services’ business model is targeted to each IAR’s individual investment style, strategy, and philosophy, taking into considera@on clients’ specific objec@ves and goals. The IAR’s methods of investment analysis and strategies may vary from one office to another. The following details the types of analysis IARs use to formulate client recommenda@ons: • Fundamental Analysis: We apempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry condi@ons, and the financial condi@on and management of the company itself) to determine if the company is underpriced (indica@ng it may be a good @me to buy) or overpriced (indica@ng it may be @me to sell). Fundamental analysis does not apempt to an@cipate market movements. This presents a poten@al risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evalua@ng the stock. • • Char@ng: In this type of technical analysis, we review charts of market and security ac@vity in an apempt to iden@fy when the market is moving up or down and to predict when how long the trend may last and when that trend might reverse. Technical Analysis: We analyze past market movements and apply that analysis to the present in an apempt to recognize recurring paperns of investor behavior and poten@ally predict future price movements. Technical analysis does not consider the underlying financial condi@on of a company. This presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement. • Cyclical Analysis: In this type of technical analysis, we measure the movements of a par@cular stock against the overall market in an apempt to predict the price movement of the security. • Mutual Fund and/or ETF Analysis: IARs review the experience and track record of the manager of the mutual fund or ETF in an apempt to determine if that manger has demonstrated an ability to invest successfully over a period of @me and in different economic condi@ons. IARs also look at the underlying assets in a mutual fund or ETF in an apempt to determine if there is a significant overlap in the underlying Page 13 of 25 CRD # 330537  investments held in other funds in the client’s poroolio. A risk of mutual fund and/or ETF analysis is that, as with all securi@es investments, past performance does not guarantee future results. Risks for all forms of analysis: The WELLth Advisory Services securi@es analysis methods rely on the assump@on that the companies whose securi@es we purchase and sell, the ra@ng agencies that review these securi@es, and other publicly available sources of informa@on about these securi@es, provide accurate and unbiased data. While we are alert to indica@ons that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading informa@on. For ERISA plans in which par@cipants direct the investments in their accounts, WELLth Advisory Services seeks to ensure that the plan complies with the ERISA 404(c) requirement for the “broad array” of investment op@ons to enable par@cipants to develop a diversified poroolio. Investment Strategies: • • • Long-Term Purchases: When u@lizing this strategy, we may purchase securi@es with the idea of holding them for a rela@vely long @me (typically held for at least a year). A risk in a long-term purchase strategy is that by holding the security for this length of @me, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predic@ons are incorrect, a security may decline sharply in value before we make the decision to sell. Typically, we employ this sub-strategy when we believe the securi@es to be well valued; and/or we want exposure to a par@cular asset class over @me, regardless of the current projec@on for this asset class. Short-Term Purchases: When u@lizing this strategy, we may also purchase securi@es with the idea of selling them within a rela@vely short @me (typically a year or less). We do this in an apempt to take advantage of condi@ons that we believe will soon result in a price swing in the securi@es we purchase. Trading: We purchase securi@es with the idea of selling them very quickly (typically within 30 days or less). We do this in an apempt to take advantage of our predic@ons of brief price swings. Inves@ng always involves some risk, whether securi@es, cer@ficates of deposit or in any other type of investment. There is risk of loss of principal and also risk of loss of purchasing (‘buying”) power. WELLth Advisory Services’ objec@ve is to help clients understand the different types of risk and mi@gate the risk over @me. One way to lessen risk is to diversify investment poroolios so that when some fall in value, others may rise in value. Securi@es investments are not guaranteed, and clients may lose money on their investments, including their principal. Past performance is no guarantee of future results. We ask that clients work with us to help us understand their tolerance for risk. Depending on the type of securi@es selected, some addi@onal risk factors (below) could become relevant and should be discussed with the Advisory Associate. Addi@onal Risk Factors: • Market Risk: Risk that cannot be mi@gated through diversifica@on because an event of great magnitude (such as recession, poli@cal turmoil, natural disaster, terrorist apack) has occurred that impacts the markets systemically. • Infla@on Risk: Risk that an investor may lose some of their purchasing power if the investment does not outpace infla@on. This can be an issue for “safe-haven” instruments like money market funds or treasury bills. • Equity Risk: Risk that shares of stock, which have no guaranteed returns, could decline in value based on low demand, business challenges or broader economic factors. Also, if a company Page 14 of 25 CRD # 330537  becomes insolvent for whatever reason, common stockholders have a low priority claim on remaining assets ajer secured credit holders, subordinated bondholders, and preferred stockholders. • Liquidity Risk: Risk of loss from inability to liquidate shares promptly at a desirable price. Some investments, such as interval funds, have limited quarterly liquidity windows, while other investments might be in low demand. Alterna@ve investments, such as non-traded REITs, are ojen en@rely illiquid for 5 years or more un@l a single liquidity event occurs. • Interest Rate Risk: Risk that interest rates could rise, making a currently held bond with a lower interest rate less valuable to a prospec@ve buyer because higher rates are readily available. • Longevity Risk: Risk that an investor, especially a re@ree, will outlive their investment income. • Currency Risk: Risk that an overseas investment will fluctuate as a result of the exchange rate between the US dollar and the currency of the country where the asset is held. • Time Horizon Risk: Risk that an investor may face an unexpected change to their planned @me horizon, such as a disability, job loss, divorce, etc. • Default Risk: Risk that a bond issuer will become insolvent and default on their obliga@on to make interest payments to debtholders/investors. Item 9: Disciplinary InformaAon We are required to disclose whether there are legal or disciplinary events that are material to a client’s or prospec@ve client’s evalua@on of our advisory business or the integrity of our management. If our firm or IARs have been involved in one of these events, we must disclose that informa@on in our Form ADV Part 2A brochure for ten years following the date of the event, unless (1) the event was resolved in our or the IAR’s favor, or was reversed, suspended, or vacated, or (2) the event is not material. WELLth Advisory Services and its employees and IARs have not been involved in any legal or disciplinary events in the past ten years that would be material to a client’s evalua@on of the company or its personnel. Item 10: Other Financial Industry AcAviAes and AffiliaAons WELLth Advisory Services is a wholly owned en@ty of SRP Holdings Group, LLC (“SRP”), headquartered in Shorewood, Illinois. SRP is an independent re@rement plan consul@ng prac@ce whose professionals advise on re@rement plans, suppor@ng plan sponsors in understanding and managing their fiduciary responsibili@es to their plan, their employees, and their beneficiaries. WELLth Advisory Services and certain of its principals and supervised persons maintain ownership interests or governance roles in several Affiliated En@@es that may operate within the re@rement-plan, investment-management, and financial-technology sectors. These affilia@ons include SRP Holdings Group, LLC (the WELLth Advisory Services’ parent) and its subsidiary, SRP Risk Management, LLC, as well as advisor-owned vehicles such as SRP Ventures, SPR Ventures II, III, IV, V, VI, and Given To Fly, LLC, which in turn may hold minority investments in other en@@es. In some instances, the WELLth Advisory Services senior personnel serve in board or advisory capaci@es at these affiliated en@@es, and certain affiliates may develop or maintain opera@onal, distribu@on, or commercial rela@onships with WELLth Advisory Services. These affilia@ons create poten@al conflicts of interest because WELLth Advisory Services and its personnel may benefit financially or otherwise from the success of these affiliated en@@es. WELLth Advisory Services maintains policies and supervisory procedures designed to ensure that its fiduciary duty to clients is upheld and that recommenda@ons involving any affiliated service or plaoorm are evaluated solely on the basis of client interests. In addi@on, all IARs are required to disclose any outside business ac@vi@es, board posi@ons, ownership interests, or other compensated or uncompensated roles in their Form ADV Part 2B. WELLth Advisory Services reviews each IAR’s ADV Part 2B supplement at onboarding and at least annually, as well as upon any material change, Page 15 of 25 CRD # 330537  to ensure that outside affilia@ons are properly reported, assessed for conflicts of interest, and supervised in accordance with the WELLth Advisory Services’ policies and applicable regulatory requirements. Clients are encouraged to carefully review Item 5 (Fees and Compensation) and Item 14 (Client Referrals and Other Compensation) for information about the fees charged by WELLth Advisory Services and, where applicable, the fees charged by any Affiliated Entity. In circumstances where an Affiliated Entity charges additional fees, WELLth Advisory Services will disclose those fees prior to or at the time of engagement. Clients retain the right to select service providers other than the Affiliated Entity and are not obligated in any way to engage such affiliates. WELLth Advisory Services will only recommend or utilize an Affiliated Entity when it reasonably believes doing so is in the client’s best interest. Certain WELLth Advisory Services IARs are dually registered persons with LPL. LPL is a broker-dealer that is independently owned and operated and is not affiliated with WELLth Advisory Services. Please refer to Item 12 for a discussion of the benefits WELLth Advisory Services may receive from LPL and the conflicts of interest associated with receipt of such benefits. Dually registered persons may recommend securi@es transac@ons for individuals or en@@es who are also WELLth Advisory Services clients. Under those circumstances, LPL will pay these individuals a por@on of the brokerage commissions received for brokerage products that they sell. This creates an inherent conflict of interest in that an IAR may receive an investment advisory fee and a securi@es commission. If LPL is the broker for a plan for whom WELLth Advisory Services is providing investment advice, neither WELLth Advisory Services nor its IARs are permiped to receive any brokerage commissions generated from the plan’s investments, except to the extent that those commissions are used to offset the WELLth Advisory Services advisory fee. All ac@vi@es are disclosed in wri@ng to the WELLth Advisory Services Compliance Department. IARs may receive compensa@on from these ac@vi@es. Clients are not obligated to obtain these services through WELLth Advisory Services IARs. As discussed previously, certain WELLth Advisory Services Investment Advisory Representa@ves are registered representa@ves with LPL. As a result of this rela@onship, LPL may have access to certain confiden@al informa@on (e.g., financial informa@on, investment objec@ves, transac@ons, and holdings) about WELLth Advisory Services’ clients, even if the client does not establish any account through LPL. If you would like a copy of the LPL privacy policy, please contact Sarah Hughes at 866-777-4015. Amplify PlaAorm WELLth Advisory Services investment adviser representa@ves u@lize the Amplify Plaoorm, the Amplify Plaoorm provides back-office opera@onal support services such as administra@ve, trading and repor@ng services and/or gain access to and select from independent third-party managers available through the Amplify Plaoorm. Upon execu@ng the Plaoorm Agreement, the investment adviser firm or investment professional shall be considered a Plaoorm Member. Plaoorm Members may choose to receive certain back-office services, such as administra@ve, trading and repor@ng services and/or to select independent third-party managers to manage underlying client assets on a sub-advisory basis. Plaoorm Members may choose to allocate all or a por@on of their underlying client’s assets among the different independent investment managers available through the Amplify Plaoorm on a discre@onary basis. Plaoorm Members shall have a direct contractual rela@onship with each of their underlying clients and obtain, through such agreements, the authority to engage Amplify Plaoorm for services rendered through the Plaoorm. WELLth Advisory Services engages unaffiliated investment advisers to service Plaoorm Members as sub-advisers. Sub-advisers available through the Amplify Plaoorm will perform discre@onary investment management services and shall manage, invest and reinvest the Plaoorm Member’s underlying client assets designated by the Plaoorm Member. As such, a selected manager(s) shall be authorized, without prior consulta@on with the Plaoorm Member Page 16 of 25 CRD # 330537  or the underlying client, to buy, sell trade or allocate the underlying client’s assets in accordance with the underlying client’s investment objec@ves and to deliver instruc@ons in furtherance this responsibility to the underlying client’s broker-dealer and or custodian. Plaoorm Members retain responsibility for the underlying client rela@onship, including the ini@al and ongoing suitability determina@on. Plaoorm Members shall also retain the responsibility for implemen@ng client investment recommenda@ons in accordance with the Plaoorm Member’s fiduciary duty to the underlying client. Plaoorm Members are responsible for obtaining and furnishing informa@on pertaining to sub-advisor selec@on and underlying client account guidelines along with any reasonable account restric@ons. Please note: WELLth Advisory Services’ investment adviser representa@ves are required to u@lize the various services available through the Amplify Plaoorm. Therefore, WELLth Advisory Services clients may incur fees in addi@on to the fee associated with the advisory services provided to the client. Item 11: Code of Ethics, ParAcipaAon or Interest in Client TransacAons and Personal Trading We have established a Code of Ethics which applies to our IARs. 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 and to act solely in the best interest of each of our clients at all @mes. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securi@es Transac@ons Policies and Procedures. We require all of our IARs to conduct business with the highest level of ethical standards and to comply with all federal and state securi@es laws at all @mes. Upon employment or affilia@on and at least annually thereajer, all IARs will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and IARs must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might nega@vely affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a poten@al client wishes to review our Code of Ethics in its en@rety, a copy will be provided promptly upon request. If our firm or an IAR recommends to clients, or buys or sells for client accounts, securi@es in which our firm or an IAR has a material financial interest (excluding an interest as a shareholder of an SEC-registered, open-end investment company), we must describe our prac@ce and discuss the conflicts of interest it presents. Neither our firm nor a related person recommends to clients, or buys or sells for client accounts, securi@es in which we or an IAR has a material financial interest. If our firm or an IAR invests in the same securi@es (or related securi@es, e.g., warrants, op@ons, or futures) that our firm or an IAR recommends to clients, we are required to describe our prac@ce and discuss the conflicts of interest this presents and generally how we address the conflicts that arise in connec@on with personal trading. IARs may buy or sell securi@es and other investments that are also recommended to clients. In order to minimize this conflict of interest, IARs will place client interests ahead of our own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. If our firm or an IAR recommends securi@es to clients, or buys or sells securi@es for client accounts, at or about the same @me that you or an IAR buys or sells the same securi@es for our firm’s (or the related person's own) account, we are required to describe our prac@ce and discuss the conflicts of interest it presents. We are also required to describe generally how we address conflicts that arise. IARs may buy or sell securi@es for themselves at or about the same @me they buy or sell the same securi@es for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. If related persons’ accounts are included in a block trade, our related persons will always trade personal accounts last. Page 17 of 25 CRD # 330537  Item 12: Brokerage PracAces Clients may specify which broker-dealer to use for custodial services or if requested, WELLth Advisory Services may make recommenda@ons. These recommenda@ons are based on WELLth Advisory Services’ percep@on of the breadth of services offered, and quality of execu@on. WELLth Advisory Services generally u@lizes the services of LPL, and Charles Schwab & Co. Inc. (“Schwab”). WELLth Advisory Services will generally recommend that clients establish a brokerage account with LPL to maintain custody of clients’ assets and to effect trades for their accounts. LPL provides brokerage and custodial services to independent investment advisory firms, including WELLth Advisory Services. For WELLth Advisory Services’ accounts custodied at LPL, LPL generally is compensated by clients through commissions, trails, or other transac@on-based fees for trades that are executed through LPL or that seple into LPL accounts. For IRA accounts, LPL generally charges account maintenance fees. In addi@on, LPL also charges clients miscellaneous fees and charges, such as account transfer fees. LPL charges WELLth Advisory Services an asset-based administra@on fee for administra@ve services provided by LPL. Such administra@on fees are not directly borne by clients but may be considered when WELLth Advisory Services nego@ates its advisory fee with clients. While LPL does not par@cipate in, or influence the formula@on of, the investment advice WELLth Advisory Services provides, certain supervised persons of WELLth Advisory Services are Dually Registered Persons. Dually Registered Persons are restricted by certain FINRA rules and policies from maintaining client accounts at another custodian or execu@ng client transac@ons in such client accounts through any broker-dealer or custodian that is not approved by LPL. As a result, the use of other trading plaoorms must be approved not only by WELLth Advisory Services, but also by LPL. Clients should also be aware that for accounts where LPL serves as the custodian, WELLth Advisory Services is limited to offering services and investment vehicles that are approved by LPL and may be prohibited from offering services and investment vehicles that may be available through other broker-dealers and custodians, some of which may be more suitable for a client’s poroolio than the services and investment vehicles offered through LPL. Clients should understand that not all investment advisors require that clients’ custody their accounts and trade through specific broker-dealers. Clients should also understand that LPL is responsible under FINRA rules for supervising certain business ac@vi@es of WELLth Advisory Services and its Dually Registered Persons that are conducted through broker-dealers and custodians other than LPL. LPL charges a fee for its oversight of ac@vi@es conducted through these other broker- dealers and custodians. This arrangement presents a conflict of interest because WELLth Advisory Services has a financial incen@ve to recommend that you maintain your account with LPL rather than with another broker-dealer or custodian to avoid incurring the oversight fee. Transition Assistance Benefits LPL also provides various benefits and/or payments to IARs that are new to the LPL plaoorm to assist them with the costs (including foregone revenues during account transi@on) associated with transi@oning their business to LPL (collec@vely referred to as “Transi@on Assistance”). The proceeds of such Transi@on Assistance payments are intended to be used for a variety of purposes, including but not necessarily limited to, providing working capital to assist in funding the IAR’s business, sa@sfying any outstanding debt owed to the IAR’s prior firm, offserng account transfer fees (ACATs) as a result of the IAR’s clients transi@oning to LPL’s custodial plaoorm, technology set-up fees, marke@ng and mailing costs, sta@onary and licensure transfer fees, moving expenses, office space expenses, staffing support and termina@on fees associated with moving accounts. The amount of the Transi@on Assistance payments is ojen significant in rela@on to the overall revenue earned or compensa@on received by the IAR at their prior firm. Such payments are generally based on the size of the IAR’s business established at the prior firm. These payments are generally in the form of payments or loans to the IAR with favorable interest rate terms as compared to other lenders, which are paid by LPL or forgiven by LPL based on years Page 18 of 25 CRD # 330537  of service with LPL (e.g., if the IAR remains with LPL for 5 years) and/or the scope of business engaged in with LPL. LPL does not verify that any payments made are actually used for such transi@on costs. The receipt of Transi@on Assistance creates a conflict of interest in that WELLth Advisory Services has a financial incen@ve to recommend that a client open and maintain an account with the IAR and LPL for advisory, brokerage and/or custody services, and to recommend switching investment products or services where a client’s current investment op@ons are not available through LPL, in order to receive the Transi@on Assistance benefit or payment, and in cases of businesses not supported by LPL, to further recommend that a client’s current holdings be reinvested in a program offering LPL does support. LPL and WELLth Advisory Services’ apempt to mi@gate these conflicts of interest by evalua@ng and recommending that clients use LPL’s services based on the benefits that such services provide to clients, rather than the Transi@on Assistance earned by any par@cular WELLth Advisory Services. However, clients should be aware of this conflict and take it into considera@on in making a decision whether to establish or maintain a rela@onship with LPL. If LPL makes a loan to WELLth Advisory Services, there is also a conflict of interest because LPL’s interest in collec@ng on the loan affects its ability to objec@vely supervise the registered representa@ves. Schwab Adviser Services Disclosures – Choice of Custodian & Benefits Certain IARs may select Schwab for their clients’ custodial needs. Schwab provides WELLth Advisory Services with access to its ins@tu@onal trading and custody services, which are typically not available to Schwab retail investors. Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that seple into your Schwab account. Certain trades (e.g., mutual funds or ETFs) do not incur Schwab commissions or transac@on fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. For some accounts, Schwab charges you a percentage of the dollar amount of assets in the account in lieu of commissions. In addi@on to commissions and asset-based fees, Schwab would charge you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that, if applicable, a Third Party Asset Manager executes for our clients at a different broker- dealer, but where securi@es bought or the funds from securi@es sold are deposited (sepled) into your Schwab account. These fees would be in addi@on to the commissions or other compensa@on you pay the execu@ng broker-dealer. Because of this, in order to minimize your trading costs, we seek and encourage you and your IAR to execute trading costs through the Schwab (or other custodians that you may u@lize as part of WELLth Advisory Services’ service). Trading away can sacrifice best execu@on and incur addi@onal costs from the other firm, as well as fees from our custodians to transfer in those posi@ons. Products and Services Available to Us from Schwab Schwab Adviser Services™ serves independent investment advisory firms like WELLth Advisory Services. They provide our clients with access to their ins@tu@onal brokerage services (trading, custody, repor@ng and related services), many of which are not available to Schwab retail customers. However, certain retail investors may be able to get ins@tu@onal brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage and grow our business. Schwab’s support services are generally available on an unsolicited business (WELLth Advisory Services does not have to request them) and at no cost to us. The following material provides a more detailed descrip@on of Schwab support services. Services that benefit you. Schwab ins@tu@onal brokerage services include access to a broad range of investment products, execu@on of securi@es transac@ons and custody of client assets. The investment products made available through Schwab include some of which you might not otherwise have access to or that would require a significantly higher minimum ini@al investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Service that do not directly benefit you. Schwab also makes available other products and services that benefit us but do not directly benefit you and or your account. These products and services assist us in managing and administering our clients’ accounts and opera@ng Page 19 of 25 CRD # 330537  our firm. They include investment research, both Schwab’s own and that of 3rd par@es. We use this research to service all or a substan@al number of our clients’ accounts, including accounts not maintained in Schwab. In addi@on to investment research, Schwab also makes available sojware and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) Facilitate trade execution and allocate aggregated trade orders for multiple client accounts Facilitate payment of our fees from other clients’ accounts • • Provide pricing and other market data • • Assist with back-office functions, recordkeeping, and client reporting We do not open accounts for you, although we may assist you in doing so. To the extent that your account is maintained at Schwab (or any other WELLth Advisory Services’ other custodians for that maper), and most trades may occur through Schwab or such other designated custodian, such custodians have the ability to use other brokers to execute trades for your account. Your Brokerage and Custody Costs For our client’s accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that seple into your Schwab account. Certain trades (for example, mutual funds and ETDs) do not incur Schwab commissions or transac@on fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. For some accounts, Schwab charges you a percentage of the dollar amount of the assets in the account in lieu of commissions. Educational conference and events; Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. The services include: • • Consulting on technology and business needs; • Consulting on legal and compliance-related needs; • Publications and conferences on practice management and business succession; • Access to employee benefits providers, human capital consultants and insurance providers; and • Marketing consulting and support. WELLth Advisory Services intends to use the benefit to cover some of the costs of its annual sales and due diligence conference for our investment advisory personnel and supervised persons. This is being included as a conflict of interest. It serves as an incen@ve to use Schwab over other custodians. At the same @me, WELLth Advisory Services included a disclosure that WELLth Advisory Services obtains financial benefit when WELLth Advisory Services or its personnel invite product providers, such as a mutual fund company, insurance company and private placement sponsor, to a meal, educa@onal or entertainment events, and they pay the bills for such events. Schwab provides some of these services itself. In other cases, it will arrange for 3rd party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or part of the 3rd party fees. Schwab may also provide us with other benefits, such as occasional business entertainment for our personnel. Our interest in Schwab’s services, as well as the service of other Custodians. The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s ancillary services. Schwab has also agreed to pay for certain technology, research, marke@ng, and compliance consul@ng products and services on our behalf. The fact that we receive these benefits from Schwab is an incen@ve for us to recommend/request the use of Schwab rather than making such a decision Page 20 of 25 CRD # 330537  based exclusively on your interest in receiving the best value in custody services and the most favorable execu@on of your transac@ons. This is a conflict of interest. We believe, however, that taken in the aggregate, whichever custodian we use, our selec@on of the custodians, whether Schwab or otherwise, as custodian and broker is driven by the Best Interest of our clients. Our selec@on is primarily supported by the scope, quality, and price of custodian’s services and not services that benefit only us. Research and Other Soft Dollar Benefits WELLth Advisory Services does not engage in soj dollar benefits. WELLth Advisory Services does not use client brokerage commissions (or markups or markdowns) to obtain research or other products or services. Block Trading: WELLth Advisory Services may combine orders into block trades when more than one account is par@cipa@ng in the trade. This blocking or bunching technique must be equitable and poten@ally advantageous for each such account (e.g., for the purposes of reducing brokerage commissions or obtaining a more favorable execu@on price). Block trading is performed when it is consistent with the duty to seek best execu@on and is consistent with the terms of WELLth Advisory Services’ investment advisory agreements. Equity trades are blocked based upon fairness to the client, both in the par@cipa@on of their account, and in the alloca@on of orders for the accounts of more than one client. Alloca@ons of all orders are performed in a @mely and efficient manner. All managed accounts par@cipa@ng in a block execu@on receive the same execu@on price (average share price) for the securi@es purchased or sold in a trading day. Any por@on of an order that remains unfilled at the end of a given day will be rewripen on the following day as a new order with a new daily average price to be determined at the end of the following day. Due to the low liquidity of certain securi@es, broker availability may be limited. Open orders are worked un@l they are completely filled, which may span the course of several days. If an order is filled in its en@rety, securi@es purchased in the aggregated transac@on will be allocated among the accounts par@cipa@ng in the trade in accordance with the alloca@on statement. If an order is par@ally filled, the securi@es will be allocated pro rata based on the alloca@on statement. WELLth Advisory Services may allocate trades in a different manner than indicated on the alloca@on statement (non-pro rata) only if all managed accounts receive fair and equitable treatment. Best Execu@on: On an annual basis, custodial broker-dealers are interviewed to compare the services and fees offered by the different firms. Best execu@on is not the only factor to be considered in providing investment management services to clients. We believe that both LPL and Schwab provide clients with an appropriate level of execu@on quality for our clients’ transac@ons. In addi@on, they provide our firm and our clients with other valuable informa@on on their accounts both electronically and by mail. They also provide a forum for advisory professionals to meet and to discuss compliance issues, rules and regula@ons that are important for the client and for our firm. We will review our agreement with the custodial broker-dealers on an annual basis and will compare them with firms offering comparable services to investment advisory firms and their clients. Item 13: Review of Accounts WELLth Advisory Services may prepare individualized reports, the nature and frequency are determined by client need and the services offered. However, as clients may request, WELLth Advisory Services may provide quarterly or semi-annual reports. Client accounts are reviewed on a quarterly basis by the IAR, and a sampling of client accounts is reviewed on a monthly basis by the WELLth Advisory Services Compliance Department. Generally, when WELLth Advisory Services is contracted for a financial plan, IARs do not perform ongoing account reviews unless they retain WELLth Advisory Services for those services. We are available to meet with clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Page 21 of 25 CRD # 330537  Item 14: Client Referrals and Other CompensaAon WELLth Advisory Services does not engage in ac@vity with non-clients to gain economic benefits including sales awards or other prizes. WELLth Advisory Services and/or its Dually Registered Persons are incented to join and remain affiliated with LPL and to recommend that clients establish accounts with LPL through the provision of Transi@on Assistance (discussed in Item 12 above). LPL also provides other compensa@on to WELLth Advisory Services and its Dually Registered Persons, including but not limited to, bonus payments, repayable and forgivable loans, stock awards and other benefits. The receipt of any such compensa@on creates a financial incen@ve for the WELLth Advisory Services IAR to recommend LPL as custodian for the assets in client advisory accounts. Clients are encouraged to discuss any such conflicts of interest with the WELLth Advisory Services IAR before deciding to custody assets at LPL. WELLth Advisory Services may act as a referring agent and may also pay referral fees (non-commission based) to independent and/or affiliated promoters/solicitors for the referral of their clients to our firm in accordance with SEC regula@ons. Such referral fees represent a share of our investment advisory fee charged to our clients. This arrangement will not result in higher costs to you. In this regard, we maintain Promoter/Solicitors Agreements in compliance with SEC regula@ons. All clients referred by independent promoter/solicitors to our firm will be given full wripen disclosure describing the terms and fee arrangements between our firm and promoter/solicitor(s). In cases where state law requires licensure of promoter/solicitors, we ensure that no solicita@on fees are paid unless the promoter/solicitor is registered as an investment advisor representa@ve of our firm. If we are paying solicita@on fees to another registered investment advisor, the licensure of individuals is the other firm’s responsibility. From @me to @me, we receive a client referral from certain of our affiliates, including employees of SRP and our various divisions and SRP Risk Management, LLC. In these situa@ons, we compensate the referring affiliate for the referral. Actual payment is dictated by the role of the referring affiliate and internal organiza@onal compensa@on policies. Similarly, we and/or our employees may receive internal compensa@on for referring prospec@ve or current clients to affiliated SRP businesses. In these situa@ons, referral compensa@on is paid by our affiliates out of their own assets and is not paid directly by the client. Clients will not be charged addi@onal fees beyond our fees for the services provided by our affiliates. The amount of the referral credit could be calculated as a percent of the fees to be received in the referred client agreement over a specified period ajer the referral or as a flat fee. Such compensa@on policies are structured to mi@gate conflicts of interest and to comply with applicable law, including regula@ons and guidance applicable to client poroolios subject to ERISA and the applicable securi@es laws and regula@ons. Some affiliated entities in which WELLth Advisory Services’ supervised persons hold ownership or board roles may maintain referral arrangements, resale programs, or revenue-sharing agreements with WELLth Advisory Services or its parent company. For example, SRP Ventures V, LLC holds an interest in Peopled, Inc., which compensates SRP Holdings Group, LLC or WELLth Advisory Services for client usage, referrals, distribution of services, or other commercial activity. Additionally, WELLth Advisory Services and/or its principals hold an investment interest in Vestwell, which has received capital from SRP Ventures, LLC under terms that may result in a future contingent payment to SRP Ventures, LLC. This arrangement creates a potential conflict of interest if WELLth Advisory Services recommends clients to Vestwell, as such activity may indirectly benefit WELLth Advisory Services, its principals or its affiliates in the future. WELLth Advisory Services supervised persons may also resell or support certain affiliated products or platforms and may receive indirect financial benefits through their ownership interests. These compensation arrangements create conflicts of interest because they may provide incentives for WELLth Advisory Services or its personnel to recommend affiliated services or platforms over unaffiliated alternatives. WELLth Advisory Services mitigates these conflicts through disclosure, oversight, and its obligation as a fiduciary to place client interests ahead of its own. Clients may request further information regarding any referral or compensation arrangement involving an affiliated entity. See Item 5 (Fees and Compensation) for additional information. Page 22 of 25 CRD # 330537  Item 15: Custody Our firm does not have custody of client funds or securi@es. Regulators generally take the posi@on that any arrangement under which a registered investment advisor is authorized or permiped to withdraw client funds or securi@es maintained with a custodian upon the advisor’s instruc@on to the custodian is deemed to have custody of client funds and securi@es. As such, we have adopted the following safeguarding procedures: 1. For client accounts held at custodians other than LPL, the client must provide us with wripen authoriza@on permirng direct payment to us of our advisory fees from their account(s) maintained by a custodian who is independent of our firm; 2. For client accounts held at custodians other than LPL, we must send a statement to our clients showing the amount of our fee, the value of the assets upon which our fee was based, and the specific manner in which our fee was calculated; 3. We must disclose to you that it is your responsibility to verify the accuracy of our fee calcula@on, and that the custodian will not determine whether the fee is properly calculated; and 4. Your account custodian must agree to send you a statement, at least quarterly, showing all disbursements from your account, including advisory fees. We encourage our clients to raise any ques@ons with us about the custody, safety, or security of their assets. The custodians we do business with will send you independent account statements lis@ng your account balance(s), transac@on history and any fee debits or other fees taken out of your account. It is recommended that clients compare custodial brokerage statements to the reports that are provided to you by WELLth Advisory Services. As discussed previously, certain associated persons of WELLth Advisory Services are registered representa@ves of LPL Financial. As a result of this rela@onship, LPL Financial may have access to certain confiden@al informa@on (e.g., financial informa@on, investment objec@ves, transac@ons and holdings) about WELLth Advisory Services’ clients in order to supervise certain ac@vi@es of WELLth Advisory Services, even if client does not establish any account through LPL. WELLth Advisory Services receives support services and/or products from LPL Financial, many of which assist WELLth Advisory Services to beper monitor and service program accounts maintained at LPL Financial; however, some of the services and products benefit WELLth Advisory Services and not client accounts. These support services and/or products may be received without cost, at a discount, and/or at a nego@ated rate. Such compensa@on provided to WELLth Advisory Services includes other types of compensa@on, such as bonuses, awards or other things of value offered by LPL to WELLth Advisory Services, and, and may include the following: • • Payments based on produc@on; Equity awards from LPL’s parent company, LPL Financial Holdings Inc., consis@ng of awards of either restricted stock units or stock op@ons to purchase stock, in each case subject to sa@sfac@on of ves@ng and other condi@ons; • Reimbursement or credit of fees that WELLth Advisory Services pays to LPL for items such as administra@ve • • services or technology fees; Free or reduced-cost marke@ng materials; Payments in connec@on with the transi@on of associa@on from another broker-dealer or investment advisor firm to LPL; Payments in the form of repayable or forgivable loans; • • Advances of advisory fees; and/or • Apendance at LPL conferences and events. LPL Financial may provide these services and products directly or may arrange for third party vendors to provide the services or products to Advisor. In the case of third-party vendors, LPL Financial may pay for some or all of the third party’s fees. These support services are provided to WELLth Advisory Services based on the overall rela@onship between WELLth Advisory Services and LPL Financial. It is not the result of soj dollar arrangements or any other Page 23 of 25 CRD # 330537  express arrangements with LPL Financial that involves the execu@on of client transac@ons as a condi@on to the receipt of services. WELLth Advisory Services will con@nue to receive the services regardless of the volume of client transac@ons executed with LPL Financial. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by WELLth Advisory Services to LPL or any other en@ty to invest any specific amount or percentage of client assets in any specific securi@es as a result of the arrangement. However, because WELLth Advisory Services receives these benefits from LPL Financial, there is a poten@al conflict of interest. The receipt of these products and services presents a financial incen@ve for WELLth Advisory Services to recommend that its clients use LPL Financials’ custodial plaoorm rather than another custodian’s plaoorm. For a further lis@ng of poten@al conflicts, please refer to LPL Financials’ Brokerage Compensa@on and Conflicts Disclosure, available at lpl.com/disclosures.html. Item 16: Investment DiscreAon WELLth Advisory Services maintains limited power of aporney in client accounts held at the custodial broker dealer. The limited power of aporney will grant either full or limited discre@on in client accounts. The limited power of aporney authorizes WELLth Advisory Services to purchase and sell securi@es without obtaining the client’s prior permission to execute transac@ons. All transac@ons effected on behalf of clients will be in accordance with the client’s investment objec@ves that have been previously discussed and agreed upon with WELLth Advisory Services and the client. Item 17: VoAng Client SecuriAes Clients will receive proxy informa@on from their custodial broker-dealer(s). WELLth Advisory Services requests that clients engage another party to determine how proxies should be voted. WELLth Advisory Services does not provide proxy vo@ng services to its clients. Clients may contact their WELLth Advisory Services IAR by telephone or email if they have ques@ons. Item 18: Financial InformaAon As an investment advisory firm that maintains discre@onary authority, we are required to disclose any financial condi@on that would be likely to impair our ability to meet our contractual and fiduciary obliga@ons to our clients. WELLth Advisory Services has no such financial condi@ons to report. WELLth Advisory Services is not and has not been the subject of a bankruptcy proceeding. When conduc@ng financial planning services, WELLth Advisory Services may require a por@on of a financial planning fee in advance but will not require or solicit prepayment of fees in excess of $1,200.00 and six months or more in advance. Addi@onally, we do not take custody of client funds or securi@es. Therefore, we are not required to file financial informa@on with the SEC or with the states where WELLth Advisory Services is no@ce filed. Addi=onal Informa=on IARs will be required to meet the qualifica@on requirements of the states where WELLth Advisory Services conducts its advisory business. Professional Cer=fica=ons Certain WELLth Advisory Services IARs may have earned professional cer@fica@ons and designa@ons that are required to be explained in further detail. This informa@on will appear on each individual IAR’s ADV 2B which supplements informa@on contained in this ADV 2A brochure. The following are the most recognized designa@on that many of our IARs hold: Cer=fied Financial Planner ™ (CFP®): Cer@fied Financial Planners are licensed by the CFP® Board to display the CFP® mark. Candidates for the CFP® designa@on must meet the following requirements: • Bachelor’s degree from an accredited college or university. • Comple@on of the financial planning educa@on requirements set by the CFP® Board (www.cfp.net). Page 24 of 25 CRD # 330537  • • • Successful comple@on of the 10-hour CFP® Cer@fica@on Exam. Three years qualifying full-@me work experience. Successfully passing the Candidate Fitness Standards and background check. WELLth Advisory Services Privacy Policy We recognize our obliga@on to keep informa@on about you secure and confiden@al. It is important for you to know that we do not sell your informa@on to anyone. We restrict access to non-public personal informa@on about you to those IARs and employees who need to know that informa@on to provide products or services to you. We also maintain physical, electronic, and procedural safeguards to guard your non-public personal informa@on. WELLth Advisory Services Business Con=nuity Plan In accordance with federal requirements WELLth Advisory Services maintains a Business Con@nuity Plan that describes what steps will be taken to ensure the con@nuity of our business opera@on in the event of an unan@cipated disaster. The plan has been designed with procedures to ensure that client documenta@on will be accessible and that contact between WELLth Advisory Services, and its clients will be sustained. If you would like to receive a copy of the WELLth Advisory Services Business Con@nuity Plan, please contact our office. Page 25 of 25 CRD # 330537