Wellth Advisory Services, LLC

WELLth Advisory Services, LLC 25434 Prairiewood Lane Shorewood, IL 60404 Phone: 866-777-4015 Fax: 866-777-4015 www.srpretire.com Registered Investment Advisor Firm Brochure Form ADV Part 2A August 31, 2026 This brochure provides information about the qualifications and business practices of WELLth Advisory Services, LLC, a registered investment advisor. If you have any questions about the contents of this brochure, please contact us at 866-777-4015. 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. information about WELLth Advisory Services, LLC Additional is also available on the SEC’s website at www.advisorinfo.sec.gov. You may search this site by our identifying number known as a CRD number. The CRD number for WELLth Advisory Services, LLC is 330537. Registration with the SEC or any state securities 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 information on the qualifications of our firm and its employees. Page 1 of 28 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 time 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 additional information on our firm from www.advisorinfo.sec.gov under Investment Advisor Search. If applicable, this section will contain a summary of material changes to the information in our brochure since the last annual update of this brochure. This filing includes updates to: Item 4 – Advisory Business: Updated to describe Institutional and Fund Management Services and Outsourced Chief Investment Officer (“OCIO”) services for institutional clients and investment vehicles, including the scope of delegated authority, investment-management functions, fiduciary status, and applicable investment guidelines. Updated “Retirement Plan Services” to describe WELLth’s provision of investment management services to participants of employer-provided retirement plans. Item 5 – Fees and Compensation: Updated to describe fees and billing for advisory accounts serviced through Axxcess, including quarterly advance or arrears billing, monthly billing, valuation methodology, prorated fees and refunds, direct fee deduction, and treatment of Axxcess platform and third-party manager charges. The disclosure also clarifies that Axxcess and any sleeve strategy manager charge explicitly for their services, describes the Axxcess Account Fee structure, and identifies additional Axxcess-related fees and expenses that clients may incur. Item 10 – Other Financial Industry Activities and Affiliations: Updated the Axxcess Platform disclosure to describe WELLth Advisory Services’ business relationship with Axxcess, the platform’s administrative and investment- management functions, access to independent managers and models, the discretionary authority of sub-advisors, and WELLth Advisory Services’ responsibility for ongoing suitability, client-account restrictions, and oversight. The disclosure also describes related conflicts of interest arising from the platform’s operational and economic benefits and from the availability of managers and models through Axxcess. Item 12 – Brokerage Practices: Updated to add Axos, Pershing, and Altruist Financial, LLC to the custodians generally used by WELLth Advisory Services. Item 12 was also updated to describe trading for Axxcess-serviced accounts through the Axxcess platform, including execution through the client’s custodian, multi-custodian functionality, best- execution considerations, and related conflicts of interest. Item 15 – Custody: Updated to clarify that, for Axxcess-serviced accounts, Axxcess or its billing platform will calculate and facilitate the deduction of WELLth Advisory Services’ advisory fee pursuant to client authorization and applicable custodial arrangements, and to describe WELLth Advisory Services’ related fee-calculation and qualified-custodian statement procedures. Item 16 – Investment Discretion: Updated to describe discretionary authority for institutional accounts, investment vehicles, and OCIO engagements, including authority that may be exercised under applicable agreements and investment guidelines to select or terminate managers, allocate or rebalance assets, select securities or investment vehicles, and implement transactions without prior client approval for each transaction. Items 4, 5, 7, and 17 - Updated to clarify the authority applicable to discretionary, nondiscretionary, and third-party- manager accounts; the use and oversight of sub-advisors and sleeve strategy managers; Agreement-specific billing, fee-deduction, manager-fee, termination, and refund terms; applicable account minimums; and client responsibility for class-action claims. Page 2 of 28 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 Institutional and Fund Management Services .......................................................................................... 8 Outsourced Chief Investment Officer Services ......................................................................................... 9 Item 5: Fees and Compensation .......................................................................................... 9 Retirement Plan Services ...................................................................................................................... 9 Wealth Management Services ............................................................................................................ 10 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 ......................................................................................... 16 Item 10: Other Financial Industry Activities and Affiliations ..................................................... 16 Use of Subadvisors and Axxcess Platform Services ................................................................................. 18 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading......... 19 Item 12: Brokerage Practices .............................................................................................. 19 Item 13: Review of Accounts .............................................................................................. 24 Item 14: Client Referrals and Other Compensation ................................................................. 24 Item 15: Custody ............................................................................................................. 26 Item 16: Investment Discretion .......................................................................................... 26 Item 17: Voting Client Securities ......................................................................................... 27 Item 18: Financial Information ........................................................................................... 27 Page 3 of 28 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 (sometimes referred to herein as “we,” “us” or “WELLth Advisory Services”) is owned by SRP Holdings Group, LLC, a Nevada corporation. 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 Executive Officer; Deane Mayerhofer, President & Chief Operating Officer; and Sarah Hughes, Chief Compliance Officer. WELLth Advisory Services recognizes that an investment advisor’s role should extend beyond investment guidance and often requires a variety of coordinated financial service strategies to create a roadmap to achieving financial goals for its clients. We support this effort by providing our investment advisor representatives (“IARs”) with the tools and resources to help meet client needs and objectives. Retirement Plan Services We approach client service with a collaborative 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 Employee Retirement Income Security Act of 1974 (“ERISA”) compliance, investment research, provider analysis, fee benchmarking, employee education, and executive benefits. WELLth Advisory Services, through its affiliated IARs, provides consulting and advisory services to both ERISA and non-ERISA employer sponsored retirement plans, including, but not limited to, 401(k), 457(b), 457(f), 403(b), Simple IRA, SEP IRA, nonqualified, deferred compensation, pension and profit-sharing plans (collectively, “Plans” or individually, “Plan”) on both a one-time and/or ongoing basis. WELLth Advisory Services offers a suite of detailed engagement agreements which are customized for each client relationship and executed by the Plan’s designated fiduciary upon conclusion of a careful review, which, at times, includes the client’s independent legal counsel. Through its agreements, WELLth Advisory Services is engaged to provide investment advisory services on either a nondiscretionary basis (serving as a “fiduciary” as defined by Section 3(21)(A)(ii) of ERISA); or on a discretionary basis and thus will serve as an “Investment Manager” as defined by Section 3(38) of ERISA. Certain other additional services available from WELLth Advisory Services would be considered non-fiduciary by definition and function and are explicitly detailed within the Plan’s service agreement with us. For non-discretionary services, WELLth Advisory Services and its IARs will act in a solely advisory capacity and will not have or exercise any discretionary authority or control relative to the management or investment of the assets of the respective Plan. For discretionary services, WELLth Advisory Services and its IARs will be designated as the Investment Manager to the Plan and assume responsibility for the investment selection and asset management for the Plan’s investment menu made available to the Plan participants 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 Section 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-Discretionary Fiduciary Services may include: Investment Policy Statement. o o Ongoing Investment Selection and Recommendations. Page 4 of 28 CRD # 330537  o Ongoing Investment Monitoring. o Qualified Default Investment Alternative Assistance. o Non-Discretionary Creation of Model Portfolios. • Discretionary Fiduciary Services may include: Investment Policy Statement. Selection of Qualified Default Investment Alternative (“QDIA”). o o Ongoing Investment Discretion and Selection. o Ongoing Investment Monitoring. o o Discretionary Creation of Model Portfolios. • The Plan-level Non-Fiduciary Services may include: Service Provider Liaison. o o Education Services to Plan Committee. o Plan Search Support/Vendor Analysis. o Benchmarking Services. o Assistance Identifying Plan Fees. o Plan Review. • Participant-level Services may include: o Participant Enrollment. o Participant Education. o Participant Investment Advice. o Participant Investment Management. o Financial Wellness Program. Based on the needs of the client, the agreement will specify the services on a client-by-client basis. Participant Investment Management Services WELLth provides professional investment management of participants’ retirement plan accounts. To be eligible, a plan must utilize a custodian that has agreed to partner with WELLth to provide the account access necessary to make discretionary trades within participants’ accounts and to collect investment management fees from the participants’ accounts. In addition, the plan must agree to offer the service to its participants, on an opt-in basis and/or as the plan’s QDIA. WELLth may partner with other investment advisors to share in the responsibilities of managing participants’ accounts. Specifically, WELLth will develop models based upon the designated investment alternatives (“DIAs”) available under the plan that will then be used – either by it or in partnership with another investment advisor - to develop an allocation of participants’ investments based upon their age, sex, salary, current plan assets, and other factors designed to help participants meet their income needs in retirement. The plan’s sponsor and each participant utilizing the program will be notified of the applicable investment management fee, which will be apportioned between WELLth, the plan’s custodian, and the other investment advisor. That investment management fee will vary based upon the custodian, the inclusion of an investment advisor partner, whether the service will be offered on an opt-in or other basis, etc. Wealth Management Services WELLth Advisory Services offers investment advisory, portfolio management, and financial planning services to individuals and families. Our investment recommendations primarily include mutual funds, exchange-traded funds, and separate account managers investing in exchange-listed equity securities. The advice provided by WELLth Advisory Services is tailored to the unique objectives of each client. We work with clients to formulate an investment Page 5 of 28 CRD # 330537  strategy after discussing risk tolerance, time horizon, and projected future liquidity needs, current holdings, tax considerations, personal market views and other factors. This strategy provides guidance to formulate suitable investment and financial recommendations. We meet with clients as needed to review portfolio performance, discuss current issues, and reassess goals and investment plans. Client input, involvement and decision-making are critical to the planning process and implementation of investment decisions. WELLth Advisory Services also offers financial plans. These financial planning services are based on the client’s financial situation at the time the financial information is disclosed by the client to WELLth Advisory Services. Clients are advised that certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Because clients’ financial situations, goals, objectives, or needs change, clients are encouraged to notify us promptly if they wish to update their financial plan. WELLth Advisory Services also offers discretionary management services to our individual clients. Regardless of whether our authority is discretionary or non-discretionary, clients may impose reasonable restrictions on investing in certain securities or types of securities. Under certain Wealth Management Investment Advisory Agreements, each covered account is designated as discretionary (“D”), nondiscretionary (“ND”), or turnkey asset management program (“T”). For a D account, WELLth Advisory Services may make and implement investment decisions, including selecting, removing, and replacing investments, without obtaining the client’s prior approval for each transaction, subject to the client’s investment guidelines and reasonable restrictions. For an ND account, WELLth Advisory Services provides investment recommendations and executes transactions only when authorized by the client. For a T account, WELLth Advisory Services recommends a turnkey asset management program on a nondiscretionary basis and periodically reviews and monitors the manager’s ongoing suitability. The authority applicable to each account is identified in the client agreement and account documentation. WELLth Advisory Services may provide advisory services through certain programs sponsored by LPL Financial LLC (“LPL”), a registered investment advisor and broker-dealer. Below is a brief description of each LPL custodied advisory program available to WELLth Advisory Services, LLC. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs, clients will need to review 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 utilized 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 participate in the Separately Managed Account Platform (the “SMA Platform”) or the Model Portfolio Platform (the “MP Platform”). In the SMA Platform, WELLth Advisory Services will assist client in identifying a third party portfolio manager (“SMA Portfolio Manager”) from a list of SMA Portfolio Managers made available by LPL, and the SMA Portfolio Manager manages client’s assets on a discretionary basis. WELLth Advisory Services will provide initial and ongoing assistance regarding the SMA Portfolio Manager selection process. In the MP Platform, clients authorize LPL to direct the investment and reinvestment of the assets in their accounts, in accordance with the selected model portfolio provided by LPL’s Research Department or a third-party investment advisor. Clients should review the MAS Program Brochure for more detailed information, 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. Optimum Market Portfolios Program (OMP) OMP is a professionally managed mutual fund asset allocation program in which LPL and WELLth Advisory Services provide ongoing investment advice and management. WELLth Advisory Services obtains the necessary financial data Page 6 of 28 CRD # 330537  from the client, assists the client in determining the suitability of the program and assists the client in setting an appropriate investment objective. WELLth Advisory Services selects a model portfolio of mutual funds comprised of Optimum Funds Class I shares, designed by LPL’s Research Department consistent with the client’s stated investment objective. Clients grant LPL discretionary trading authority to sell previously purchased securities and purchase and sell Optimum Funds to track the model portfolio. Clients should review the OMP Program Brochure for more detailed information, available at lpl.com/disclosures.html. LPL generally requires a minimum account value of $1,000 for OMP, but additional contributions may be required for account sizes below $10,000. In certain instances, LPL will permit a lower minimum account size. Personal Wealth Portfolios 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 setting an appropriate investment objective. Client authorizes WELLth Advisory Services on a discretionary basis to select an asset allocation model portfolio designed by LPL (“Portfolio”). WELLth Advisory Services then selects third party investment advisor (“PWP Advisors”) who will provide investment models within each asset class of the Portfolio. Clients authorize LPL to invest in accordance with the portfolio and models. Clients should review the PWP Program Brochure for more detailed information, 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 Portfolios Program (MWP) MWP is a unified managed account program in which LPL and WELLth Advisory Services provide ongoing investment advice on a discretionary 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 setting an appropriate investment objective. WELLth Advisory Services selects one or more model portfolios of securities (each, a “Portfolio”) designed by LPL’s Research Department, a third-party investment strategist, or WELLth Advisory Services (each, a “Portfolio Strategist”), consistent with the client’s stated investment objective. These Portfolios may contain mutual funds, ETFs, exchange-traded notes (“ETNs”), closed-end funds, equities, or fixed-income securities. WELLth Advisory Services provides ongoing advice on the selection or replacement of a Portfolio based on the client’s individual needs and may choose more than one Portfolio to be managed within a single MWP account. A Portfolio also may be comprised of one or more underlying models. Clients grant WELLth Advisory Services discretion to choose among the available models designed by the Portfolio Strategists, which may include WELLth Advisory Services and its IARs. The Portfolio Strategist is responsible for selecting the securities within a Portfolio and for making changes to the securities selected. Each Portfolio Strategist provides its model portfolio 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 information, 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 portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $10,000. In certain instances, a lower minimum for a portfolio is permitted. Client understands that the account will not be invested according to a model portfolio until the applicable asset minimums for that model portfolio have been reached. Guided Wealth Portfolios (GWP) GWP is an advisor-enhanced digital advice program that offers clients the ability to participate in a centrally managed investment program, which is made available to users and clients through a web-based, interactive account management portal. Clients are required to maintain an active profile in the account management portal to participate in the program. Clients select from one of the following goals for their account: retirement, major purchase, or general investing. Based on information provided by the client, the client is assigned a model portfolio constructed by LPL. WELLth Advisory Services determines the suitability of the Program for the client and an Page 7 of 28 CRD # 330537  appropriate investment allocation track for the client. Clients authorize LPL on a discretionary basis to purchase and sell securities based upon the model portfolio. Program securities 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 information, 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 transaction charges for the purchase and sale of certain securities in their SWM accounts, unless their WELLth Advisory Services elects to pay transaction charges on their behalf. Clients should be aware that WELLth Advisory Services pays LPL transaction charges for those transactions. The transaction charges paid by WELLth Advisory Services vary based on the type of transaction (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 transaction charges is set forth in the SWM Account Agreement and the accompanying fee schedule (available here - https://www.lpl.com/disclosures.html). Being subject to transaction charges results in higher fees and expenses and, as a result, reduces investment returns. Because WELLth Advisory Services has elected to pay the transaction 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 transaction fees vary based on the type of transaction. Clients should understand that the cost to Advisor of transaction charges may be a factor that WELLth Advisory Services considers when deciding which securities to select and how frequently to place transactions 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. Potential Conflicts of Interest Transactions in LPL advisory program accounts are generally made through LPL as the executing broker-dealer. WELLth Advisory Services receives compensation as a result of a client’s participation in an LPL program. Depending on, among other things, the size of the account, changes in its value over time, the ability to negotiate fees or commissions, and the number of transactions, the amount of this compensation may be more or less than what WELLth Advisory Services would receive if the client participated in other programs, whether through LPL or another sponsor, or paid separately for investment advice, brokerage, and other services. WELLth Advisory Services receives compensation as a result of a client’s participation in an LPL program. Depending on, among other things, the type and size of the account, type of securities held in the account, changes in its value over time, the ability to negotiate fees or commissions, the historical or expected size or number of transactions, and the number and range of supplementary advisory and client-related services provided to the client, the amount of this compensation may be more or less than what the WELLth Advisory Services would receive if the client participated 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 advisors for similar services. Clients should consider the level and complexity of the advisory services to be provided when negotiating the account fee (or the advisor fee portion 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. Institutional and Fund Management Services WELLth Advisory Services provides discretionary and non-discretionary investment management services to private funds, investment companies, collective trusts, retirement plans, endowments, foundations, family offices, Page 8 of 28 CRD # 330537  corporations, and other sophisticated investors (collectively, “Institutional Clients”). These services may include acting as an investment advisor or sub-advisor to private investment funds, collective investment trusts, model portfolios, separately managed institutional accounts, and other investment vehicles sponsored by third parties or affiliates. Services are provided pursuant to written advisory or sub-advisory agreements that define the scope of services, investment authority, fee arrangements, and applicable restrictions. The Advisor’s role may include portfolio construction, security selection, risk management, rebalancing, and ongoing monitoring consistent with the investment mandate of the applicable fund or institutional account. In some arrangements, WELLth Advisory Services may have full discretionary authority over assets; in others, services may be limited to model delivery, investment recommendations, or sub-advisory functions. Outsourced Chief Investment Officer Services WELLth Advisory Services provides Outsourced Chief Investment Officer (“OCIO”) services to institutional clients seeking to delegate all or a portion of their investment management, oversight, and implementation responsibilities to the advisor. OCIO services are provided pursuant to written agreements that define the scope of delegation, fiduciary status, investment discretion, and reporting obligations. OCIO clients may include retirement plans (ERISA and non-ERISA), foundations, endowments, trusts, family offices, corporations, and other institutional investors. Under an OCIO arrangement, WELLth Advisory Services may assume discretionary authority over portfolio construction, asset allocation, manager selection and monitoring, rebalancing, and ongoing risk management, subject to client-approved investment guidelines. WELLth Advisory Services will act as a fiduciary under ERISA or applicable state or federal law. OCIO services may be provided on a full-scope or partial-scope basis, including delegated investment discretion, co-fiduciary arrangements, or advisory-only OCIO support. Assets Under Management and Advisement As of December 31, 2025, WELLth Advisory Services manages a total of $26,677,833,474 regulatory assets under management, which includes $9,372,111,875 of discretionary assets under management, and $17,305,721,599 of non-discretionary assets under management. Item 5: Fees and Compensation WELLth Advisory Services charges the fees identified below, but fees are negotiable on a client-by-client basis. Retirement Plan Services The WELLth Advisory Services fee and billing procedures for retirement plans are described in our client Agreement. These fees are negotiable, so 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, alternatively, 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 negotiated with the Sponsor, asset-based fees used in the managed account program do not include the value of any assets invested in Plan participants' self-directed brokerage accounts ("SDBAs") nor participant loans or other investments that may be defined as excluded investments from the arrangement, as identified 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 capabilities of the platform that Client selects (e.g., recordkeeper capabilities). Fees are due upon receipt of statement, if applicable. When billed as an asset-based fee in advance, fees will be based on the Page 9 of 28 CRD # 330537  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., settlor-related services and associated fees). These services are clearly identified on the agreement between client and Sponsor. Wealth Management Services WELLth Advisory Services’ fee and billing procedures for wealth management clients are described in our client Agreement. These fees are negotiable, so we do not have a standard fee schedule that applies to all Clients. However, the following maximum fees apply: 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% For accounts governed by the Wealth Management Investment Advisory Agreement, the applicable fee schedule identifies whether fees are billed in advance or arrears and on a monthly or quarterly basis. The initial fee is prorated based on the date the account is funded and the number of days remaining in the applicable billing period. Clients may authorize WELLth Advisory Services or an applicable sub-advisor to instruct the qualified custodian to deduct fees directly from an account. If sufficient cash is not available, the applicable agreement may authorize the sale of securities to cover a debit balance resulting from assessed fees, subject to the client’s investment objectives, account restrictions, trading authority, and custodial procedures. The termination requirements are stated in the applicable client agreement or program documents. Under the client agreement, either party may terminate the agreement without penalty upon 30 days’ written notice. Upon termination, the advisory fee is prorated through the effective termination date, and any unearned advisory fees paid in advance are refunded to the client. Different notice, processing, or cancellation provisions may apply to accounts maintained through an advisory program or third-party asset manager, as described in the applicable documents. 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 information. ** 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 information. *** 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 information. **** GWP clients are charged an account fee consisting of an LPL program fee of 0.35% and an advisor fee of up to 1.00%. LPL Research currently serves as the sole portfolio strategist and does not charge a fee for its services. Page 10 of 28 CRD # 330537  Account fees are payable quarterly in advance. LPL serves as program sponsor, co-investment advisor 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 representatives of LPL. GWP Educational Tool provides access to sample recommendations at no charge to users. However, if users decide to implement sample recommendations by executing 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 compensation directly to WELLth Advisory Services by deducting 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 reflecting 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 authorization permitting WELLth Advisory Services to be directly paid by these terms; For accounts utilizing LPL as the custodian, LPL will perform the billing and will take instruction 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 time we send the invoice to our client; The invoice includes a legend that urges the client to compare information provided in their statements with those from the qualified custodian in account opening notices 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 initial fee deduction, 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 initial quarter in addition to the quarterly Advisor fee for the upcoming quarter. Subsequent fee deductions 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. Additional 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 notified by Advisor or the client of the termination or deactivation 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 after the notice of termination to LPL. Hourly and Fixed Fee Financial Planning Fees: WELLth Advisory Services will charge on an hourly or fixed fee basis for financial planning and consulting services. The total estimated fee will be based on the time, scope, and complexity of our engagement with clients. Generally, Financial Planning fees are fixed based on an estimated 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 $500 for hourly rates and negotiable amount for fixed rates. Fixed fees are generally paid 50% in advance with the balance due upon completion. Hourly fees are generally charged as they incur. The applicable fee is determined by the scope and complexity of a particular Client’s financial situation as well as the amount of time and expertise required. In some cases, a fee greater or lesser then the typical fee range may be Page 11 of 28 CRD # 330537  warranted. In the case of fixed fee financial planning, payment for services will be according to individual arrangement. In general, a portion of the fee is paid in advance with the balance paid upon the completion and presentation 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 objectives of certain WELLth Advisory Services clients. This includes Axxcess and the independent investment managers or model providers available through the Axxcess platform, as described in Item 4 and Item 10. Axxcess and any sleeve strategy manager explicitly charge for their services, as described under “Axxcess-Serviced Advisory Accounts” below and in the applicable fee schedule. Clients utilizing the services of third-party asset managers will receive documentation 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 cancellation policy of the particular third-party asset manager. The treatment of a third-party manager’s fee depends on the applicable client agreement, manager agreement, and fee addendum. A sleeve strategy manager’s fee may be separately disclosed in an addendum and may be collected and remitted by WELLth Advisory Services or an applicable sub-advisor. Clients should review the applicable agreements and fee schedules to determine whether manager fees are charged separately, included within an aggregate fee, or allocated from the fee paid to WELLth Advisory Services. Axxcess Account Fees: Wealth management clients will be serviced through Axxcess, as described in the applicable client agreement and fee schedule and as further described in Item 10 herein. Standard advisory accounts can be billed monthly or quarterly in advance, meaning at the beginning of the quarter for the upcoming three months of service, or quarterly in arrears, meaning at the end of the quarter for the preceding three months of service. The applicable billing method will be specified in the client agreement or other account documentation. Clients can authorize the qualified custodian to deduct advisory fees directly from the client’s custodial account. The billable market value generally will be based on the procedures of the qualified custodian holding the assets as identified in the client agreement. Axxcess calculates quarterly fees based on the actual number of days in the quarter rather than by dividing the annual fee into four equal installments. Monthly billing is also available to accommodate a client’s particular engagement. For accounts opened or closed during a billing cycle, fees will be adjusted on a prorated basis calculated on the number of days in the cycle that services were not provided. If sufficient cash is not available when a fee is due, WELLth Advisory Services will communicate with the IAR servicing the account regarding the sale of securities to raise cash, subject to the client agreement, investment objectives, and applicable trading authority. If sufficient cash is not available, the fee may not be deducted until such time sufficient cash is available. Page 12 of 28 CRD # 330537  Axxcess and any sleeve strategy manager charge explicitly for their services. The annualized account fee rate shown on the client’s agreement with WELLth Advisory Services (“WELLth’s Account Fee”) only reflects the fee we will collect for our services. WELLth Advisory Services does not receive any portion of the fees charged by Axxcess or a sleeve strategy manager. Additional Fees and Expenses: WELLth’s Account Fee is exclusive of brokerage commissions, transaction 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 parties such as fees charged by managers; custodial fees; Axxcess platform, administrative, trading, reporting, sleeve strategy, or manager fees, may be separately charged and disclosed to the client as clearly identified in the client agreement; deferred sales charges; odd-lot differentials; transfer taxes; wire transfer and electronic fund fees; and other fees and taxes on brokerage accounts and securities transactions. Mutual 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 addition to WELLth Advisory Services’ fee. Other than the previously disclosed situations, WELLth Advisory Services’ affiliated entities, ownership interests, and outside business activities described elsewhere in this Brochure do not affect the advisory fees charged to clients, and no portion of WELLth Advisory Services fees is increased, passed through, or otherwise influenced by any compensation or revenue received by such affiliates. Item 6: Performance Based Fees WELLth Advisory Services does not charge fees based on a share of capital gains or on capital appreciation 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, retirement, and profit-sharing plans. Corporations, Limited Liability Companies and/or other Institutions. 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. Minimum account requirements vary by agreement, investment program, third-party manager, platform, and investment advisor representative. Other programs and managers may impose different minimums, as described in the applicable program brochure, manager agreement, or WELLth Advisory Services agreement. WELLth Advisory Services, the applicable manager, or the platform sponsor may accept an account below a stated minimum in its discretion. The specific amounts are detailed in the third-party asset managers’ agreements or in the WELLth Advisory Services agreement, as negotiated by the client and WELLth Advisory Services. Accounts below the stated minimums may be accepted on an individual basis at the discretion of WELLth Advisory Services and the platform 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 consideration clients’ specific objectives and goals. The IAR’s methods of investment analysis Page 13 of 28 CRD # 330537  and strategies may vary from one office to another. The following details the types of analysis IARs use to formulate client recommendations: • • • • Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential 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 evaluating the stock. Charting: In this type of technical analysis, we review charts of market and security activity in an attempt to identify 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 attempt to recognize recurring patterns of investor behavior and potentially predict future price movements. Technical analysis does not consider the underlying financial condition 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 particular stock against the overall market in an attempt to predict the price movement of the security. • Mutual Fund and/or ETF Analysis: WELLth Advisory Services, including its Investment Committee and their IARs review the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest successfully over a period of time and in different economic conditions. IARs also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is a significant overlap in the underlying investments held in other funds in the client’s portfolio. A risk of mutual fund and/or ETF analysis is that, as with all securities investments, past performance does not guarantee future results. Risks for all forms of analysis: The WELLth Advisory Services securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, provide accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. For ERISA plans in which participants 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 options to enable participants to develop a diversified portfolio. Investment Strategies: • Long-Term Purchases: When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (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 time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Typically, we employ this sub-strategy when we believe the securities to be well valued; and/or we want exposure to a particular asset class over time, regardless of the current projection for this asset class. Page 14 of 28 CRD # 330537  • • Short-Term Purchases: When utilizing this strategy, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. Trading: We purchase securities with the idea of selling them very quickly (typically within 30 days or less). We do this in an attempt to take advantage of our predictions of brief price swings. Investing always involves some risk, whether securities, certificates 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’ objective is to help clients understand the different types of risk and mitigate the risk over time. One way to lessen risk is to diversify investment portfolios so that when some fall in value, others may rise in value. Securities 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 securities selected, some additional risk factors (below) could become relevant and should be discussed with the client’s investment advisor representative. Additional Risk Factors: • Market Risk: Risk that cannot be mitigated through diversification because an event of great magnitude (such as recession, political turmoil, natural disaster, terrorist attack) has occurred that impacts the markets systemically. • Inflation Risk: Risk that an investor may lose some of their purchasing power if the investment does not outpace inflation. 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 becomes insolvent for whatever reason, common stockholders have a low priority claim on remaining assets after 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. Alternative investments, such as non-traded REITs, are often entirely illiquid for 5 years or more until 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 prospective buyer because higher rates are readily available. • Longevity Risk: Risk that an investor, especially a retiree, 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 time horizon, such as a disability, job loss, divorce, etc. • Default Risk: Risk that a bond issuer will become insolvent and default on their obligation to make interest payments to debtholders/investors. Page 15 of 28 CRD # 330537  Item 9: Disciplinary Information We are required to disclose whether there are legal or disciplinary events that are material to a client’s or prospective client’s evaluation 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 information 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 evaluation of the company or its personnel. Item 10: Other Financial Industry Activities and Affiliations WELLth Advisory Services is a wholly owned entity of SRP Holdings Group, LLC (“SRP”), headquartered in Shorewood, Illinois. SRP is an independent retirement plan consulting practice whose professionals advise on retirement plans, supporting plan sponsors in understanding and managing their fiduciary responsibilities 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 Entities that may operate within the retirement-plan, investment-management, and financial-technology sectors. These affiliations 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 I, II, III, IV, V, VI, and Given To Fly, LLC, which in turn may hold minority investments in other entities. In some instances, the WELLth Advisory Services senior personnel serve in board or advisory capacities at these affiliated entities, and certain affiliates may develop or maintain operational, distribution, or commercial relationships with WELLth Advisory Services. These affiliations create potential conflicts of interest because WELLth Advisory Services and its personnel may benefit financially or otherwise from the success of these affiliated entities. WELLth Advisory Services maintains policies and supervisory procedures designed to ensure that its fiduciary duty to clients is upheld and that recommendations involving any affiliated service or platform are evaluated solely on the basis of client interests. In addition, all IARs are required to disclose any outside business activities, board positions, 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, to ensure that outside affiliations 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. LPL Financial 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 securities transactions for individuals or entities who are also WELLth Advisory Services clients. Under those circumstances, LPL will pay these individuals a portion of the brokerage Page 16 of 28 CRD # 330537  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 securities 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 permitted 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 activities are disclosed in writing to the WELLth Advisory Services Compliance Department. IARs may receive compensation from these activities. Clients are not obligated to obtain these services through WELLth Advisory Services IARs. As discussed previously, certain WELLth Advisory Services Investment Advisory Representatives are registered representatives with LPL. As a result of this relationship, LPL may have access to certain confidential information (e.g., financial information, investment objectives, transactions, 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. Axxcess Platform WELLth Advisory Services has a business relationship with Axxcess Wealth Management, LLC (“Axxcess”), an unaffiliated SEC-registered investment advisor that acts as a discretionary sub-advisor and provides a platform through which WELLth Advisory Services obtains back-office operational support and accesses independent third- party investment managers and model providers. Axxcess provides administrative, trading, reporting, account- maintenance, data-reconciliation, performance-reporting, model-management, and advisory-fee billing services, and exercises discretionary investment-management authority over client assets allocated to it, directly or through independent sleeve strategy managers whose models it implements. WELLth Advisory Services enters into the applicable platform and service arrangements and maintains a direct contractual relationship with its clients. Through the client agreement, WELLth Advisory Services obtains the authority necessary to engage Axxcess and any selected sub-advisor or manager for the services described in this Brochure. Axxcess, as sub-advisor, exercises discretionary authority over the assets allocated to it and may buy, sell, trade, invest, reinvest, or allocate those assets without obtaining approval for each transaction, subject to the client’s investment objectives and account restrictions. WELLth Advisory Services remains responsible for the client relationship and for making the initial and ongoing suitability determination for the use of Axxcess, a selected manager, and any model or investment strategy. WELLth Advisory Services is also responsible for obtaining and communicating client investment objectives, account guidelines, and reasonable restrictions, and for monitoring the services provided in accordance with its fiduciary duty and written policies and procedures. WELLth Advisory Services’ use of Axxcess creates conflicts of interest. Axxcess provides services that may make its platform more operationally convenient or economically attractive than alternative providers, and the availability of independent managers and models through the platform may create an incentive for WELLth Advisory Services to recommend Axxcess or a manager available through Axxcess rather than an unaffiliated alternative. WELLth Advisory Services addresses these conflicts through disclosure, due diligence, ongoing monitoring, fee review, and its fiduciary obligation to place client interests ahead of its own. Clients are not required to use Axxcess or a manager available through the Axxcess platform unless the relevant service is a condition of the client’s selected advisory program and is disclosed in the applicable agreement. However, all wealth management clients of WELLth Advisory Services are required to leverage the Axxcess platform for operational and administrative services. Axxcess operates under its own compliance program and written supervisory procedures, and the respective responsibilities of WELLth Advisory Services and Axxcess are allocated in the applicable investment-management and platform agreements. The specific services, fees, and conflicts applicable to Axxcess are further described in the Axxcess Form ADV Part 2A brochure, which will be provided when applicable. See Item 4 and Item 5 for additional information. Page 17 of 28 CRD # 330537  Use of Subadvisors and Axxcess Platform Services WELLth Advisory Services may recommend or refer clients to unaffiliated turnkey asset management programs (“TAMPs”) and independent investment managers, either in WELLth Advisory Services’ discretion or at a client’s request. WELLth has a relationship with Axxcess Wealth Management, LLC (“Axxcess”), an SEC-registered investment advisor that offers TAMP, sub-advisory, and investment-administration services. Under certain individual wealth agreements, WELLth Advisory Services will appoint a sub-advisor to assist with management of all or a portion of a discretionary account. WELLth Advisory Services or the applicable sub-advisor may also appoint one or more third- party sleeve strategy managers to manage specified assets. A sleeve strategy manager may exercise the authority granted in the applicable agreement or addendum, subject to WELLth Advisory Services’ or the sub-advisor’s oversight and authority to terminate the manager. Clients may be required to execute additional documentation and will receive applicable disclosure documents for the sub-advisor or manager. Where Axxcess or another TAMP is used, the client may be required to authorize and enter into an investment- management agreement with the applicable TAMP or manager. WELLth Advisory Services will remain the client’s primary advisor and will retain responsibility for the client relationship, including establishing or confirming the client’s investment objectives, assessing the suitability of the recommended program or manager, recommending investment strategies consistent with those objectives, and overseeing the client’s investment allocation and overall performance. The applicable TAMP, sub-advisor, or independent manager may assume discretionary, day-to-day management of all or a portion of the assets allocated to it. Axxcess provides investment-management and back-office administrative and operational services, including technology supporting data reconciliation, performance reporting, client database maintenance, quarterly performance evaluations, model management, trading platforms, account maintenance, and other administrative functions relating to managed accounts. When Axxcess acts as a sub-advisor, it will have discretionary authority. Axxcess also makes available independent third-party investment managers and model providers through its platform. WELLth Advisory Services may select from, or allocate client assets among, the available managers or models, subject to the client’s investment objectives, any applicable account restrictions, and WELLth Advisory Services’ fiduciary duty. The selected manager or sub-advisor will have discretionary authority, without prior consultation with WELLth Advisory Services or the client for each transaction, to buy, sell, trade, invest, reinvest, or allocate assets it manages in accordance with the client’s investment objectives and the applicable agreement. Where a third-party sleeve strategy manager is used, that manager provides the investment model and Axxcess implements and places the resulting trades. WELLth Advisory Services retains responsibility for the initial and ongoing suitability of the selected program, manager, and investment strategy, as well as for communicating applicable client account guidelines and reasonable restrictions. Clients will receive the Form ADV Part 2A brochure of Axxcess and, where applicable, the brochure of the selected sub-advisor, TAMP, or independent manager, or another brochure containing the required disclosures, before or at the time the relevant services are used. Those brochures describe the applicable provider’s services, fees, practices, and conflicts of interest in more detail. The fees and billing methodology applicable when Axxcess is used are described in Item 5 — Fees and Compensation. WELLth Advisory Services’ relationship with Axxcess and the material conflicts associated with that relationship are described in Item 10 — Other Financial Industry Activities and Affiliations. Page 18 of 28 CRD # 330537  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading We have established a Code of Ethics which applies to our IARs. An investment advisor, WELLth Advisory Services is required to act in a fiduciary capacity. As a fiduciary, it is our 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 times. 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 Securities Transactions Policies and Procedures. We require all of our IARs to conduct business in compliance with our Code of Ethics, as well as all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all IARs are required to 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 negatively 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 potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. If our firm or an IAR recommends to clients, or buys or sells for client accounts, securities 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 practice 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, securities in which we or an IAR has a material financial interest. If our firm or an IAR invests in the same securities (or related securities, e.g., warrants, options, or futures) that our firm or an IAR recommends to clients, we are required to describe our practice and discuss the conflicts of interest this presents and generally how we address the conflicts that arise in connection with personal trading. IARs may buy or sell securities 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 securities to clients, or buys or sells securities for client accounts, at or about the same time that you or an IAR buys or sells the same securities for our firm’s (or the related person's own) account, the firm is allowed to purchase the same securities that are recommended to and purchased on behalf of clients so long as the personal trading (or trading for a related person) is not influenced by Client account activity. The firm or its IAR will discuss the conflicts of interest presented and we will describe generally how we address conflicts that arise. IARs may buy or sell securities for themselves at or about the same time they buy or sell the same securities 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. Item 12: Brokerage Practices Clients may specify which broker-dealer to use for custodial services or if requested, WELLth Advisory Services may make recommendations. These recommendations are based on WELLth Advisory Services’ perception of the breadth of services offered, and quality of execution. WELLth Advisory Services generally utilizes the services of LPL, Goldman Sachs Executions & Clearing, L.P., Fidelity Clearing & Custody Solutions, Axos Clearing, LLC, Pershing LLC, Altruist Financial LLC, and Charles Schwab & Co. Inc. (“Schwab”). LPL Financial Page 19 of 28 CRD # 330537  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 transaction-based fees for trades that are executed through LPL or that settle into LPL accounts. For IRA accounts, LPL generally charges account maintenance fees. In addition, LPL also charges clients miscellaneous fees and charges, such as account transfer fees. LPL charges WELLth Advisory Services an asset-based administration fee for administrative services provided by LPL. Such administration fees are not directly borne by clients but may be considered when WELLth Advisory Services negotiates its advisory fee with clients. While LPL does not participate in, or influence the formulation of, the investment advice WELLth Advisory Services provides, certain supervised persons of WELLth Advisory Services are also registered representatives of LPL (“Dually Registered Persons.”) Dually Registered Persons are restricted by certain FINRA rules and policies from maintaining client accounts at another custodian or executing client transactions in such client accounts through any broker- dealer or custodian that is not approved by LPL. As a result, the use of other trading platforms 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 portfolio 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 activities 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 activities conducted through these other broker- dealers and custodians. This arrangement presents a conflict of interest because WELLth Advisory Services has a financial incentive to recommend that you maintain your account with LPL rather than with another broker-dealer or custodian to avoid incurring the oversight fee. WELLth Advisory Services receives support services and/or products from LPL Financial, many of which assist WELLth Advisory Services to better 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 negotiated rate. Such compensation provided to WELLth Advisory Services includes other types of compensation, such as bonuses, awards or other things of value offered by LPL to WELLth Advisory Services, and may include the following: • • Payments based on production; Equity awards from LPL’s parent company, LPL Financial Holdings Inc., consisting of awards of either restricted stock units or stock options to purchase stock, in each case subject to satisfaction of vesting and other conditions; • Reimbursement or credit of fees that WELLth Advisory Services pays to LPL for items such as administrative • • services or technology fees; Free or reduced-cost marketing materials; Payments in connection with the transition of association 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 • Attendance at LPL conferences and events. Page 20 of 28 CRD # 330537  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 relationship between WELLth Advisory Services and LPL Financial. It is not the result of soft dollar arrangements or any other express arrangements with LPL Financial that involves the execution of client transactions as a condition to the receipt of services. WELLth Advisory Services will continue to receive the services regardless of the volume of client transactions 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 entity to invest any specific amount or percentage of client assets in any specific securities as a result of the arrangement. However, because WELLth Advisory Services receives these benefits from LPL Financial, there is a potential conflict of interest. The receipt of these products and services presents a financial incentive for WELLth Advisory Services to recommend that its clients use LPL Financial’s custodial platform rather than another custodian’s platform. For a further listing of potential conflicts, please refer to LPL Financial’s Brokerage Compensation and Conflicts Disclosure, available at lpl.com/disclosures.html. Transition Assistance Benefits LPL also provides various benefits and/or payments to IARs that are new to the LPL platform to assist them with the costs (including foregone revenues during account transition) associated with transitioning their business to LPL (collectively referred to as “Transition Assistance”). The proceeds of such Transition 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, satisfying any outstanding debt owed to the IAR’s prior firm, offsetting account transfer fees (ACATs) as a result of the IAR’s clients transitioning to LPL’s custodial platform, technology set-up fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees associated with moving accounts. The amount of the Transition Assistance payments is often significant in relation to the overall revenue earned or compensation 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 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 transition costs. The receipt of Transition Assistance creates a conflict of interest in that WELLth Advisory Services has a financial incentive 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 options are not available through LPL, in order to receive the Transition 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’ attempt to mitigate these conflicts of interest by evaluating and recommending that clients use LPL’s services based on the benefits that such services provide to clients, rather than the Transition Assistance earned by any particular WELLth Advisory Services. However, clients should be aware of this conflict and take it into consideration in making a decision whether to establish or maintain a relationship with LPL. If LPL makes a loan to WELLth Advisory Services, there is also a conflict of interest because LPL’s interest in collecting on the loan affects its ability to objectively supervise the registered representatives. Schwab Advisor 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 institutional trading and custody services, which are typically not available to Schwab retail investors. Brokerage and Custody Costs Page 21 of 28 CRD # 330537  For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (e.g., mutual funds or ETFs) do 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. For some accounts, Schwab charges you a percentage of the dollar amount of assets in the account in lieu of commissions. In addition 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 securities bought or the funds from securities sold are deposited (settled) into your Schwab account. These fees would be in addition to the commissions or other compensation you pay the executing 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 utilize as part of WELLth Advisory Services’ service). Trading away can sacrifice best execution and incur additional costs from the other firm, as well as fees from our custodians to transfer in those positions. 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 institutional brokerage services (trading, custody, reporting and related services), many of which are not 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 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 description of Schwab support services. Services that benefit you. Schwab institutional brokerage services include access to a broad range of investment products, execution of securities transactions 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 initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services 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 operating our firm. They include investment research, both Schwab’s own and that of 3rd parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained in Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) Facilitate trade execution and allocate aggregated trade orders for multiple client accounts Facilitate payment of our fees from 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 matter), 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 settle into your Schwab account. Certain trades (for example, mutual funds and ETFs) do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Page 22 of 28 CRD # 330537  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 incentive to use Schwab over other custodians. At the same time, 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, educational 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, marketing, and compliance consulting products and services on our behalf. The fact that we receive these benefits from Schwab is an incentive for us to recommend/request 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. We believe, however, that taken in the aggregate, whichever custodian we use, our selection of the custodians, whether Schwab or otherwise, as custodian and broker is driven by the Best Interest of our clients. Our selection 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 soft 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 participating in the trade. This blocking or bunching technique must be equitable and potentially advantageous for each such account (e.g., for the purposes of reducing brokerage commissions or obtaining a more favorable execution price). Block trading is performed when it is consistent with the duty to seek best execution 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 participation of their account, and in the allocation of orders for the accounts of more than one client. Allocations of all orders are performed in a timely and efficient manner. All accounts participating in a block execution receive the same execution price (average share price) for the securities purchased or sold in a trading day. Any portion of an order that remains unfilled at the end of a given day will be rewritten on the following day as a Page 23 of 28 CRD # 330537  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 securities, broker availability may be limited. Open orders are worked until they are completely filled. If an order is filled in its entirety, securities purchased in the aggregated transaction will be allocated among the accounts participating in the trade in accordance with the allocation statement. If an order is partially filled, the securities will be allocated pro rata based on the allocation statement. WELLth Advisory Services may allocate trades in a different manner than indicated on the allocation statement (non-pro rata) only if all accounts receive fair and equitable treatment. Best Execution On an annual basis, custodial broker-dealers are interviewed to compare the services and fees offered by the different firms. Best execution 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 execution quality for our clients’ transactions. In addition, they provide our firm and our clients with other valuable information 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 regulations 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 prepares individualized reports based upon client need and the services offered. However, clients can request that WELLth Advisory Services 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. Item 14: Client Referrals and Other Compensation Commissionable Securities Sales: In their capacity as registered representatives of LPL Financial, certain Dually Registered Persons may earn commissions for the sale of securities or investment products that they recommend for brokerage clients. They do not earn commissions on the sale of securities or investment products recommended or purchased in advisory accounts through WELLth Advisory Services. Clients have the option of purchasing many of the securities and investment products we make available to you through another broker-dealer or investment advisor. However, when purchasing these securities and investment products away from WELLth Advisory Services, you will not receive the benefit of the advice and other services we provide. WELLth Advisory Services does not engage in activity 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 Transition Assistance (discussed in Item 12 above). LPL also provides other compensation 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. Page 24 of 28 CRD # 330537  The receipt of any such compensation creates a financial incentive 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 regulations. 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 regulations. All clients referred by independent promoter/solicitors to our firm will be given full written 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 solicitation fees are paid unless the promoter/solicitor is registered as an investment advisor representative of our firm. If we are paying solicitation fees to another registered investment advisor, the licensure of individuals is the other firm’s responsibility. From time-to-time, 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 situations, we compensate the referring affiliate for the referral. Actual payment is dictated by the role of the referring affiliate and internal organizational compensation policies. Similarly, we and/or our employees may receive internal compensation for referring prospective or current clients to affiliated SRP businesses. In these situations, referral compensation is paid by our affiliates out of their own assets and is not paid directly by the client. Clients will not be charged additional 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 after the referral or as a flat fee. Such compensation policies are structured to mitigate conflicts of interest and to comply with applicable law, including regulations and guidance applicable to client portfolios subject to ERISA and the applicable securities laws and regulations. WELLth Advisory Services may provide retirement plan sponsors with access to Peopled, Inc. (“Peopled”). Peopled is a technology company that develops software and tools used to support recruitment, talent matching, and related human-capital functions. Its solutions are designed to automate or enhance hiring workflows and may integrate with third-party HR platforms. Peopled operates within the broader human-capital technology sector and does not provide investment advisory services. WELLth Advisory Services will receive compensation in connection with the use of Peopled. Such compensation will include fees associated with client usage, referral arrangements, distribution of services, or other commercial activities related to the platform. This compensation is separate from, and in addition to, the fee WELLth charges retirement plans for its services. These arrangements create a conflict of interest because WELLth Advisory Services has a financial incentive to recommend or promote Peopled. WELLth Advisory Services addresses this conflict through disclosure and by recommending the platform only when it reasonably believes it is appropriate for the client. Clients are not obligated to utilize Peopled and may elect alternative providers or choose not to implement such services. Some affiliated entities in which WELLth Advisory Services’ supervised persons hold ownership and 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, which compensates SRP Holdings Group, LLC or WELLth Advisory Services for client usage, referrals, distribution of services, or other commercial activity. 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 Page 25 of 28 CRD # 330537  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. Item 15: Custody Our firm does not have direct custody of client funds or securities. Regulators generally take the position that any arrangement under which a registered investment advisor is authorized or permitted to withdraw client funds or securities maintained with a custodian upon the advisor’s instruction to the custodian is deemed to have custody of client funds and securities. WELLth Advisory Services maintains limited custody of client funds by virtue of its ability to instruct the client’s custodian to withdraw funds from the client’s account to pay its investment advisory fee. For accounts serviced through Axxcess, Axxcess or its billing platform will calculate and facilitate the deduction of WELLth Advisory Services’ advisory fee pursuant to the client’s written authorization and the applicable custodial arrangements. WELLth Advisory Services’ will provide the fee-calculation information required by applicable law and will rely on the qualified custodian to send account statements showing fee deductions at least quarterly. 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 written authorization permitting 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 calculation, 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 questions with us about the custody, safety, or security of their assets. The custodians we do business with will send you independent account statements listing your account balance(s), transaction history and any fee debits or other fees taken out of your account. It is recommended that clients compare custodial brokerage statements to the reports that are provided to you by WELLth Advisory Services. Item 16: Investment Discretion WELLth Advisory Services maintains limited power of attorney in client accounts held at the custodial broker dealer. The limited power of attorney will grant either full or limited discretion in client accounts. The limited power of attorney authorizes WELLth Advisory Services to purchase and sell securities without obtaining the client’s prior permission to execute transactions. All transactions effected on behalf of clients will be in accordance with the client’s investment objectives that have been previously discussed and agreed upon with WELLth Advisory Services and the client. Institutional Investment Strategies and Risks For institutional accounts and investment vehicles, WELLth Advisory Services typically exercises discretionary authority consistent with the governing documents of the account or fund. Discretion will include authority to select securities, determine position sizes, enter into derivatives or other investment transactions, and rebalance portfolios without prior client approval, subject to applicable investment guidelines. Page 26 of 28 CRD # 330537  Discretionary Authority for OCIO Clients Under OCIO engagements, WELLth Advisory Services typically exercises broad discretionary authority to manage client assets without prior approval for each transaction, subject to the investment policy statement, OCIO agreement, and any client-imposed restrictions. This authority will include selecting and terminating managers, reallocating assets, entering into investment vehicles, and rebalancing portfolios. Item 17: Voting Client Securities Clients will receive proxy information 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 voting services to its clients. Clients may contact their WELLth Advisory Services IAR by telephone or email if they have questions. WELLth Advisory Services does not monitor class-action lawsuits involving securities held or formerly held in client accounts, determine whether a client is eligible to participate in a class action, file claims on a client’s behalf, or determine whether participation is in the client’s best interests. Clients remain responsible for evaluating and responding to class-action notices unless a separate written agreement expressly provides otherwise. Item 18: Financial Information As an investment advisory firm that maintains discretionary authority, we are required to disclose any financial condition that would be likely to impair our ability to meet our contractual and fiduciary obligations to our clients. WELLth Advisory Services has no such financial conditions to report. WELLth Advisory Services is not and has not been the subject of a bankruptcy proceeding. When conducting financial planning services, WELLth Advisory Services may require a portion 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. Additionally, we do not take custody of client funds or securities. Therefore, we are not required to file financial information with the SEC or with the states where WELLth Advisory Services is notice filed. Additional Information IARs will be required to meet the qualification requirements of the states where WELLth Advisory Services conducts its advisory business. Professional Certifications Certain WELLth Advisory Services IARs may have earned professional certifications and designations that are required to be explained in further detail. This information will appear on each individual IAR’s ADV 2B which supplements information contained in this ADV 2A brochure. The following are the most recognized designation that many of our IARs hold: Certified Financial Planner ™ (CFP®): Certified Financial Planners are licensed by the CFP® Board to display the CFP® mark. Candidates for the CFP® designation must meet the following requirements: • Bachelor’s degree from an accredited college or university. • • • • Completion of the financial planning education requirements set by the CFP® Board (www.cfp.net). Successful completion of the 10-hour CFP® Certification Exam. Three years qualifying full-time work experience. Successfully passing the Candidate Fitness Standards and background check. WELLth Advisory Services Privacy Policy We recognize our obligation to keep information about you secure and confidential. It is important for you to know that we do not sell your information to anyone. We restrict access to non-public personal information about you to Page 27 of 28 CRD # 330537  those IARs and employees who need to know that information to provide products or services to you. We also maintain physical, electronic, and procedural safeguards to guard your non-public personal information. WELLth Advisory Services Business Continuity Plan In accordance with federal requirements WELLth Advisory Services maintains a Business Continuity Plan that describes what steps will be taken to ensure the continuity of our business operation in the event of an unanticipated disaster. The plan has been designed with procedures to ensure that client documentation 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 Continuity Plan, please contact our office. Page 28 of 28 CRD # 330537