Wescott Financial Advisory Group LLC

March 29, 2026 Wescott Financial Advisory Group, LLC Form ADV Part 2A: Firm Brochure (CRD # 105989 / SEC# 801-29752) FOR FURTHER INFORMATION, PLEASE CONTACT: CARRIE DELGOTT CHIEF COMPLIANCE OFFICER 215.979.1600 | CDELGOTT@WESCOTT.COM This brochure provides information about the qualifications and business practices of Wescott Financial Advisory Group, LLC. If you have any questions about the contents of this brochure, please contact us at T: 215.979.1600 or via email at cdelgott@wescott.com. The information contained in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or any state securities authority. Registration does not imply a certain level of skill or training. Additional information about our firm is available on the SEC’s website at www.adviserinfo.sec.gov. (Click on the link, select “Investment Adviser – Firm,” and enter our firm name or CRD #105989. Results will display all firm-level disclosure brochures.) m o c . t t o c s e w - PLEASE RETAIN FOR YOUR RECORDS - 30 South 17th Street • Philadelphia, PA 19103 • 215.979.1600 162 Main Street • Harleysville, PA 19438 • 215.256.4600 201 S. Biscayne Boulevard • Suite 3400 • Miami, FL 33131 • 305.960.2350 Copyright © 2025 Wescott Financial Advisory Group LLC All Rights Reserved C:\Users\KOF700\OneDrive - Duane Morris LLP\Desktop\2025 Wescott ADV Template www.wescott.com 1 www.facebook.com/wescottfin www.linkedin.com/company/wescott-financial-advisory-group www.instagram.com/wescottfinancial  Item 2: Summary of Material Changes ___________________________________________________________________________________________ In this item, Wescott Financial Advisory Group, LLC ("Wescott,” the “Adviser” or “Firm”) is required to summarize only those material changes made to this brochure since our last Annual Updating Amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last Annual Updating Amendment on March 14, 2025, we have made changes to the following brochure sections: Item 4: Advisory Business Assets Under Management As of December 31, 2025, Wescott’s assets under continuous management total $4,155,788,050. The following represents Client assets under management by account type: Account Type Assets Under Management “AUM” Discretionary Non-Discretionary Total $ 3,181,898,426 $ 973,889,624 $ 4,155,788,050 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss In this section, we added new disclosures regarding the Adviser’s limited use of artificial intelligence (“AI”) tools to support operational efficiency and Client service functions. These disclosures clarify that AI is not used in the firm’s investment selection or portfolio management processes and describe the potential risks associated with AI, including data security, confidentiality, accuracy, and evolving regulatory considerations. Enhancement of ADV Disclosures This brochure has been further amended to include enhanced disclosures, additional clarifying information regarding Wescott’s advisory practices, and certain aesthetic and formatting changes. While these updates may not be material, they are intended to improve clarity and help investors better understand our business model, procedures, and services. Full Brochure Availability At any time, we may amend this document to reflect changes in Wescott’s business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary due to material changes, we will provide Clients, either by electronic means or in hard copy, with a new brochure or a summary of material changes from the previously supplied document, with an offer to deliver a full brochure upon request. Please retain this document for future reference, as it contains essential information concerning our advisory services and business. You may view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Wescott Financial Advisory Group, LLC” or CRD #105989. The SEC's website also provides information about any Wescott-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may also obtain a copy of this brochure free of charge by contacting us directly at T: 215.979.1600 or cdelgott@wescott.com. 2  Item 3: Table of Contents ___________________________________________________________________________________________ Item 1: Cover Page ................................................................................................................................. 1 Item 2: Summary of Material Changes .................................................................................................. 2 Item 3: Table of Contents ....................................................................................................................... 3 Item 4: Advisory Business ...................................................................................................................... 4 Item 5: Fees & Compensation .............................................................................................................. 17 Item 6: Performance-Based Fees & Side-By-Side Management .......................................................... 25 Item 7: Types of Clients ........................................................................................................................ 25 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .................................................... 27 Item 9: Disciplinary Information .......................................................................................................... 35 Item 10: Other Financial Industry Activities & Affiliations ................................................................... 36 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............ 37 Item 12: Brokerage Practices ............................................................................................................... 39 Item 13: Review of Accounts ............................................................................................................... 43 Item 14: Client Referrals & Other Compensation ................................................................................ 47 Item 15: Custody .................................................................................................................................. 49 Item 16: Investment Discretion ........................................................................................................... 50 Item 17: Voting Client Securities .......................................................................................................... 52 Item 18: Financial Information.............................................................................................................. 53 Item 19: Requirement for State Registered Advisers ........................................................................... 53 3  Item 4: Advisory Business ___________________________________________________________________________________________ Firm Description Wescott Financial Advisory Group, LLC (“Wescott” or the “Adviser”) is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940 (“Advisers Act”), as amended. Headquartered at 30 South 17th Street, Philadelphia, Pennsylvania, with additional locations in Florida and New Jersey, the Firm has been providing investment advisory services since 1987. Principal Owners Wescott is directly owned by its principal shareholders, Grant Rawdin, Founder, CEO, Chairman, Member & Managing Member (50% but <75% ownership), Wescott Holding Company, LLC (10% but <25% ownership), and Anterian Holdinge, LTD (10% but <25% ownership). (Please refer to each Principal’s Form ADV Part 2B Brochure Supplement for additional details on their formal education and business background.) Advisory Business Wescott acts as a fiduciary to its advisory Clients, as defined under applicable federal and state securities laws. In its fiduciary capacity, the Adviser owes each Client a duty of loyalty and a duty of care and is required to act in good faith and in the Client’s best interests at all times. Consistent with these obligations, Wescott seeks to identify, fully and fairly disclose, and appropriately address potential conflicts of interest, and endeavors to avoid circumstances in which the interests of the firm or any Client are placed ahead of the interests of another Client. As used in this brochure, the terms “we,” “our,” and “us” refer to Wescott Financial Advisory Group, LLC. The terms “you,” “your,” and “Client” refer to any Client or prospective Client of the firm. The term “Associated Persons” or “Associates” refers collectively to Wescott’s Supervised Persons, as that term is defined under the Advisers Act, including the firm’s officers and directors, Control Persons, employees, and investment professionals—the firm’s Investment Advisor Representatives (“IARs”)—who are subject to Wescott’s supervision and control and authorized to provide investment advisory services on the Adviser’s behalf. Wescott provides investment advisory services designed to help Clients pursue their financial objectives. Each advisory relationship is managed by one or more of the firm’s IARs, who are responsible for establishing, overseeing, and maintaining the Client relationship and who serve as the primary point of contact between Wescott and its Clients. IARs are required, pursuant to applicable laws, regulations, and firm policies, to maintain appropriate licenses and complete required training to recommend specific investment products, strategies, and services. Accordingly, an IAR’s ability to recommend certain investments, strategies, or services may be limited by licensing status, training, or other regulatory restrictions. IARs may conduct advisory business and respond to Client inquiries only in the jurisdictions in which they are properly registered or otherwise exempt from registration. Clients may obtain additional information regarding the background, qualifications, and business practices of their assigned IAR by reviewing the applicable Form ADV Part 2B Brochure Supplement, which is a separate disclosure document required to be delivered to Clients before or at the inception of the advisory relationship, together with this Form ADV Part 2A brochure. (Note: Clients who did not receive these disclosures may request copies by contacting their 1600 or via email at cdelgott@ IAR or Wescott’s Chief Compliance Officer, Carrie M. Delgott, at T: 215.979 wescott.com.) . ‑ Non-Exclusive Relationship exclusive advisory relationship with its Clients and provides advisory services to multiple Wescott maintains a non Clients simultaneously. Advice and investment strategies are developed based on each Client’s individual financial circumstances, objectives, and constraints. As a result, the advice or investment decisions made for one Client may differ from, or be inconsistent with, those made for another Client regarding the same security or investment. (See Item 8 - Methods of Analysis, Investment Strategies & Risk of Loss for additional information.) 4  ‑ Other Professional Service Provider Recommendations party professionals to assist with At a Client’s request, Wescott may recommend independent third implementation matters or related services. Such professionals may include, but are not limited to, attorneys, accountants, insurance professionals, or other specialists. Clients are under no obligation to engage any recommended professional and remain free to select service providers of their choosing. Any professional engaged by a Client is retained directly by the Client pursuant to a separate agreement that governs the scope of services, fees, and other contractual terms. Unless otherwise specifically disclosed, Wescott is not a party to these arrangements, does not share in any fees or compensation paid to or received by the recommended professional, and does not have the authority to accept Clients on behalf of, or otherwise bind, any such professional. Each recommended professional retains sole discretion to accept or decline any referral, for any reason or no reason. ‑ Clients are responsible for reviewing and understanding the terms of any agreement entered into with a third party professional, including all applicable fees and charges. Clients retain full discretion over all implementation decisions and may accept or reject any recommendation made by Wescott. Wescott does not party professionals and is not responsible for their acts, supervise, direct, or control the services provided by third omissions, or services. Any disputes arising from a Client’s engagement of a recommended professional must be ‑ resolved directly between the Client and the engaged provider. Client Responsibilities Wescott’s advisory services are based on information provided by Clients. The Adviser cannot effectively perform its contractual obligations or fulfill its fiduciary duties unless Clients provide accurate, complete, and timely information regarding their financial circumstances, investment objectives, risk tolerance, and other information relevant to the advisory relationship. Clients are responsible for promptly furnishing requested information or documentation, notifying Wescott of any material changes in circumstances, and otherwise complying with the terms of their written Investment Advisory Agreement (“Advisory Agreement” or “Agreement”). Regardless of whether a Client has granted discretionary authority or retains final decision making authority, Clients are responsible for ensuring that their IAR has all information reasonably necessary to provide appropriate recommendations and/or manage the account ‑ consistent with the Client’s objectives, limitations, and restrictions. Clients must promptly notify Wescott, in writing, of any changes to information previously provided that may affect account management or render prior disclosures inaccurate. Clients or their successors or authorized representatives must also notify Wescott, in writing, of any event that may affect the validity of the Agreement or Wescott’s authority thereunder, including, for Clients that are not natural persons, events such as dissolution, merger, termination, or bankruptcy. Wescott maintains ongoing communication with Clients and periodically reviews Client accounts, as described in Item 13: Review of Accounts. Wescott and its IARs generally rely on information provided by the Client or on the Client’s behalf and are not required to independently verify such information, including information received from third parties such as accountants or attorneys. Wescott reserves the right to decline or terminate an advisory engagement if a Client willfully withholds, conceals, or refuses to provide information that Wescott determines is material to the advisory services provided. Establishing an Advisory Relationship Wescott provides investment advisory services, including portfolio management and related financial planning services, designed to address each Client’s objectives within the scope of the advisory relationship. 5  An advisory relationship generally begins with an initial discovery process through which Wescott obtains information necessary to evaluate the appropriateness of the advisory services selected and to establish investment and planning objectives consistent with the Client’s goals and the nature of the engagement. Information gathered through this process forms the basis for developing a Client’s personal wealth management approach and for tailoring advisory services to the Client’s individual circumstances. The Advisory Agreement Wescott’s investment advisory services are provided pursuant to the Client’s comprehensive written Advisory Agreement, which serves as the primary contractual framework governing each Client’s advisory relationship with the firm. This Agreement identifies the Client’s selected program(s) or services, defines the scope of services to be provided, and sets forth the respective duties and responsibilities of Wescott and the Client. ‑ ‑ imposed restrictions and limitations on services, as well as the The Agreement reflects any written Client applicable brokerage and custodial arrangements, as described below. It also details advisory fee billing practices, including the fee calculation methodology, billing frequency, proration and termination provisions, and the treatment of any prepaid fees, in accordance with applicable regulatory requirements. In addition, the Agreement discretionary—and incorporates documents the Client’s investment authorization—whether discretionary or non required disclosures under the Advisers Act, including those relating to fiduciary obligations, conflicts of interest, trading practices, and Wescott’s policies regarding proxy voting and class action matters. (See Item 16: Investment Discretion for additional information.) ‑ The Agreement further reflects the custodial arrangements applicable to each account. Wescott does not maintain physical custody of Client funds or securities, except for its limited authority to deduct advisory fees from Client accounts, as disclosed herein. Client assets are held by independent and unaffiliated qualified custodians, and opening documentation either directly from Clients receive applicable custodial agreements and related account the custodian or through the Agreement. (See Item 12: Brokerage Practices and Item 15: Custody for additional information.) The Client’s executed Agreement, together with any applicable supplemental agreements or documents, governs the terms of the advisory relationship and serves as the primary legal document for each Client account. ‑ As determined appropriate by the Client’s IAR, certain advisory arrangements may involve independent third party managers, which may require Clients to enter into separate agreements with the referred manager and, where applicable, its designated custodian. These agreements are separate from the Client’s Advisory Agreement with Wescott and are required only where mandated by the referred manager. (See “Selection of Other Advisors Services” for additional information.) Advisory services will commence only after the applicable agreement(s) and related documents have been fully executed. Wescott’s IARs will provide only those services and assess only those fees, expressly authorized under the executed agreement(s) and consistent with the Client’s stated objectives, limitations, and restrictions. Clients may engage Wescott for additional or expanded services by executing the applicable supplemental or separate agreement(s). Any amendment to an existing agreement will be made in accordance with the amendment provisions set forth therein. (See Item 5: Fees & Compensation for additional information.) Investment Policy Statement Following completion of the discovery process and execution of the Client’s Advisory Agreement, where requested and appropriate in connection with the Client’s selected investment management program, Wescott may prepare a written Investment Policy Statement (“IPS”). The IPS documents the Client’s approved investment objectives, constraints, and relevant risk considerations and serves as a framework to guide portfolio recommendations and, where applicable, ongoing portfolio management. 6  The Client’s IAR uses information obtained through the discovery process and reflected in the IPS to recommend portfolio management services and an investment approach that the IAR believes are appropriate for the Client, consistent with the scope of the engagement. The IPS is intended as a guideline only and does not constitute a contract, amend or supersede the Client’s Advisory Agreement, or guarantee investment results or performance outcomes. (See Item 8: Methods of Analysis, Investment Strategies & Risk of Loss for additional information.) Clients are responsible for reviewing and approving their IPS. only investment advisory firm and does not sell securities or receive commissions. The following Description of Advisory Services Wescott is a fee is a summary of the advisory programs Wescott offers, as described in greater detail throughout this brochure: ‑ • Wealth Management Program Services Selection of Other Advisors Services - Independent Third Party Management Services o Third-Party Management Referral Services o Entrada® Management Program ‑ - o MRK Powered by Wescott Initial Wealth Management Plan Services (“MRK PBW”) o MRK Powered by Wescott Wealth Management Program ("PARTNERS Program") Family Office Solution Services Financial Planning & Consulting Services Legacy SUNSET & PIMA Programs • • • • Retirement Plan & Pension Consulting Services • Asset Allocation Services • Wescott Trust Services • Education Seminars & Workshop Services Clients will indicate their selected advisory services Program and applicable billing or management arrangement directly within the Advisory Agreement. ‑ Wealth Management Program Services Wescott’s Wealth Management Program services represent the firm’s core investment advisory and portfolio discretionary investment management offerings through which Clients receive ongoing discretionary or non portfolio management and related advisory services designed to support their investment objectives within the agreed scope of the engagement, as specified in the Advisory Agreement. Program services generally include: • Ongoing discretionary management and oversight of the Client’s investment portfolio in accordance with the Client’s stated objectives, risk tolerance, and investment guidelines. • Development and implementation of asset allocation strategies, portfolio construction, and periodic rebalancing, as appropriate. • Continuous monitoring of portfolio holdings and investment strategies, with recommendations for adjustments based on market conditions, performance considerations, or changes in the Client’s circumstances. • Preparation and delivery of portfolio performance reports and related written materials, including investment commentary. • Ongoing communication with Clients regarding portfolio activity, investment strategy, and relevant market or economic developments. 7  • Integration of applicable financial planning considerations into portfolio management decisions, where appropriate. • Coordination and monitoring of certain held-away assets over which Wescott does not hold sponsored retirement plans or benefit plans, that are discretionary authority, such as employer included for reporting or tracking purposes as part of the Client’s overall portfolio. ‑ ‑ Where fitting and based on a Client’s objectives and circumstances, Wescott may utilize independent third party investment managers (“Managers” or “TPMs”) to manage all or a portion of a Client’s portfolio, while retaining responsibility for Manager selection, oversight, and ongoing monitoring, as described below. Entrada® Management Program Wescott developed the Entrada® Management Program to provide investment management services for those Clients with investable assets below $2 million. The Entrada® portfolio retains Wescott’s hallmark of a strategic, disciplined, and diversified portfolio, blending the advantages of passive investing with active management. Entrada® combines Wescott’s investment management services with a coordinated, efficient process for needs assessment, account suitability, account administration, portfolio rebalancing, portfolio reporting, and tax optimization. MRK Powered by Wescott Initial Wealth Management Plan (“MRK PBW”) The MRK Powered by Wescott Initial Wealth Management Plan (“MRK PBW”) provides comprehensive financial, tax, estate, and investment planning services tailored for Merck® executives. This program follows a multidisciplinary approach that integrates the proficiency of Wescott’s financial, tax, estate, investment, and risk management professionals to deliver coordinated, holistic recommendations aligned with each Client’s objectives and circumstances. week period. This process includes in ‑ ‑ ‑ The development of the initial wealth management plan involves a significant collaborative effort between Wescott and the Client over a multi depth analysis, planning, and the preparation and presentation of a customized wealth management plan and related investment strategy recommendations designed to help Clients strive to achieve their long term goals. Following delivery of the plan, if a Client elects to engage Wescott for ongoing advisory services under the Wealth Management Program or Entrada® Management Program, Wescott prepares an IPS for Client review and approval prior to the commencement of portfolio investment management. MRK Powered by Wescott Wealth Management Program (“PARTNERS Program”) The MRK Powered by Wescott Wealth Management Program (“PARTNERS Program”) for legacy APS Clients was developed to provide wealth management services to Merck® executives with investable assets of $2 million or more. This minimum account size may be negotiable under certain circumstances, but may still be subject to a $25,000 minimum fee. ‑ Ongoing management services delivered are consistent with those provided under Wescott’s Wealth Management Program. Selection of Other Advisors Services As part of its wealth management offering, Wescott may, where appropriate, provide Clients with access to investment advisory services offered by independent, unaffiliated third party investment Managers. Under the selection of other advisors' services, the Client’s IAR will assist in selecting and overseeing such Managers in accordance with the Client’s investment objectives and the structure of the applicable advisory program. Depending on the program selected, Wescott’s role may include referral services, ongoing monitoring, or both. Party Management Referral Services ‑ Third Under Wescott’s third party management referral services, Clients may elect to establish an advisory relationship directly with the referred TPM and, if accepted, become a Client of that Manager. Wescott does not have the ‑ 8  authority to accept Clients on behalf of any referred Manager, and each Manager retains sole discretion to accept or decline any prospective Client for any reason or no reason at all. In connection with such referrals, Wescott’s role generally includes conducting reasonable due diligence on each TPM before selection or recommendation, assessing whether a prospective Client appears suitable for the Manager’s program (including asset minimums and a general understanding of investment risk), and assisting Clients in understanding the Manager’s investment program, investment management agreement (“IMA”), and applicable suitability requirements. Wescott may also assist Clients in selecting among available Managers and allocation models believed to be appropriate for the Client’s stated objectives, risk tolerance, and overall financial circumstances. Party Management Services ‑ ‑ Independent Third Alternatively, under Wescott’s independent third party management services, Clients may select an independent, unaffiliated investment manager (“Independent Manager”) to manage all or a portion of their assets as part of the Client’s ongoing advisory relationship with Wescott. When an Independent Manager is engaged, Wescott’s role may include delegating discretionary investment management authority to the Independent Manager, subject to the applicable advisory program, the Client’s Advisory Agreement with Wescott, and the terms of any agreement between the Client and the Independent Manager. Depending on the Independent Manager and the applicable program's structure, Clients may be required to enter into a separate written investment management agreement (“IMA”) directly with the Independent Manager. Where required, such agreements govern the Independent Manager’s authority, services, fees, and responsibilities. In all cases, agreements with an Independent Manager or its designated custodian are separate and distinct from the Client’s Advisory Agreement with Wescott and are provided to Clients at or before the time of engagement. Clients receive the Independent Manager’s applicable disclosure documents, including the manager’s Form ADV Part 2A brochure and any required brochure supplements, at or before engagement. Clients are responsible for reviewing and understanding the terms of all agreements entered into with an Independent Manager, including provisions relating to fees, investment discretion, custody, investment strategies, termination rights, and any applicable refund policies. ‑ Once engaged, Wescott continues to provide advisory services in connection with the discretionary or non discretionary selection or recommendation of Independent Managers. Ongoing, the Client’s IAR monitors accounts managed by Independent Managers to assess whether the Manager’s investment strategies and target allocations remain generally consistent with the Client’s stated investment objectives and overall best interests. This monitoring does not include day to day management of individual securities. ‑ ‑ ‑ In evaluating Independent Managers for acceptance to the Adviser’s platform, Wescott conducts reasonable due diligence, which may include reviewing public regulatory filings, disclosure documents, materials provided by the manager, and information from reputable independent third party research providers. To the extent practicable, Wescott considers a range of qualitative and quantitative factors, including investment strategy, historical performance, risk characteristics, management style, reputation, financial condition, reporting capabilities, pricing, research resources, and operational infrastructure. The Independent Manager retains responsibility for investment management and portfolio oversight of assets allocated to it, including portfolio construction, security selection, trading, rebalancing, and related activities. These responsibilities are carried out in accordance with the applicable IMA and the Client’s stated investment 9  objectives, guidelines, and suitability information. The applicable IMA defines the scope of authority exercised by an Independent Manager and may vary depending on whether the account is managed on a discretionary or non discretionary basis. ‑ Client assets managed by Independent Managers are held by independent, unaffiliated qualified custodians selected by the Independent Manager. Wescott does not take custody of Client funds or securities in connection with Independent Manager services, does not have physical possession of Client assets, and does not access Client funds or income generated in Independent Manager custodial accounts. A separate custodial agreement governs the relationship between the Client and the custodian. ‑ Clients are responsible for all custodial, brokerage, and transaction related fees and expenses associated with Independent Manager accounts. Wescott is not responsible for the acts or omissions of any Independent Manager or custodian, nor for a custodian’s compliance with the terms of the Client’s brokerage or custody agreement. Clients receive full and fair disclosure of all material aspects of such referred Manager arrangements at or before the time of referral, including, as applicable: Wescott’s Form ADV Part 2A brochure, applicable Form ADV Part 2B brochure supplement(s), Privacy Notice, written disclosures describing the relationship with the Independent Manager, including any referral or compensation arrangement, material terms, and material conflicts of interest; and any additional disclosures required by federal or state law. Clients should be aware that referral and TPM arrangements may give rise to conflicts of interest, particularly where Wescott receives advisory fee compensation in connection with an ongoing advisory relationship. Family Office Solution Services Our family office solution services are designed to help Clients organize their financial situation and plan for the tax-efficient transfer of wealth to the next generation. Such services generally include financial planning in the following areas: Family continuity. Lifestyle management. Family philanthropy. • • Estate planning and trustee oversight. • Wescott tax and financial planning. • • • Risk management. based, comprehensive planning to limited scope or single ‑ ‑ ‑ ‑ ‑ Financial Planning & Consulting Services Wescott offers Clients comprehensive, tailored financial planning and consulting services on either an hourly or fixed upon fee basis. The scope and nature of these services vary based on the Client’s needs and the agreed subject engagement, and may range from broad analyses. Services may be provided on a standalone basis pursuant to a separate Financial Planning Agreement or, where applicable, in conjunction with other advisory services offered by the firm. The scope of services, complexity of analysis, recommendations developed, and the form of any written materials, reports, or presentations provided are determined by the terms of the engagement. (See Item 5: Fees & Compensation for additional information.) Financial planning and consulting services may include, but are not limited to, advice and analysis in one or more of the following areas: • Asset allocation and investment consulting. • Business and succession planning. 10  • Cash flow forecasting and financial reporting. • Distribution planning. • Estate and charitable giving planning. • Retirement planning and retirement plan analysis. • Risk management and insurance needs analysis. Depending on the engagement, services may address a Client’s current and projected financial condition using information provided by the Client and assumptions that Wescott believes to be reasonable at the time the analysis is prepared. In providing these advisory services, Wescott may make assumptions regarding interest rates, inflation rates, and the performance of financial markets and the broader economy, and may rely, in part, on historical data and past trends. (See Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss for additional information.) Clients engaging Wescott for financial planning or consulting services will execute a Financial Planning Agreement that defines the scope of services, fees, deliverables, and termination provisions applicable to the engagement. Fee arrangements - including service billing options and whether a written report or electronic financial plan will be provided- are documented in the executed Financial Planning Agreement before commencement of services. ‑ Financial planning and consulting services do not include discretionary investment authority, investment implementation, or monitoring of recommendations as part of a stand alone financial planning or consulting engagement unless the Client separately engages the firm for investment advisory services under a written Advisory Agreement. Financial Planning Process As part of the financial planning process, Wescott works with Clients to evaluate their financial circumstances, objectives, risk tolerance, and planning priorities. Clients may be asked to provide detailed information regarding personal and family circumstances, investments, insurance coverage, retirement plans, estate planning documents, and other information relevant to the services requested. Based on the information provided, the Client’s IAR will develop customized recommendations designed to assist the Client in evaluating financial strategies and planning alternatives. Financial plans are based on the Client’s circumstances at the time they are prepared, on information the Client has disclosed. Financial plans generally do not include tax preparation, legal advice, or detailed liability risk party professionals as appropriate. analysis. Clients are responsible for obtaining such services from qualified third ‑ Where applicable, Clients will receive a formal written report or financial plan summarizing the analysis performed and recommendations presented. Clients are responsible for reviewing and approving any financial plan delivered to them. ‑ Ongoing planning is continuous and lacks a clear beginning/end. Financial planning consultations are structured as discrete, one time engagements with a defined scope and are not ongoing. Such engagements are typically completed within approximately 90 days, depending on the scope and complexity of the engagement and the Client’s timely provision of requested information. If services are not completed within six (6) months, any unearned fees will be prorated and refunded in accordance with the terms of the applicable Financial Planning Agreement. Because financial planning is an iterative process, circumstances may arise in which a Client’s situation differs materially from what was disclosed at the outset of the engagement. If a material scope change is required, Wescott will notify the Client and provide a revised fee or engagement terms for review and approval before performing additional work. Any additional planning services or updates generally require execution of a new 11  current hourly rates, which must be approved in Financial Planning Agreement and are subject to Wescott’s then writing before commencement. (See Item 5: Fees & Compensation.) ‑ ‑ Financial planning and consulting services may be the sole service provided to a Client. Execution of a Financial Planning Agreement does not obligate the Client to engage Wescott for investment advisory services or to implement any recommendations through Wescott or any affiliated or unaffiliated third-party. Clients are not required to act on any financial planning or consulting recommendations. Implementation of any recommendations is entirely at the Client’s discretion, and may be made through any financial institution, broker dealer, or service provider of their choosing. Wescott may, at the Client’s request, assist with implementation, subject to the execution of appropriate agreements. Clients should refer to their Financial Planning Agreement for complete details. Legacy SUNSET & PIMA Programs Wescott no longer offers the SUNSET and PIMA Programs to new Clients. However, Wescott continues to provide advisory services to existing Clients who remain invested in these programs pursuant to their existing Agreements. Clients should refer to their applicable Agreements for program specific terms, including fees. ‑ Retirement Plan & Pension Consulting Services As part of its advisory services, Wescott also offers retirement plan and pension consulting, including various levels of advisory and consulting, investment due diligence, education, and other investment advisory services, provided to Clients with employee benefit plans or other retirement accounts for a fee, as described herein. These services are designed to assist Plan sponsors in meeting their management and fiduciary obligations to Plan Participants under the Employee Retirement Income Security Act of 1974 (“ERISA”). Wescott also provides advisory services to pension, profit-sharing, and 401(k) plans. Pension consulting services comprise three distinct services. Under this program, Clients may choose to use any or all of the following services: 1. Selection of Investment Vehicles & Asset Allocation Models – The Client’s IAR will assist plan sponsors in constructing appropriate asset allocation models and recommend specific investment vehicles. 2. Monitoring Investment Performance – IARs will continuously monitor the performance of recommended investment managers and recommend changes to plan sponsors, as appropriate. 3. Employee Communications - For pension, profit sharing, and 401(k) plan Clients with individual plan participants exercising control over their own account ('self-directed plans'), the Client’s IAR will provide an annual report covering mutual fund manager performance and annual educational support for plan participants. The topics covered are determined in consultation with plan sponsors, in accordance with the ERISA Section 404(c) guidelines. Educational support and investment workshops do not provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. For retirement plan services, Client assets remain held with the retirement plan’s custodian or trustee, as designated by the plan sponsor or Responsible Plan Fiduciary. Wescott does not take custody of plan assets and provides advisory or fiduciary services in accordance with ERISA and the applicable plan documents. Custodial relationships are disclosed to Clients in advance. (Additional information regarding Wescott’s brokerage practices and custodial arrangements is provided in Item 12: Brokerage Practices and Item 15: Custody.) To the extent Wescott provides investment advice for a fee or exercises discretionary authority over plan assets, Wescott is considered a fiduciary under ERISA and the Internal Revenue Code of 1986. In this capacity, our status is that of an investment advisor registered under the Advisers Act and a fiduciary under ERISA Part 4, Title 1. In performing these services, Wescott acts either as a non-discretionary fiduciary of the Plan, as defined in Section 3(21) of ERISA, or as a discretionary fiduciary of the Plan, as defined in Section 3(38) of ERISA. Wescott is not subject to any disqualification under Section 411 of ERISA. 12  ‑ Plan Fiduciary Authority & Reliance on Plan Documents governed engagements, Wescott relies on representations from the plan sponsor or other responsible For ERISA plan fiduciary that such person has the authority to engage the Adviser, to bind the plan to the applicable Advisory Agreement, and to confirm that our services are consistent with the plan’s governing documents, investment policies, and applicable guidelines. The plan fiduciary agrees to provide Wescott with complete and accurate copies of all relevant plan documents, including investment policy statements, guidelines, and restrictions, and to notify Wescott promptly in writing of any material changes. Where the Client’s IAR advises only a portion of a plan’s assets, the plan fiduciary will provide documentation of any plan level investment policies or restrictions applicable to those assets. ‑ Wescott’s responsibilities are limited to the assets under its advisement and the services expressly described in the applicable Advisory Agreement. Except where Wescott has been expressly appointed as an ERISA § 3(38) investment manager, Wescott does not assume responsibility for overall plan diversification and has no responsibility for plan assets not subject to its advisory services. 02 (“PTE 2020 ‑ ‑ ERISA, Retirement & Other Qualified Accounts To comply with the U.S. Department of Labor’s Prohibited Transaction Exemption 2020 02”), as currently in effect, where applicable, and pursuant to regulations issued by the U.S. Department of Labor (“DOL”), we are required to provide the Plan’s Responsible Plan Fiduciary—the individual authorized to engage us as an investment adviser to the Plan—and our Clients with a written description of the services we provide, the compensation we receive, any material conflicts of interest, our status as an ERISA fiduciary, and the notice set forth below: “When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, and the laws governing retirement accounts. How we are compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must:  Meet a professional standard of care when making investment recommendations (give prudent advice).  Never put our financial interests ahead of yours when making recommendations (give loyal advice).  Avoid misleading statements about conflicts of interest, fees, and investments.  Follow policies and procedures to ensure we provide advice in your best interest.  Charge no more than is reasonable for our services.  Give you basic information about conflicts of interest. ‑ We have a financial incentive to recommend that a Client roll over assets from a retirement account to an account for which Wescott provides investment advice, because doing so increases our assets under management. As fiduciaries, we will recommend a rollover only if we believe it is in the Client’s best interest. Clients are not required to complete a rollover and are not obligated to engage Wescott to manage or provide advice on their retirement assets. If a Client elects to roll over retirement assets to an based advisory fee, as disclosed IRA subject to our management, those assets will be subject to an asset in the applicable Advisory Agreement. If we recommend that a Client leave assets in an existing employer sponsored plan, Wescott will not receive any compensation for that recommendation.” ‑ It is essential that you understand the differences between these accounts and decide whether a rollover is best for you. Before proceeding, if you have questions, please contact us directly. 13  governed plans or other qualified retirement accounts, based ‑ ERISA Fiduciary Status, Compensation & Prohibited Transaction Considerations To the extent acting as a fiduciary with respect to ERISA Wescott and its IARs are generally prohibited from receiving both advisory fees and transaction compensation unless permitted under applicable prohibited transaction exemptions or other regulatory relief. ‑ The compliance of any recommendation or investment is determined as of the date it is made, based on the information provided by the plan fiduciary at that time. The plan fiduciary is responsible for notifying Wescott promptly in writing if any recommendation or transaction is inconsistent with applicable plan documents or instructions. Retirement Account Rollover Considerations Individual participants in corporate Plans advised by Wescott who are retiring or changing jobs can request that Wescott provide additional educational information on tax-free transfer options and the benefits of keeping assets in the Plan as long as they remain eligible. Wescott will not solicit Plan Participants to retire or change jobs. For Plan Participants who decide to leave the Plan of their own accord due to retirement or a change in employer, we can be separately engaged to provide recommendations on the advisability of taking retirement Plan distributions. Any Plan Participant services that include discussions about individual distributions or how to invest distribution proceeds will be performed separately with the Plan Participant. In determining whether to rollover a retirement account to Wescott, Plan Participants and Clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company Plans. Further, current employees can sometimes move assets from their company Plan before retiring or changing jobs. IARs will consider various factors before recommending retirement plan rollovers, including the investment options available in the plan versus others available, the rollover options available, each individual's age, personal circumstances, investment options, plan fees and expenses versus those of alternative account types, services, conflicts of interest, penalties, protections from creditors and legal judgments, required minimum distributions and employer stock tax consequences (if any), and the services and responsiveness of the plan's Investment Professionals versus those of Wescott, among others. To the extent the following options are available, Clients should carefully consider the costs and benefits of the following: Leaving the funds in the employer's/former employer's Plan. • • Moving the funds to a new employer's retirement Plan. • Cashing out and taking a taxable distribution from the Plan. • Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for Wescott to manage are encouraged to speak with their CPA or tax attorney before taking any action or making any changes. The following is also offered for Client consideration before making a change: 1. Determine whether the investment options in your employer's retirement Plan address your needs or whether you might wish to consider other investment types: - - Employer retirement Plans generally have a more limited investment menu than IRAs. Employer retirement Plans may offer unique investment options, such as employer securities or previously closed funds, that are unavailable to the public. 14  2. Consider Plan fees & expenses - your current Plan may have lower fees than ours. - - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement Plan and how the share class costs compare with those available in an IRA. You should understand the various products and services you might use with an IRA provider, along with their potential costs. 3. Our strategy/strategies may involve greater risk than your Plan's option(s). 4. Your current Plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73, subject to plan terms and applicable law. 6. Your 401(k) may offer more liability protection than a rollover IRA; this may vary by state. - Generally, federal law protects assets in qualified Plans from creditors. Since 2005, IRA assets have been largely protected from creditors in bankruptcy proceedings. However, there can be some exceptions to the usual rules, so consult an attorney about protecting retirement Plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. 9. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. If you own company stock in your Plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your Plan may allow you to hire Wescott as the manager and keep the assets in the Plan name. Asset Allocation Services We provide asset allocation services tailored to each Client’s financial circumstances, investment objectives, and risk profile. Based on the information gathered during our Client onboarding process, we assist Clients in defining their investment goals and objectives and provide initial recommendations for asset allocation across appropriate asset classes. We review accounts periodically and, when appropriate, may recommend adjustments to asset allocation to help maintain consistency with the Client’s stated objectives and risk tolerance. Clients retain full discretion at all times to accept or reject any recommendation. Clients are solely responsible for implementing all recommendations. Unless Clients engage us separately for discretionary portfolio management or trade execution services, we do not execute transactions or implement changes to their asset allocation. Westcott Trust Services Wescott Trust Services offers trust and fiduciary solutions for Clients whose financial, family, or business circumstances warrant the use of a professional fiduciary. Under this program, Wescott Trust Services acts as a trust representative of National Advisors Trust Company (“NATC”), a federally chartered trust company regulated by the Office of the Comptroller of the Currency (“OCC”), a bureau of the U.S. Department of the Treasury, and authorized to conduct trust business in all 50 states. Wescott Financial Advisory Group is a shareholder of National Advisors Trust Company, holding an ownership interest of less than 0.25%. This ownership interest presents a conflict of interest, as Wescott Financial Advisory Group has a financial incentive to recommend NATC. Clients are under no obligation to use NATC and may select any qualified trustee or trust company of their choice. (See Item 10: Other Financial Industry Activities & Affiliations for additional information.) 15  related topics on an “as ‑ ‑ Educational Seminars & Workshop Services Wescott provides investment education seminars and workshops, and may speak at community events and conferences on various investment announced” basis for groups seeking general education on investments and other personal finance matters. Seminar and workshop content vary depending on the audience and are purely educational, with no sale of investment products. Information presented during these events is general in nature, is not tailored to any individual’s circumstances, and does not constitute personalized investment advice. Wescott and its IARs do not provide personalized investment advice, recommendations, or portfolio management services during such events. Investment advice will be provided only pursuant to a separate advisory engagement, and only after the attendee’s individual financial information, investment objectives, and circumstances are obtained and evaluated. Any materials distributed in connection with educational seminars or workshops are provided for informational and educational purposes only and should not be construed as accounting, investment, legal, tax, or other professional advice. Attendees are under no obligation to schedule a consultation, engage Wescott for advisory services, purchase any services, or become Clients of the firm as a result of attending such events. Client Tailored Services Wescott offers a consistent suite of advisory services to its Clients. However, depending on a Client’s individual circumstances, investment holdings, or service needs, certain Clients may engage the Adviser for limited or modified services. In such cases, advisory fees may be reduced or adjusted at Wescott’s discretion, as documented in the Client’s written Advisory Agreement. (See Item 5: Fees & Compensation for additional information.) Imposed Investment Restrictions ‑ Client Clients who engage Wescott for discretionary Wealth Management Program services may impose reasonable restrictions on the Adviser’s discretionary authority at account inception or thereafter. Such restrictions may include limitations on investing in specific securities, asset classes, industries, or investment strategies based on a Client’s preferences, values, beliefs, or other considerations. All Client imposed restrictions must be provided to Wescott in writing, and any modifications or amendments must likewise be submitted in writing. ‑ ‑ Wescott will use reasonable efforts, consistent with industry standards, to comply with Client imposed investment guidelines and limitations. Clients should understand, however, that the imposition of restrictions may affect portfolio construction, management flexibility, and investment performance, and may result in outcomes— positive or negative—that differ from similarly managed accounts or applicable composites not subject to such constraints. Certain investment structures, strategies, or limitations may also constrain the ability to pursue or achieve specific investment outcomes. ‑ Upon receipt of a written restriction request, the Client’s IAR will review the proposed limitation, assess its feasibility, and discuss any potential implications with the Client. If a Client imposed restriction would materially impair effective account management or require substantial deviation from the Adviser’s recommended approach, Wescott reserves the right to decline the restriction or, if necessary, decline or terminate the advisory relationship. Under no circumstances, and regardless of the advisory service provided, will Wescott implement an investment strategy or execute a transaction that it reasonably believes would violate applicable federal or state laws or regulations. Clients who participate in our selection of other advisors' services programs may impose investment restrictions only as permitted under the applicable referred Manager’s program documents and the governing IMA and other applicable agreement(s) of the selected Manager. 16  Types of Investments The types of investments on which Wescott provides advice are not limited to any specific type of advisory service. Wescott’s investment recommendations generally include advice regarding the advisability of owning a broad range of securities, including, as appropriate, the following: Securities traded over-the-counter. Foreign issuers. • Exchange-listed securities. • • • Corporate debt securities (other than commercial paper). • Commercial paper. • Certificates of deposit. • Municipal securities. • Mutual fund shares. • Private fund securities. • United States governmental securities. • Interests in partnerships investing in real estate, oil and gas interests, and other businesses. Although we will predominantly provide advice on the products listed above, Wescott reserves the right to advise on any investment product deemed suitable for a Client's specific circumstances, needs, and individual goals and objectives, and will use other securities as necessary to help diversify a portfolio when applicable and appropriate. Additionally, we may advise on other investments held in the portfolio at the inception of the advisory relationship. Since investment strategies and advice are based on each Client's specific financial situation, the investment advice we provide to one Client may differ from or conflict with that provided for the same security or investment for another Client. (See Item 8 - Methods of Analysis, Investment Strategies & Risk of Loss for additional information.) Wrap Fee Programs A wrap fee program is an advisory service in which a single, specified fee is charged for investment supervision, rather than fees based on individual transactions in a Client’s account. The fee generally covers portfolio management, advice on selecting other investment advisers, and the execution of Client transactions. Wescott does not offer a wrap fee program as part of its advisory services. Assets Under Management As of December 31, 2025, Wescott’s assets under continuous management total $4,155,788,050. The following represents Client assets under management by account type: Account Type Assets Under Management “AUM” Discretionary Non-Discretionary Total $ 3,181,898,426 $ 973,889,624 $ 4,155,788,050 Item 5: Fees & Compensation ___________________________________________________________________________________________ Advisory Fees & Billing Practices Wescott charges advisory fees based on a variety of fee structures, depending on the specific advisory service selected. These fee arrangements may include asset-based fees calculated as a percentage of assets under management (“AUM”), fixed or flat fees, hourly fees, and financial planning retainers, as applicable. Fees are assessed in accordance with the fee schedules described below and in the applicable executed Advisory Agreement. 17  Unless otherwise disclosed for a particular service, advisory fees are generally billed at the start of the engagement and quarterly in advance, based on the value of the Client’s investment portfolio as of the end of the prior calendar quarter. Certain services, such as financial planning, consulting, or trustee services, may be billed on a different basis (e.g., fixed fee, hourly, or pursuant to a separate agreement), as described herein. Required Disclosure Documents Wescott will deliver its Form ADV Part 2A Disclosure brochure, Form ADV Part 3 (Form CRS), and applicable IARs’ Form ADV Part 2B brochure supplement(s) to Clients as required by applicable law, either before or at the time of entering into an Advisory Agreement. If a Client does not receive these disclosure documents at least 48 hours prior to executing an Advisory Agreement, the Client may terminate the agreement within five (5) business days of execution without penalty or advisory fees. (See “Additions, Withdrawals & Terminations” for further details.) Fee Negotiation Wescott may, in its sole discretion, elect to waive its minimum fee for any of the following services based upon certain criteria. In determining whether to negotiate advisory fees or waive minimum account requirements, the firm considers a variety of factors, including the Client’s financial circumstances, the amount of assets placed under management, anticipated future contributions or earning capacity, related accounts, portfolio and account composition, reporting requirements, the nature and scope of services provided, Client tenure, account retention considerations, and pro bono activities. For fee determination purposes, Wescott may aggregate related Client accounts—such as accounts held by members of the same household, family members, or related entities—to satisfy minimum account requirements and establish advisory fee levels based on the combined asset balance. As a result of negotiated and discretionary pricing arrangements, similarly situated Clients may pay different advisory fees for the same or substantially similar services. Clients should also be aware that lower fees for comparable services may be available from other investment advisers or financial service providers. Fee Prepayment Limitation Regardless of fee negotiation, under no circumstances does Wescott require or solicit payment of advisory fees in excess of $1,200 per Client more than six (6) months in advance of services rendered. Legacy Fees Since Wescott began providing investment management services, it has utilized various advisory fee schedules, including certain legacy fee arrangements, that may differ from those currently described herein. From time to time, the Adviser may implement new advisory fee schedules. Such fee schedule changes generally apply only to new Clients entering into Advisory Agreements after the effective date of the latest schedule. The advisory fees charged to existing Clients are typically not affected by the adoption of new advisory fee schedules, unless otherwise mutually agreed in writing. As a result, some existing Clients may pay advisory fees that differ from those described in this brochure, including fees that may be higher or lower than those currently offered for comparable advisory services. Fee Changes Wescott may modify its Fee Schedule upon at least thirty (30) days’ prior written notice to the Client. Any such change will apply prospectively and will be subject to the Client’s right to object and terminate the Advisory Agreement without penalty prior to the effective date of the change. Impact of Advisory Fees Advisory fees are an ongoing expense and, when deducted from a Client’s account, reduce the assets available for investment. Over time, advisory fees may cumulatively affect portfolio performance and overall growth. Clients 18  should consider the long-term impact of advisory fees and are encouraged to raise any questions or concerns regarding fees, costs, or compensation with their IAR. The following describes the fees and compensation for each advisory service offered by Wescott: Wealth Management Program Services The annual Wealth Management Program services advisory fee is calculated as a percentage of assets under management (“AUM”) pursuant to a graduated Standard Fee Schedule, as disclosed in and governed by the Client’s executed Advisory Agreement: Wealth Management Program Services Standard Advisory Fee Schedule Assets Under Management Annual Advisory Fee 1.25% Minimum Requirement: $2,000,000 $2,000,001 – $5,000,000 1.00% $5,000,001 – $7,000,000 0.75% $7,000,001 and above. 0.50% Lower fees for comparable services may be available from other sources. The minimum account requirement may be waived or adjusted at the firm’s discretion; however, Clients remain subject to a minimum annual advisory fee of $25,000. Related Client accounts may be aggregated for fee determination. Existing Clients' fees are billed in advance each calendar quarter based on the market value of the account assets under management as of the last business day of the prior calendar quarter. If assets in excess of $100,000 of the existing portfolio value are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets may be adjusted to reflect the interim change in the portfolio, consistent with the Client’s Agreement. Clients may terminate the engagement at any time by written notice, in accordance with the provisions of the executed Advisory Agreement. Quarterly fees billed in advance are generally deemed earned through the end of the calendar quarter to account for the ongoing time and responsibility for transitioning accounts, portfolio reporting for that final quarter, tax basis reporting, capital gain and loss worksheet reporting, and other services provided during that period. Any unearned portion of prepaid fees is refunded to Clients on a prorated basis. Failure to Timely Remit Payment for Advisory Services Unless waived by the Adviser, Wescott reserves the right to assess interest on any advisory fees or expenses not paid within fifteen (15) days of the due date, at a rate not to exceed the lesser of (1) five percent (5%) per annum, or (2) the maximum interest rate permitted under applicable law. Wescott also reserves the right to recover reasonable costs incurred in connection with the collection of unpaid fees and interest, including reasonable attorneys’ fees, to the extent permitted by law. party management referral services enter into a separate investment Selection of Other Advisors Services Third-Party Management Referral Services Clients who elect to participate in our third management agreement (“IMA”) directly with the recommended third party manager (“TPM”). ‑ ‑ 19  All fees charged pursuant to the TPM’s IMA are billed directly by the TPM in accordance with the terms, billing frequency, and disclosures outlined in the TPM’s Form ADV and related disclosure documents. Termination and refund provisions are likewise governed solely by the TPM’s investment management agreement (“IMA”). Wescott does not control, administer, or enforce these terms. party management Wescott does not charge a Standard Advisory Fee or bill Clients for participation in third referral services. ‑ Independent Third-Party Management Services Clients participating in Wescott’s independent third-party management services, with assets allocated to Independent Managers, will pay Wescott’s standard advisory fee in addition to the investment management fees charged by the Independent Manager. Fees are assessed quarterly in advance, with billing, terminations, and refunds made in accordance with the referred Manager’s IMA. The Independent Manager’s agreement also governs termination of the program’s services and refund provisions. IARs will review with Clients any fees charged to them by Independent Managers. Entrada® Management Program The annual fee for the Entrada® Management Program is 1.00% of assets under management. A minimum of $500,000 in assets under management is required. This minimum may be negotiable under certain circumstances, but may still be subject to a $1,500 annual minimum fee. Wescott may aggregate related Client accounts to meet minimum account requirements and determine the applicable annualized fee. Fees are billed quarterly in advance, at the start of the engagement and at each subsequent calendar quarter, based on the value of the investment portfolio as of the last business day of the prior calendar quarter. Termination and refund treatment follow the Wealth Management Program’s general termination provisions. MRK Powered by Wescott Initial Wealth Management Plan Services (“MRK PBW”) The initial Wealth Management Plan is provided for a fixed planning fee, as follows: • $12,000 – $15,000 for Merck Executive Director and above (or investable assets above $3 million). • $7,500 – $12,000 for Merck Director and below (or investable assets below $3 million). The total planning fee is payable in two installments: 50% at the onset of the engagement, and 50% upon presentation of the Wealth Management Plan. The Wealth Management Planning Agreement governs termination and any refund considerations. MRK Powered by Wescott Wealth Management Program (“PARTNERS Program”) The annual advisory fee for legacy APS Clients participating in Wescott’s PARTNERS Program is 1.00% of assets under management. The minimum annual fee is $3,500, which generally requires at least $250,000 in assets under management. Fees are billed quarterly in advance, and termination and refund treatment follow the firm’s general Advisory Agreement termination provisions, subject to any grandfathered contractual terms applicable to legacy APS Clients. 20  Family Office Solution Services The minimum annual fee for Wescott’s family office solution services is $50,000. The fee includes all services performed by Wescott, including portfolio management and financial planning services (the "Wealth Management Program"). The Wealth Management Program fee is based on the fee schedule below, and the fees are credited against the total minimum annual fee of $50,000. Family Office Solutions Fee Schedule Assets Under Management (“AUM”) $0 – $5,000,000 Maximum Annual Fee 1.00% $5,000,001 – $7,000,000 0.75% $7,000,001 and above. 0.50% Lower fees for comparable services may be available from other sources. Fees are billed quarterly in advance, at the beginning of each calendar quarter, commencing on the date of engagement. Clients may terminate the advisory relationship at any time upon written notice. Any unearned portion of prepaid fees will be refunded on a prorated basis in accordance with the Advisory Agreement’s general termination provisions. Financial Planning & Consulting Services Wescott offers financial planning and consulting services on a standalone basis or, in certain cases, in conjunction with ongoing portfolio management services, as determined by the scope of services outlined in the applicable Advisory Agreement. Financial planning and consulting services are billed at hourly rates, payable in advance, ranging from $150 to $750, depending on the scope, complexity, and nature of the services provided. Clients will be invoiced for any additional work as incurred beyond the initial contemplated scope. The applicable hourly rate and estimated scope of services are disclosed in the Client’s executed Financial Planning & Consulting Agreement. Clients receiving ongoing portfolio management services may receive financial planning and/or financial consulting services at no additional cost, as determined by the scope of services described in the applicable Advisory Agreement. Clients may terminate the advisory relationship at any time upon written notice. Any unearned portion of prepaid fees will be refunded on a prorated basis in accordance with the Advisory Agreement’s general termination provisions. If financial consulting fees are payable in arrears, the Clients will be responsible for a prorated fee based on services performed before termination of the financial consulting agreement. Clients are under no obligation to implement any recommendations provided as part of a financial planning or consulting engagement, nor are they required to engage Wescott for ongoing portfolio management services. Legacy SUNSET & PIMA Programs Legacy SUNSET and PIMA programs are no longer offered to new Clients. Existing Clients remain subject to their original agreements. The applicable legacy Client agreements govern billing practices, termination, and refund provisions and are not restated in this Brochure. 21  Retirement Plan & Pension Consulting Services The annual fee for retirement plan and pension consulting services is charged as a percentage of assets under management, according to the following schedule: Retirement Plan & Pension Consulting Services Fee Schedule Assets Under Management (“AUM”) $0 – $3,000,000* $3,000,001 – $8,000,000 $8,000,001 – $25,000,000 $25,000,001+ Maximum Annual Fee 1.00% 0.75% 0.50% 0.25% thereafter Lower fees for comparable services may be available from other sources. A minimum of $2,000,000 in assets under management is required for this service, with account size and fees negotiable under certain circumstances. Plan sponsors are billed at the start of the engagement and at each subsequent calendar quarter, in advance, based on the value of the investment portfolio at the end of the prior calendar quarter. This minimum fee may prevent Wescott from providing services to small ERISA plans. Clients may terminate the advisory relationship at any time upon written notice. Any unearned portion of prepaid fees will be refunded on a prorated basis in accordance with the Advisory Agreement’s general termination provisions. Asset Allocation Services Asset allocation services are billed at hourly rates ranging from $150 to $750/hour, payable in advance. Clients may be invoiced for additional work beyond the initially contemplated scope. Any unearned prepaid fees are refunded on a prorated basis. Trust Services The annual fee for trustee services through Wescott Trust Services is charged as a percentage of assets under management, according to the following schedule: Wescott Trust Services Fee Schedule Assets Under Management (“AUM”) $0 – $2,000,000* $2,000,001 – $5,000,000 $5,000,001 and above Maximum Annual Fee 0.55% 0.50% 0.35% Lower fees for comparable services may be available from other sources. A minimum of $800,000 of trust assets is required to participate in this program. The applicable Trust Services Agreement governs billing frequency, termination, and refund provisions. These provisions are separate from Wescott’s standard Wealth Management Program advisory fee arrangements. 22  Education Seminars & Workshop Services Educational seminars and workshop services are generally offered on a complimentary basis. Where fees apply, they are determined pursuant to a separate written agreement and may be included in other advisory services. The terms of the applicable agreement will govern any applicable billing, termination, and refund terms. ‑ Additions, Withdrawals & Terminations Account Additions Clients may add cash or marketable securities to their Wescott managed accounts at any time, subject to the terms of the applicable advisory services Agreement and custodial requirements. Wescott reserves the right, in its discretion and consistent with the scope of authority granted, to decline certain securities or to liquidate transferred securities that are inconsistent with the Client’s investment strategy, operational constraints, or custodial limitations. If transferred securities are liquidated, Clients may incur transaction costs, redemption or liquidation fees, mutual fund level charges (including contingent deferred sales charges, where applicable), and tax consequences. Clients are encouraged to consult with their tax advisers regarding the potential tax impact of such transactions. ‑ Account Withdrawals Clients may request withdrawals from their accounts at any time in cash or securities, subject to customary securities settlement procedures, custodial processing requirements, and applicable costs. If a Client elects to transfer an account to another advisory firm, the custodian may impose an outgoing account transfer or termination fee, which is not charged or retained by Wescott. Withdrawals may affect account composition, investment strategy implementation, and the calculation of advisory fees, as described above under “Advisory Fees & Billing Practices.” Termination of Advisory Services Clients may terminate Wescott’s advisory services at any time by providing written notice, in accordance with the terms of the applicable Advisory Agreement. Unless otherwise specified in a governing agreement, termination becomes effective on the business day Wescott receives written notice from the Client. For purposes of this section, a “business day” is any day on which the New York Stock Exchange is open for trading. Termination of the Advisory Agreement does not affect: • The validity of any actions taken by Wescott before termination. • Any liabilities or obligations arising from transactions initiated before termination. • The Client’s obligation to pay advisory fees and other charges properly due and payable, prorated through the effective date of termination, consistent with the applicable Advisory Agreement. Advisory fees billed in advance are generally considered earned on a daily basis during the applicable billing period. Any unearned portion of prepaid advisory fees is refunded to the Client on a prorated basis in accordance with the terms of the Advisory Agreement and applicable law. Where fees are payable in arrears, Clients remain responsible for fees attributable to services provided through the termination date. Upon receipt of a termination notice, Wescott will take reasonable steps to facilitate the orderly transition of the Client’s account(s) in accordance with the Client’s written instructions. If securities are liquidated at the Client’s direction or as part of account closure or transfer, the Client may incur liquidation costs, redemption fees, custodian charges, or tax consequences. Market conditions at the time of liquidation may result in gains or losses. If a Client holds alternative investments or other illiquid securities, those holdings may be subject to imposed redemption restrictions, notice periods, or transfer limitations that could delay liquidation or issuer ‑ 23  prevent transfer to another advisory firm. Certain illiquid investments may not be transferable and may remain subject to the terms of their governing offering documents following termination. Upon termination, Client assets will generally remain invested as of the termination date until further instructions are provided or processed. After termination, Wescott has no further responsibility to provide advisory services, monitoring, or recommendations with respect to the Client’s account(s) or investments. Other Fees & Expenses Wescott’s advisory fees are separate and distinct from other fees and expenses that Clients may incur in connection with their accounts and investments. In addition to the advisory fees paid to the firm, Clients are responsible for paying all applicable third party fees and expenses associated with their accounts and selected investments. ‑ Related Fees ‑ ‑ downs on fixed ‑ ‑ ‑ Custodial, Brokerage & Transaction Clients may incur fees and expenses imposed by custodians, broker dealers, or other financial institutions, including but not limited to: brokerage commissions, transaction and execution charges, custodial or account ups and maintenance fees, wire transfer and delivery charges, account transfer or termination fees, mark mark income securities, regulatory fees, foreign transaction costs, taxes, duties, and other governmental charges. These fees are charged by third parties, not by Wescott, and are governed by the applicable custodial or brokerage agreements executed by the Client. ‑ Margin Interest & Securities Lending Clients who utilize margin borrowing or securities lending will incur interest charges and related fees assessed by the custodian or broker dealer. The terms, interest rates, and risks associated with margin borrowing or securities lending are described in the applicable margin or lending agreements executed between the Client and the custodian or broker dealer. The use of margin or securities lending can increase investment risk and result in additional costs and expenses. ‑ ‑ Mutual Funds, ETFs & Pooled Investment Vehicle Expenses Clients who invest in mutual funds, exchange traded funds (“ETFs”), or other pooled investment vehicles will indirectly bear their proportionate share of the internal fees and expenses of those investments. These expenses typically include investment management fees, administrative costs, operating expenses, and, where applicable, distribution or shareholder servicing fees. Such fees and expenses are described in the applicable prospectuses or offering documents and vary by fund and share class. Mutual funds and similar investment vehicles often offer multiple share classes with different eligibility requirements and expense structures. Different share classes of the same fund may carry higher or lower internal expenses or transaction costs, which can materially affect an account’s long term performance. Certain share classes may not be available through Wescott, even if otherwise available to the general public. ‑ When recommending mutual funds or similar investments, Wescott seeks, where reasonably practicable, to recommend share classes it believes are appropriate based on the Client’s circumstances, including eligibility requirements, transaction charges, internal expense structures, and availability. However, Clients should not assume that all investments will be held in the lowest cost share class available under all circumstances. ‑ ‑ For securities transferred from another institution, Wescott’s IARs will review Client holdings as soon as effective share classes may be available. Where appropriate, practicable to determine whether more cost Wescott may recommend exchanging into a different share class or liquidating a position. Such actions may result in transaction charges, contingent deferred sales charges, or tax consequences. 24  Party Investment Management Fees ‑ ‑ Third party or independent investment managers through Wescott’s advisory programs and When Clients engage third execute a separate investment management agreement with an unaffiliated manager, Clients may incur additional advisory fees charged by such managers, as well as the same categories of third party fees and expenses described above. ‑ ‑ ‑ These fees are disclosed in the applicable third party manager’s Form ADV, investment management agreement, or other disclosure documents and are charged in addition to Wescott’s advisory fees, unless otherwise disclosed. party fees, commissions, or expenses, does not offset Wescott does not receive or retain any portion of such third party managers or reduce its advisory fees by any such amounts, and does not receive compensation from third for such fees except as disclosed herein. ‑ ‑ Evaluation of Fees & Expenses Clients should carefully review and consider all fees and expenses associated with their accounts, including those disclosed in this brochure, their Advisory Agreement, and the applicable prospectuses, custodial agreements, and other third party disclosure documents. These materials describe advisory fees charged by Wescott, as well as commissions, transaction costs, internal investment expenses, and other charges that may apply based on the selected advisory services and investments. Wescott does not represent that its advisory services or recommended investments are offered at the lowest possible cost. Advisory fees and related expenses may be higher than those charged by other investment advisers or financial service providers for similar services, and comparable services or investment products may be available at a lower cost from other sources. Clients are under no obligation to act on Wescott’s recommendations and may purchase investment products through any broker, agent, or provider of their choosing. Item 6: Performance-Based Fees & Side-By-Side Management ___________________________________________________________________________________________ Performance-based fees are fees based on a share of capital gains or capital appreciation of a Client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees alongside those that are not. Wescott does not charge performance-based fees or participate in side-by-side management. (See Item 5: Fees & Compensation for additional information.) Item 7: Types of Clients ___________________________________________________________________________________________ Types of Clients Wescott provides investment advisory services to a diverse range of Clients, including the following: net worth individuals. Individuals (other than high net worth individuals). ‑ ‑ ‑ ‑ sharing plans (other than plan participants). • High • • Charitable organizations. • Family offices. • Irrevocable trusts. • Pension and profit • Corporations and other businesses not listed above. ‑ Minimum Account Size The minimum account sizes to participate in Westcott’s advisory services programs are as follows: 25  Wealth Management Program Services The minimum account size is $2,000,000, which is negotiable under certain circumstances. However, Clients may remain subject to a minimum annual advisory fee of $25,000. Related Client accounts may be aggregated to meet minimum requirements. Party Management Referral Services ‑ Selection of Other Advisors Services Third There is no minimum account size required to participate in this service. Clients are subject to the minimum account requirements established by the referred third party manager, as disclosed in the TPM’s Form ADV and separate investment management agreement. ‑ Party Management Services ‑ ‑ Independent Third imposed minimum beyond the underlying program. Clients may be subject to There is no separate Wescott minimum account requirements imposed by the selected Independent Manager, as disclosed in the Independent Manager’s investment management agreement. In selecting a referred manager, the Client is responsible for understanding the account minimums, requirements, and fee agreement they execute with their referred third- party manager. Entrada® Management Program The minimum account size is $500,000, which is negotiable under certain circumstances. However, Clients remain subject to a $1,500 annual minimum fee. Related accounts may be aggregated to meet the minimum. MRK Powered by Wescott Initial Wealth Management Plan Services (“MRK PBW”) There is no minimum account size required to participate in this service, which is provided for a fixed planning fee based on role and/or investable assets. MRK Powered by Wescott Wealth Management Program (“PARTNERS Program” for legacy APS Clients only.) The minimum account size requirement is $250,000, subject to a $3,500 minimum annual fee and any grandfathered contractual terms. Family Office Solution Services The minimum annual fee requirement is $50,000. There is no stated asset minimum; the minimum annual fee drives eligibility. Financial Planning & Consulting Services There is no minimum account size or asset level to provide financial planning and consulting services. These services may be provided on a standalone basis or in conjunction with other advisory services, pursuant to a written agreement that outlines the scope of services and applicable fees. Legacy SUNSET & PIMA Programs This advisory program is no longer offered to new Clients. Existing Clients remain subject to the original Agreement’s minimum account size requirements and terms. Retirement Plan & Pension Consulting Services The minimum plan asset size is $2,000,000. Account size and fees may be negotiable under certain circumstances. Engagement terms, including the scope of services and compensation, are defined in the applicable advisory or consulting agreement and may vary based on plan characteristics, fiduciary responsibilities, and service complexity. 26  discretionary, Asset Allocation Services There is no minimum account size requirement for these services, which are provided on a non hourly basis. ‑ Wescott Trust Services The minimum trust asset size is $800,000, as governed by the applicable Trust Services Agreement. Education Seminars & Workshop Services Participation in Wescott’s educational seminars and workshops does not require the establishment or maintenance of an advisory account. Thus, there is no minimum account requirement. ‑ Certain investment products, custodial platforms, or third party investment vehicles recommended or utilized by Wescott may impose their own minimum investment amounts, balance requirements, or fees. These requirements are determined by the product sponsor, custodian, or third-party—not by Wescott. Clients are encouraged to review applicable disclosure documents and agreements to understand any such minimums before and during the investment process. sensitive, and opportunistic open architecture, manager approach that incorporates both passive and active investment management strategies and has ‑ Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ___________________________________________________________________________________________ Methods of Analysis Wescott’s investment philosophy reflects a disciplined, tax multi been consistently applied for more than 30 years. ‑ Fundamental Analysis Wescott primarily employs fundamental analysis to formulate its investment advice and/or manage Client assets. The Adviser’s dedicated Investment Research Group continuously evaluates the composition and performance of investment allocation models, selected equity and fixed income managers, and other investment vehicles. The Group employs both qualitative analysis (including assessments of a manager’s investment philosophy, process, ‑ and discipline) and quantitative analysis (including performance metrics, rankings, and comparative analytics). ‑ Wescott regularly analyzes the value and characteristics of its core investment holdings by considering a broad range of economic, market, style, performance, and financial factors. These factors include, among others, prevailing economic conditions, industry and sector trends, benchmark comparisons, portfolio composition, a management discipline, financial condition, and organizational stability, manager’s security selection and risk including staffing and management depth. This analytical framework is designed to assist in determining whether a selected manager or investment continues to perform in a manner consistent with stated objectives, expectations, and the Client’s ongoing needs. Wescott’s securities analysis relies on information obtained from investment managers, rating agencies, custodians, and other publicly available sources that are believed to be reliable and accurate. While the firm seeks to identify inconsistencies or potential inaccuracies, there is an inherent risk that such information may be incomplete, outdated, or misleading, which could adversely affect our analysis and investment recommendations. (Refer to the risk disclosures that follow for additional important information.) term market timing strategies. As a result, investment Our use of fundamental analysis is not based on short values may fluctuate due to broader market movements regardless of the economic or financial factors evaluated, ‑ and securities or funds may decline in value even when the underlying analysis remains sound. 27  ‑ Investment Strategy Wescott’s investment advisory and management services suite is designed to accommodate a wide range of investment philosophies and objectives. Our investment strategies and advice vary based on each Client’s individual circumstances and are implemented only when they are consistent with the Client’s investment objectives, risk tolerance, time horizon, liquidity needs, and other relevant considerations. Client imposed restrictions and guidelines are also taken into account and may affect the composition and ongoing management of a Client’s portfolio. ‑ ‑ ‑ In managing Client accounts, we typically purchase securities with the intention of holding them for a year or longer, expecting their value to grow over a relatively long period. This long term purchase strategy is generally employed when we believe a security is currently undervalued and/or when we seek to maintain exposure to a term market projections. A risk associated with this approach particular asset class over time, regardless of short term opportunities for a Client. is that, by holding securities for extended periods, we may miss profitable shorter In addition, if our assessments prove incorrect, a security’s value may decline—potentially significantly—before a decision to sell is made. In addition to the foregoing, we consider other relevant factors and practices when determining appropriate investment strategies for Client accounts, including but not limited to the items described below: Asset Allocation - Portfolio construction generally reflects an allocation among asset classes based on the liquidity needs, and other suitability factors. Client’s objectives, risk tolerance, time horizon, Diversification across asset classes is designed to manage risk and volatility; however, asset allocation and diversification do not guarantee profits or protect against losses. ‑ ‑ ‑ ‑ Oriented Investing - Depending on a Client’s objectives, portfolios can Capital Growth and/or Income oriented investments can emphasize capital appreciation, income generation, or a blend of both. Income rate risk, and the risk that expected income is reduced or be exposed to issuer credit risk, interest eliminated (e.g., through dividend reductions or suspensions). Growth oriented investments can be more volatile and may not realize anticipated appreciation, and companies with higher growth expectations may experience outsized declines if those expectations are not met. Cost Averaging - In appropriate circumstances, a Client may choose to invest a fixed dollar amount cost averaging does not assure a profit or protect against loss. In particular, Dollar at regular intervals. Dollar ‑ dollar cost averaging strategies are ineffective and do not prevent loss in declining markets. ‑ ‑ term price fluctuations. Short Short Term Purchases – While Wescott typically focuses on long-term purchase strategies, in limited ‑ circumstances and where consistent with the Client’s objectives and risk tolerance, securities can be purchased with the expectation that they will be sold within a relatively short period (generally less than one year) to strive to take advantage of short term trading can involve heightened market timing risk and can increase transaction costs and taxable events. ‑ ‑ ‑ Margin Transactions - Use of margin involves borrowing against account assets and can amplify gains and losses. If account values decline, Clients can be required to deposit additional funds or securities, and the custodian or broker dealer can liquidate positions to meet margin requirements, potentially without advance notice. Margin and other forms of leverage can result in losses exceeding the amount invested. ‑ Tax Considerations Wescott’s investment strategies and recommended investments can have unique and significant tax implications. However, unless expressly agreed to otherwise in writing, tax efficiency is not the primary consideration in managing Client assets. Tax efficiency is evaluated as part of our manager due diligence process and in the selection of investment vehicles (e.g., mutual funds versus exchange traded funds) when constructing target portfolios in taxable accounts. ‑ 28  managed, direct ‑ ‑ indexing, separately managed account (“SMA”) solution for In addition, Wescott offers a tax efficient Clients whose investment objectives meet the program’s requirements and for whom an active tax ‑ strategy is deemed appropriate. In these cases, the active, tax-managed, direct-index separately managed account is managed by a sub-advisor selected by Wescott Financial Advisory Group. efficient cost basis accounting methodology (referred to by basis accounting methods must be made prior to ‑ ‑ For applicable accounts, Wescott defaults to a tax custodians using varying terminology). Elections regarding cost trade settlement, as such elections generally cannot be changed after settlement. ‑ ‑ ‑ Cash Management Wescott generally invests Client cash balances in Federal Deposit Insurance Corporation (“FDIC”) insured deposit accounts, money market funds, or certificates of deposit, using the cash investment vehicles made available by the Client’s custodian in accordance with the custodian’s parameters and limitations. Cash balances are managed with consideration given to prevailing yields and the financial soundness of money market funds and other term investment instruments. (Note: Money market funds are investment products and are not short insured, insured by any federal government agency, deposits, or obligations of the Adviser, and are not FDIC ‑ guaranteed. FDIC insurance applies only to qualifying deposit accounts and certificates of deposit held at participating institutions, subject to applicable limits.) Other cash management or money market options may be available outside of the custodian’s platform and may offer higher yields or different underlying investment characteristics, including potentially lower risk. However, such alternatives are generally not utilized due to custodial constraints or operational considerations. In most cases, Wescott maintains at least a portion of Client cash balances to facilitate the payment of advisory fees and/or anticipated Client cash distributions. Risks of Specific Securities Utilized Wescott generally seeks to implement investment strategies that do not involve significant or unusual risk beyond those inherent in the markets and investment types in which the firm advises. Recommendation of Particular Security Types Wescott recommends various types of securities and does not primarily favor any one type over another, as each Client has different needs and risk tolerances. Because each security type has its own unique set of associated risks, it is not possible to identify or describe every potential risk applicable to each type of investment. Even within the same investment category, risks may vary significantly. However, in very general terms, investments with higher anticipated returns typically involve a greater risk of loss. The following overview, which is illustrative and not intended to cover all possible investments or risks, discusses general categories of securities that may be held in Client accounts and outlines certain risks associated with those investment types: Bond Funds - Bond funds have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in risk and reward. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Exchange-Traded Funds (“ETFs”) - ETFs are typically investment companies classified as open-end mutual funds or UITs. However, they differ from traditional mutual funds, particularly when ETF shares are listed on a securities exchange. An ETF is designed to track the price of an index or a collection of underlying assets as closely as possible. Shares can be bought and sold throughout the day, like those of publicly traded companies, and may trade at a discount or premium to their NAV. This difference between the bid 29  and ask prices is often called the "spread." The spread varies over time based on the ETF's trading volume and market liquidity. It is generally lower when the ETF has high trading volume and market liquidity, and higher when it has low trading volume and market liquidity. Although many ETFs are registered as investment companies under the Investment Company Act of 1940, like traditional mutual funds, some ETFs (particularly those that invest in commodities such as gold and precious metals) are not registered as investment companies. ETFs may be closed and liquidated at the discretion of the issuing company. Leveraged ETFs, in particular, present distinct risks and are not appropriate for all investors. Leveraged ETFs should be used only by investors who understand the risks of seeking daily leveraged or inverse investment results, generally for short-term active trading within an actively monitored and managed investment program. Investors must be aware of the daily nature of leveraged and inverse investment strategies, the high expense ratios, and the lack of guarantee of long-term inverse returns, among other considerations, before participating in this type of investment. Limited Partnerships, Limited Liability Companies & Business Development Companies - Limited partnerships, limited liability companies, and business development companies represent different forms of ownership of investment assets. These entities are investment vehicles that may own full or partial interests in various operating businesses. The types of operating companies may include, but are not limited to, equipment leasing, oil and gas, alternative energy, and real estate. ‑ ‑ risk investments, their long ‑ ‑ Money Market Funds - A money market fund is technically a security. Fund managers seek to maintain a stable net asset value of $1.00 per share; however, this value is not guaranteed. An investor may lose some or all of the principal invested if the share price declines. The U.S. Securities and Exchange Commission notes that, while investor losses in money market funds have been rare, they are possible. In exchange for this risk, money market funds generally aim to provide a higher return than FDIC insured savings accounts; however, they are not FDIC insured. Money market fund yields are variable and may increase or decrease over time, and there is no assurance regarding future returns. In addition, because money market funds are generally considered lower term average returns have historically been lower than those of riskier investments, and inflation may erode purchasing power over extended periods. Mutual Funds - Mutual funds are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. Mutual funds can also be "closed-end" or "open- end." So-called “open-end” mutual funds allow new investors to invest indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. Some mutual funds are "no-load" and charge no fee to buy into or sell out of the fund; others charge such fees, which can also reduce returns. Mutual funds are sold in different share classes and may offer investors discounts on sales charges, as described in each fund's prospectus. Funds will have a manager who trades the fund's investments in line with the fund's investment objective. Mutual fund shares held in Client accounts may also be subject to 12b-1 fees, short-term redemption fees, and other fund annual expenses. No-load or load-waived mutual funds used in Client portfolios do not have initial or deferred sales charges; however, if a fund that imposes sales charges is selected, the Client may pay an initial or deferred sales charge. Non- advisory accounts typically have upfront or back-end charges. Each fund's prospectus fully describes these fees and costs. If Clients have mutual funds in their portfolio, they will pay their adviser, any third-party manager, custodian, and mutual fund manager to manage their assets, as well as any other fund expenses paid by the fund's shareholders. If Clients transfer particular share classes of mutual funds and liquidate those shares after the transfer, the shares may also incur contingent deferred sales charges (“CDSCs”) from the mutual fund company if they are within the CDSC holding period. While mutual funds generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates on a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. In short, all these costs of managing the funds can reduce the fund’s returns. 30  Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss, and that past performance is not indicative of future results. Over time, assets will fluctuate in value, sometimes being worth more and sometimes less than the initial investment amount. Depending on the investment type, differing risk levels will exist. Wescott cannot guarantee or promise that a Client's financial goals and objectives will be met. When evaluating risk, each Client may view financial loss differently and may depend on many distinct risks, each affecting the probability and magnitude of potential losses. The following additional risks, which are not all-inclusive, are provided for careful consideration by a prospective Client before retaining our services. Items are presented alphabetically for ease of reading, not in order of importance: Adviser's Investment Activities - An adviser’s investment activities can involve significant risk. The performance of any investment is subject to numerous factors beyond our control and beyond its predictive ability. As further detailed within this section, decisions made for Client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or deviate from expectations, adversely affecting a Client's ability to realize profits or resulting in material losses. Client and Adviser investment decisions will not always be profitable. Artificial Intelligence - We can leverage artificial intelligence ("AI") to enhance operational efficiency and improve Client services. Currently, however, AI is not used in our investment selection process or in formulating specific investment advice. Instead, our AI applications primarily automate administrative and Client service tasks, including meeting preparation, note-taking, CRM updates, task management, and the generation of meeting recap notes. We believe AI streamlines Client engagement, reduces administrative burdens, and ultimately enhances the overall Client experience. It is essential to recognize that AI models are inherently complex and that their outputs may be incomplete, inaccurate, or biased. While AI augments our operations, its use introduces risks, including inaccuracies, decision-making errors, and challenges in its effective deployment. Additionally, AI usage may pose risks to the confidentiality of the Client or proprietary information. These risks include the potential exposure of sensitive data to unauthorized parties, violations of data privacy, or other instances of data leakage. For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable data—entered into an AI application could inadvertently become part of a broader dataset accessible to other users or systems, compromising confidentiality. Moreover, the regulatory framework governing AI is evolving rapidly, and future developments may necessitate adjustments to our AI adoption strategy. The use of AI also carries the potential for regulatory and litigation risks. To mitigate these risks, we have implemented stringent data protection measures, including encryption, access controls, and regular security assessments, to safeguard both Client and proprietary information. We continuously evaluate the performance of AI technologies to ensure they are deployed in accordance with our fiduciary responsibilities and regulatory obligations. Additionally, our staff is trained to handle sensitive data with the utmost care, and we partner with trusted third-party vendors who adhere to best practices in data security and compliance. Business Risk - The risks associated with a specific industry or company. Conflicts of Interest - advisers face inherent conflicts when administering Client portfolios and when preparing financial reports. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures, as well as a Code of Ethics, ensuring that the Client's interests are always held above those of the firm and its associates. Credit Risk - Credit risk typically applies to debt investments, such as corporate, municipal, and sovereign fixed-income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the 31  value of an issuer's securities held by a Client. Currency/Exchange Risk - Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment's originating country. Diversification Risk - A portfolio may not be sufficiently diversified across sectors, industries, geographic areas, security types, or issuers. These portfolios might be subject to more rapid changes in value than would be the case if the investment vehicles were required to maintain broad diversification across companies or industry groups. Equity Investment Risk - Generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease in value; the investment may incur a loss. Financial Risk - The possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders in the event of insolvency. Financial risk also refers to the possibility that a corporation or government will default on its bonds, resulting in bondholders losing money. Foreign/Non-U.S. Investments - From time to time, advisers may invest and trade a portion of Client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, and enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may hold foreign currencies directly and purchase and sell them through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the US dollar's strength relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may miss the benefits of favorable exchange rate movements. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - Investments in financial instruments such as forward contracts, options, commodities, and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in those positions' values or prevent losses if they decline, but rather establishes other positions designed to gain from the same developments, thus moderating the portfolio positions' decline in value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions increases. Horizon & Longevity Risk - The risk that an investment horizon is shortened because of an unforeseen event, such as loss of a job. This may force an investor to sell investments they had expected to hold for the long term. An investor can lose money if they have to sell when markets are down. Longevity Risk is 32  the risk of outliving one’s savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes future dollars to be worth less and may reduce the purchasing power of a Client's future interest payments and principal. Inflation also generally leads to higher interest rates, which may cause the value of many fixed-income investments to decline. Leverage Risk - Leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements may require the pledging of additional collateral or the liquidation of account holdings, forcing the account to close positions at substantial losses not otherwise realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or using different leveraging strategies. Liquidity Risk - The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - Long-term trading is designed to capture returns and market rates of return. By its nature, the long-term investment strategy can expose Clients to risks that typically surface at multiple points over time as they hold the investments. These risks include, but are not limited to, inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Margin Risk - Securities purchased on margin in a Client's account serve as the firm's collateral for the Client's loan. If the account securities decline in value, so does the value of the collateral supporting the loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing advance written notice or the entitlement to an extension of time on the margin call. Market Risk - Market risk is the possibility that an investment's current market value will decline due to a general market decline, regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - Because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction it otherwise might have and may not be able to sell an investment it otherwise might have. Non-U.S.Investment Risk - Investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. 33  Political & Legislative Risk - Companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - An account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of comparable-sized investment entities. Private Investment Risk - Investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors over a short period could require a fund to liquidate its securities and other investments more rapidly than would otherwise be desirable, possibly reducing the value of its assets or disrupting its investment strategy. Private Placement Risks - A private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended period, making them difficult to sell. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - An adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data, or seek independent corroboration when appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Reinvestment Risk - The risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk – This risk occurs when investors lack the right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of a firm's key personnel, including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not be able to find equally desirable replacements, which could adversely affect the accounts' performance. Stock Fund Risk - Although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the greatest potential danger to investors in stock funds. Stock prices can fluctuate for various reasons, such as the overall strength of the economy and demand for products or services. Stock Market Risk - A stock's market value will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate in the short term due to factors affecting individual companies, industries, or the broader securities market. The past performance of investments is no guarantee of future results. Strategy Risk - An adviser's investment strategies and techniques may not work as intended. Supervision of Trading Operations Risk - An adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with the firm's and the Client's objectives. However, despite their efforts, there is a risk of unauthorized or 34  otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a Client and the securities used to implement the investment strategy, Clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks -These are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - For all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions, thereby exposing the Adviser to potential losses. Unsystematic Risks - These are risks specific to a particular investment. Also known as "diversifiable risks," diversifying investments may, in theory, significantly reduce unsystematic risks. Use of Independent Managers Risk - Wescott selects certain Independent Managers to manage a portion of its Clients' assets. In these situations, we continue to conduct ongoing due diligence on such managers, but such recommendations rely heavily on the Independent Managers' ability to implement their investment strategies successfully. In addition, we do not have the ability to supervise the Independent Managers on a daily basis. Withdrawal of Capital Risks - An Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals over a short period could require a fund to liquidate its securities and other investments more rapidly than would otherwise be desirable, reducing the value of its assets and disrupting its investment strategy. Wescott attempts to address the above risks by diversifying across multiple asset classes and strategies, creating distinct portfolio segments. Any security eligible for inclusion in a portfolio with low or no liquidity may be removed and replaced with the next-highest-ranked security in the same asset segment. Due to the fluctuating nature of security prices, the weighting of an individual security or sector in the portfolio may change after the portfolio is established. The Adviser does not represent or guarantee that the services provided or any analysis methods provided can predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of future Client account performance or any level of performance; the success of any investment decision or strategy used; overall account management; or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for Client accounts are subject to various market, currency, economic, political, and business risks (including those noted above) and will not always be profitable. The outcome(s) described, and any strategies or investments discussed, may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients are encouraged to contact their IAR with any questions regarding applicable risks, fees, or costs. Item 9: Disciplinary Information ___________________________________________________________________________________________ Legal or Disciplinary Event Disclosure Registered investment advisers such as Wescott must disclose all material facts regarding any legal or disciplinary events that would be material to a Client's or prospective Client's evaluation of the investment adviser or the integrity of its management. 35  Neither Wescott nor any of its management persons have any criminal or civil actions, administrative proceedings, or self-regulatory organization proceedings to report that are material to a Client's evaluation of our advisory business. Please visit the SEC’s website at www.adviserinfo.sec.gov to use a free, simple search tool to research our firm. The SEC's website also provides information and disclosure items about any affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. Copies of this information can also be obtained by contacting us directly. Item 10: Other Financial Industry Activities & Affiliations ___________________________________________________________________________________________ Wescott is an independent registered investment adviser that offers no other services than those described herein. We do not have any relationship or arrangement material to our advisory business or our Clients with respect to the following entities: • Broker-dealer, municipal securities dealer, government securities dealer, or broker. • An investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company, or "hedge fund," and offshore fund). Futures commission merchant, commodity pool operator, or commodity trading adviser. • Other investment adviser or financial planner. • • Banking or thrift institution. • Accountant or accounting firm. • Insurance company or agency. • Pension consultant. • Real estate broker or dealer. • Sponsor or syndicator of limited partnerships. Attorney or Law Firm Affiliations The law firm of Duane Morris LLP has an ownership interest in Wescott Financial Advisory Group. No Wescott Client is ever required to engage Duane Morris LLP for legal services, although a referral to Duane Morris LLP may be made for appropriate legal services, if requested. A conflict of interest exists as a result of this recommendation because of Duane Morris LLP's ownership interest in Wescott Financial Advisory Group. Wescott respects all Clients' legal advisor relationships and commonly works with their chosen legal counsel. Duane Morris LLP may refer Clients to Wescott for financial planning and investment management services if it believes such services are appropriate for its Clients' situation. Wescott and our affiliates are not restricted from forming investment funds, entering into other investment advisory relationships, or engaging in other business activities, even though such activities may involve substantial time and resources of the Firm and our affiliates. Potentially, such activities could be viewed as creating conflicts of interest, in that the time and effort of our management personnel and employees will not be devoted exclusively to our primary advisory practice, but would instead be allocated across a variety of business interests. Wescott Trust Services Wescott offers trust and fiduciary services through Wescott Trust Services, which provides professional fiduciary solutions for Clients whose financial, family, or business circumstances warrant the use of a corporate trustee or professional fiduciary. Under this program, Wescott Trust Services acts as a trust representative of National Advisors Trust Company (“NATC”), a federally chartered trust company regulated by the Office of the Comptroller of the Currency (“OCC”), a bureau of the U.S. Department of the Treasury, and authorized to conduct trust business in all fifty (50) states. 36  NATC serves as the trustee or fiduciary pursuant to the applicable trust or fiduciary agreement, and Wescott Trust Services does not itself act as trustee unless expressly provided for in a separate written agreement. Wescott Financial Advisory Group is a shareholder of National Advisors Trust Company, holding an ownership interest of less than 0.25%. This ownership interest presents a conflict of interest, as Wescott has a financial incentive to recommend NATC as a trustee or fiduciary service provider. Wescott addresses this conflict by disclosing its affiliation and ownership interests to Clients and by maintaining policies and procedures to ensure that all recommendations are made in the Client’s best interest and consistent with Wescott’s fiduciary obligations. ‑ Clients are under no obligation to engage NATC and may select any qualified trustee or trust company of their choosing. Wescott does not receive commissions, referral fees, or other transaction based compensation in connection with a Client’s decision to engage NATC, other than the indirect economic benefit associated with its de minimis ownership interest. The specific terms, billing practices, and termination provisions applicable to trust services are governed by the applicable Trust Services Agreement, which is separate from Wescott’s standard Wealth Management Program Advisory Agreement. (See Item 5: Fees & Compensation for additional information.) Other Business Relationships Wescott utilizes third-party resources to support its business operations and deliver services to Clients, primarily focusing on back-office functions. Wescott sources these professionals who act in a Client’s best interest with fiduciary responsibility while focusing on finding the highest-value-added providers to service Clients. While the Adviser has developed a network of professionals, including accountants, lawyers, and others, neither Wescott nor its Associates receive compensation for such use or referrals outside the items disclosed in this brochure. Conflicts of Interest Certain business activities or relationships of Wescott and its Associates may create conflicts of interest, including economic incentives that could influence recommendations of products, services, custodians, or other service providers. Wescott addresses these potential conflicts by requiring full and fair disclosure of all material conflicts and by requiring the Adviser and its Associates to strive to act in Clients' best interests. When an Associate engages in activities or offers products outside of Wescott, the nature of the relationship, role, and any compensation received must be disclosed in advance, and the Associate must clearly communicate that such activities are not conducted on behalf of the firm or under a Wescott Advisory Agreement. Clients are under no obligation to act on any recommendation, and all decisions regarding the acceptance of recommendations or engagement of services remain solely within the Client’s discretion. Additional information regarding Wescott’s conflict management practices is available in the firm’s Code of Ethics and compliance policies, which are provided upon request for review at no cost. ‑ ‑ Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ___________________________________________________________________________________________ Code of Ethics Wescott has adopted a Code of Ethics (the “Code”) pursuant to Rule 204A 1 under the Advisers Act, as amended. The Code establishes rigorous standards of ethical conduct and requires compliance with applicable federal securities laws. It reflects Wescott’s fiduciary duty of loyalty and care to its Clients, as well as the firm’s obligation to supervise the advisory activities of its Supervised Persons. The Code applies to all of Wescott’s Supervised Persons, including officers, directors, employees, IARs, and any other persons subject to the firm’s supervision and control, as well as any additional persons designated by the Chief Compliance Officer. 37  ‑ The Code reflects Wescott’s commitment to placing Clients’ interests first and conducting its advisory business with integrity, professionalism, and fairness. The Code restricts activities that may give rise to actual, potential, or perceived conflicts of interest and establishes reporting, review, and enforcement procedures. Among other matters, it governs personal securities transactions, including the review of initial, annual, and quarterly securities holdings and transaction reports submitted by Access Persons, as well as pre approval requirements for investments in initial public offerings and limited offerings, such as private placements. The Code also includes appropriate oversight, enforcement, and recordkeeping provisions. ‑ The Code also includes appropriate oversight, enforcement, and recordkeeping provisions, and expressly prohibits public information (“MNPI”). While Wescott does not believe it has routine access to the misuse of material non MNPI, all Supervised Persons are prohibited from using such information in either a personal or professional capacity. ‑ In addition, the Code addresses the confidentiality of Client information, gifts and entertainment, outside business activities, and pre clearance and reporting requirements applicable to Access Persons and operates in conjunction with Wescott’s written supervisory policies and procedures. The Code is designed to help ensure that Associates’ personal securities transactions, activities, and interests do not compromise their ability to act in the best interests of advisory Clients, while permitting them to invest for their own accounts in a manner consistent with the firm’s fiduciary obligations. The Code is distributed upon hire and at least annually thereafter, and Associates are required to acknowledge receipt of and comply with the Code. Violations must be reported to the Chief Compliance Officer and may result in disciplinary action, up to and including termination. Participation or Interest in Client Transactions Neither Wescott nor any person associated with the firm has any material financial interest in Client transactions beyond the provision of investment advisory services, except as otherwise disclosed in this brochure. Investments in Securities Recommended to Clients Wescott and individuals associated with the Firm may buy or sell securities for their personal accounts, whether or not the same as those recommended to Clients. These activities present actual or potential conflicts of interest. To address such conflicts and to satisfy the Firm’s fiduciary and regulatory obligations, Wescott has adopted and implemented policies and procedures under its Code of Ethics designed to promote fair and ethical conduct and provide full and fair disclosure of material conflicts. Concurrent Trading & Personal Securities Transactions Wescott or persons associated with the firm may recommend securities to Clients, or buy or sell securities for Client accounts, at or about the same time that Wescott or its related persons buy or sell the same securities for their own accounts. Such concurrent trading activity presents potential conflicts of interest, including the possibility that personal transactions could be executed at more favorable prices or otherwise influence investment recommendations. ‑ ‑ ‑ Wescott addresses these potential conflicts through the policies and procedures set forth in its Code of Ethics, including restrictions on trading based on non related information, prohibitions on trading public or employment ahead of Client transactions, pre clearance and reporting requirements for certain personal securities transactions, and ongoing review by the Chief Compliance Officer or a designated reviewer. Wescott seeks to ensure that all personal trading activities are conducted in a manner consistent with the firm’s fiduciary obligations and do not disadvantage Clients. Among other things, these policies provide that: 38  • • No principal or Associate may place their personal interests ahead of the interests of any advisory Client, including by trading based on information obtained through their employment, unless such information is also publicly available, or by engaging in personal securities transactions before the execution of transactions for Client accounts. Investments by related persons in initial public offerings (“IPOs”) or limited offerings, including private placements, are subject to prior approval. • The firm maintains records of reportable securities holdings and transactions for Access Persons, which are reviewed periodically by the Chief Compliance Officer or a designated reviewer. • All principals and Associates are required to comply with applicable federal and state securities laws governing registered investment advisers. These controls operate in conjunction with Wescott’s Code of Ethics and related supervisory policies and procedures, which are designed to ensure that personal securities activities do not compromise the firm’s fiduciary obligations to Clients. A copy of Wescott’s Code of Ethics is available to Clients and prospective Clients for review upon request at no cost by emailing Carrie Delgott, Chief Compliance Officer, at cdelgott@wescott.com, or by calling T: 215.979.1600. Item 12: Brokerage Practices ___________________________________________________________________________________________ Preferred Custodians Wescott recommends that Clients participating in its Wealth Management Program utilize National Financial Services LLC, Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity"), Schwab Advisor Services, a division of Charles Schwab & Co. Inc. ("Schwab"), or National Advisors Trust Company ("NAT") – each a FINRA registered custodian and member of SIPC - to maintain custody of Client's assets and to execute transactions for their accounts. Wescott Financial Advisory Group is independently owned and operated and not affiliated with Schwab or Fidelity. Wescott owns a de minimis ownership interest (less than 0.25%) in National Advisors Trust Company. As a result, a conflict of interest arises when Wescott recommends NAT’s custodial services because of this ownership interest. ‑ ‑ Dealers; Reasonableness of Compensation Factors Used to Select and Recommend Custodians & Broker Wescott seeks to recommend custodians and broker dealers to hold Client assets and execute transactions on terms most advantageous to Clients, taking into account the range and quality of services provided. Although the firm has designated certain preferred custodians, it retains the ability to effect transactions through other dealers when consistent with its duty to seek best execution and the applicable Client Agreement. broker ‑ Wescott regularly reviews and evaluates its custodial and brokerage relationships to assess the reasonableness of compensation arrangements and the overall quality of services provided, regardless of which firm maintains custody of Client assets. The specific factors considered in this evaluation vary based on the circumstances and may include, among others, the following: • The combination of transaction execution services along with asset custody services, generally offered without a separate fee for custody. • The capability to execute, clear, and settle trades - buy and sell securities for a Client’s account. • The ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc. • Competitive trading commission costs. • Reporting tools, including cost basis and 1099 reports, to facilitate tax management strategies. 39  • Personal money management tools such as electronic fund transfer, dividend reinvestment, and electronic communication delivery. Financial stability to ensure individual accounts, including primary and backup account insurance. • • The breadth of investment products made available. • The availability of investment research and tools that assist us in making investment decisions. • Customer service levels and service quality. • The competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them. • The provider's reputation, financial strength, and stability. • The custodian’s prior service to our Clients and us. • The availability of other products and services that benefit us. ‑ faith determination that commissions, In selecting and recommending a custodian, Wescott makes a good markups, markdowns, and other transaction costs are reasonable in relation to the value of the brokerage, custodial, and research services provided. This analysis was conducted as part of our due diligence. based charges, including commissions where applicable, mark ups or mark ‑ ‑ ‑ Generally, custodians do not charge separate custody fees. Instead, they are compensated through transaction downs on certain fixed income transactions, interest earned on uninvested Client cash balances, and other compensation permitted under applicable laws and regulations. ‑ Custodial Support Services In addition to brokerage execution and custody, custodians offer products and services that support an adviser’s investment management, operational, and business activities. The availability and terms of these services may change at the custodian’s discretion. The categories of custodial support services typically include the following: ‑ Services That Benefit Clients Custodial services include the safekeeping of Client assets; the execution, clearance, and settlement of securities transactions; and access to a broad range of institutional investment products, including mutual funds, exchange traded funds (“ETFs”), alternative investment vehicles, and other securities that may not otherwise be available or may require higher minimum investments through other custodial platforms. Custodial services also support account administration, transaction processing, portfolio implementation, asset movement, and reporting for Client accounts. Services That Do Not Always Directly Benefit Clients Custodians also make available products and services that assist advisers in managing and administering Client accounts, but do not directly benefit individual Client accounts. These services may include, among others:  Investment research, including both proprietary research produced by the custodian and research provided by third party vendors. ‑  Software and technology that facilitate trade execution, aggregation, and allocation across multiple Client accounts, access to Client account data (including trade confirmations and account statements), pricing and other market data, and portfolio performance measurement and analysis. office operational support.  Systems that facilitate the calculation and payment of advisory fees from Client accounts.  Recordkeeping, Client reporting, and other back ‑ Wescott may use this research, technology, and support services to service all or a substantial portion of Client accounts, including accounts not maintained at the particular custodian. These services are not provided in connection with any specific Client transaction. 40  Services That Primarily Benefit the Adviser Custodians may also offer services intended to support an adviser’s overall business operations rather than individual Client accounts. These services may include, without limitation: party service providers, including employee benefits providers, human capital  Educational conferences, seminars, and training events.  Technology solutions unrelated to specific Client accounts.  Compliance, legal, regulatory, and business consulting.  Practice management resources and publications.  Business succession planning resources.  Access to third consultants, and insurance providers. ‑ ‑ Custodians may provide some of these services directly or arrange for third party vendors to deliver them. In certain cases, custodians may discount or waive fees for these services or subsidize all or a portion of party costs. Custodians may also provide occasional business entertainment to advisory personnel. third ‑ Research & Other Soft Dollar Benefits Custodians make available certain research, technology, and administrative support tools that assist Wescott in managing Client accounts and operating its advisory business. These services are provided in connection with the maintenance of Client accounts at custodians. They are not contingent upon Wescott committing to any specific level of Client assets or trading activity. ‑ The research, products, and services made available to us can include, among others: access to Client account data (such as trade confirmations and account statements), software and technology that facilitate trade execution, aggregation, and allocation of transactions across multiple Client accounts, investment research, party vendors, pricing and including proprietary research produced by custodians and research provided by third other market data, systems that facilitate the calculation and payment of advisory fees from Client accounts, and office operational support. recordkeeping, reporting, and other back ‑ ‑ ‑ ‑ Custodians may also make available certain products and services that do not directly benefit individual Client accounts, such as compliance, legal, regulatory, and business consulting, publications, conferences, and training related to practice management or business succession, access to third party service providers (including employee benefits providers, human capital consultants, and insurance providers), and occasional educational events or business entertainment. These services may be provided directly by custodians or through third party vendors, and in some cases, custodians may discount, waive, or subsidize all or a portion of the associated costs. The availability of this research, technology, and support services benefits Wescott by reducing costs the firm would otherwise incur to operate its business. As a result, Wescott has an incentive to recommend custodians that offer such benefits, creating a conflict of interest. Wescott nevertheless believes that its recommendations are in the Clients’ best interests, based on the overall scope, quality, reliability, and cost effectiveness of the custodians’ brokerage, custodial, and support services, rather than solely on the additional benefits provided to Wescott. Wescott does not receive compensation, direct or indirect, “hard” or “soft,” from custodians for Client referrals. cash benefits, such as conference registration waivers, However, custodians may provide certain non participation by custodial personnel at Client events, or training opportunities. ‑ Research, technology, and other support services made available through custodial platforms may be used to service some or all Client accounts, including accounts not maintained at a particular custodian, and are not provided in connection with any specific Client transaction. In addition, Wescott’s access to certain institutional services is generally available so long as specified asset thresholds are maintained at a custodian’s institutional platform, as disclosed by the custodian. These thresholds may create an additional conflict of interest by incentivizing Wescott to recommend the custodian that imposes them. 41  Best Execution Wescott acts in accordance with its fiduciary duty to seek best execution for Client transactions. As part of its brokerage oversight, Wescott conducts initial and ongoing due diligence of its brokerage arrangements, including considerations related to execution quality, brokerage practices, potential conflicts of interest, and directed brokerage, and seeks to ensure consistency with each Client’s written Advisory Agreement and, where applicable, the Client’s investment policy statement. Wescott also believes that the institutional commission rates and service capabilities of its recommended custodians are favorable and operationally efficient for Clients and for effective account supervision. In seeking best execution, the determinative factor is not necessarily the lowest possible transaction cost, but whether a transaction represents the most favorable execution under the circumstances. In making this determination, Wescott considers a range of qualitative and quantitative factors, including execution capability, dealer or custodian, responsiveness and service quality, commission financial strength and stability of the broker rates and other transaction costs, and the value of research and other brokerage services provided. ‑ ‑ Accordingly, while Wescott seeks to obtain competitive commission rates, it may not always obtain the lowest available commission or transaction cost for Client transactions. In certain circumstances, a Client may pay a commission or other transaction charge that is higher than that charged by another broker dealer for effecting the same transaction when Wescott determines, in good faith, that such costs are reasonable in relation to the value of the brokerage and research services received. dealers or third parties when selecting or recommending Brokerage for Client Referrals Wescott does not consider Client referrals from broker broker dealers and does not direct Client transactions in return for such referrals. ‑ ‑ ‑ Directed Brokerage Wescott’s custodial arrangements are designed to promote operational efficiency, economies of scale, effective supervision, and cost-effectiveness. In connection with its advisory services, Wescott generally directs brokerage and custodial services to its selected custodians. Clients may, however, direct us to use a particular broker dealer, qualified custodian, or financial institution for custodial or transaction services for their accounts, subject to the Adviser’s ability to reasonably accommodate such requests in a manner consistent with its fiduciary duties and operational requirements. By electing to direct brokerage, Clients acknowledge that the efficiencies, economies of scale, and operational effectiveness associated with Wescott’s primary custodial arrangement may be reduced or unavailable when alternative brokers or custodians are used. The use of alternative brokerage or custodial service providers may result in execution delays, limitations on transaction aggregation, and other operational constraints that could adversely affect account management. ‑ Any Client electing to direct brokerage must do so in writing and is solely responsible for negotiating commissions, transaction charges, and other terms with the selected broker dealer or custodian. In such cases, Wescott is not responsible for negotiating execution terms on the Client’s behalf, seeking more favorable execution through alternative brokers, or aggregating transactions with those of other Clients. Directed brokerage arrangements may result in higher transaction costs, less favorable execution, wider spreads, execution delays, or other adverse effects on account management. Accordingly, Clients must understand that directing brokerage may increase the costs associated with managing their accounts. Consistent with its fiduciary duty and obligation to seek best execution, Wescott reserves the right, in its discretion, to decline a Client’s request to direct brokerage where such arrangements would result in material operational difficulties or otherwise impair Wescott’s ability to manage the account effectively. 42  Aggregation of Client Transactions Wescott combines multiple orders for shares of the same securities for discretionary advisory accounts it manages (“aggregated trading”) and allocates executions among participating accounts in a manner intended to be fair and equitable. In certain cases, participating accounts pay an average price per share for all transactions and a proportionate share of transaction costs on a given day; if an order is partially filled, allocations are generally made fairly and equitably, typically in proportion to each Client’s order size. Accounts owned by Wescott or persons associated with Wescott may participate in aggregated trading alongside Client accounts; however, they are not given priority over Client accounts. discretionary accounts. As a result, non ‑ ‑ discretionary accounts may Wescott does not aggregate trades for non incur different costs than discretionary accounts and may pay higher commissions, fees, and/or transaction costs than Clients who enter into discretionary arrangements. Mutual Fund Share Classes Mutual funds are sold in different share classes with different cost structures. When Wescott purchases or recommends mutual funds, it seeks to select the share class it deems in the Client’s best interest, taking into account cost, tax implications, and other factors, and reviews mutual funds held in accounts under management to evaluate whether a more beneficial share class is available. Trade Errors Even with the best efforts and controls, trade errors can happen. A trade error can include, among other things, the purchase or sale of an incorrect security, the purchase or sale of an incorrect amount of a security, or the failure to purchase or sell an intended security. ‑ Wescott maintains internal controls designed to prevent trade errors and to identify and address them promptly, including efforts to detect errors before settlement and correct or mitigate them as expeditiously as possible. If a trade error results in a breach of applicable regulatory requirements, contractual terms, investment objectives, imposed restrictions, our policy is to restore the affected account to the position it would have been in or Client had the error not occurred. Corrective actions may include canceling or adjusting a trade, rebalancing an allocation, and/or reimbursing the account, as appropriate, with the objective of making the Client whole. Clients are generally reimbursed for losses resulting from a Wescott trade error. To the extent a trade error is caused by a third-party, such as a broker or counterparty, Wescott will seek to recover any associated losses from that party. Wescott maintains records of all trade errors in its books and records, including details regarding the nature of the error and the manner in which it was resolved. These procedures are designed to ensure fair and equitable treatment of Clients and compliance with applicable regulatory requirements. Item 13: Review of Accounts ___________________________________________________________________________________________ Client Account Evaluation & Oversight Wescott has a fiduciary duty to provide investment advice and services that are appropriate to each Client’s individual circumstances and consistent with the applicable written advisory services agreement. The Chief Compliance Officer, or their Designee, is responsible for overseeing the firm’s Compliance Program supervisory framework, including monitoring Advisor Representative account review obligations and overseeing Client account review activity. All initial Client Advisory Agreements are reviewed and approved by the CCO or another designated firm principal before implementation. 43  From time to time, supervisory responsibilities may be reassigned due to personnel or organizational changes. Any such reassignment does not alter Wescott’s supervisory standards, review processes, or overall oversight responsibilities. Review Frequency The frequency and scope of reviews vary by advisory service and the applicable service Agreement. to ‑ ‑ Client accounts and holdings are monitored by designated principals and advisory Staff, as reflected below, and by Adviser Representatives (“IARs”) in the ordinary course of their day day responsibilities. Reviews occur quarterly, annually, and periodically as needed. Client accounts and holdings are monitored using portfolio management systems, reporting tools, and exception reporting. Account reviews associated are included as part of Wescott’s advisory services and are provided at no additional cost to Clients. The account review practices applicable to each advisory service are described below: Wealth Management Program Services Wealth Management Program Services, Entrada® Management Program, MRK Powered by Wescott Wealth Management Program (“PARTNERS Program”), Family Office Solution Services, and other programs involving ongoing portfolio management. ‑ internal oversight from Because a Client’s goals, objectives, and financial circumstances may change over time, Wealth Management Program services’ portfolio accounts are subject to ongoing oversight to help ensure that investment advice upon strategy. The Client’s assigned IAR will monitor remains appropriate and aligned with each Client’s agreed accounts and holdings in the ordinary course of their day day responsibilities, using portfolio management to ‑ systems, automated alerts, exception reporting, and supervisory controls, supplemented by periodic ‑ communications with Clients and investment, accounting, and administrative perspectives. At a minimum, and as outlined in each Client’s executed Advisory Agreement, IARs conduct a comprehensive review of managed portfolios at least annually to assess the continued appropriateness of the investment strategy and its alignment with the Client’s objectives and risk tolerance. flow or tax planning considerations, market, economic, political, regulatory, or security ‑ ‑ ‑ Portfolio reviews may occur more frequently as circumstances warrant. They may be prompted by Client requests, material changes in a Client’s objectives or individual and financial circumstances, significant contributions or withdrawals, cash specific developments, or account activity identified through the firm’s supervisory or exception monitoring processes. Wescott may also determine that additional reviews are appropriate based on the facts and circumstances. ‑ Changes may be recommended as a result of Client requests or needs, manager changes, liquidity needs, model allocation changes, rebalancing, or tax considerations. Reviews serve to safeguard that each Client's portfolio is invested in a manner consistent with the Client's written Investment Policy Statement. Further reviews are conducted by designated supervisory and advisory personnel, including: Grant Rawdin (Founder & CEO), Susan Green (Partner, Director of Financial Planning Standards & Senior Financial Advisor), David Lafferty (Partner & Senior Financial Advisor/Peer Reviewer), Scott Michalek (Partner & Senior Financial Advisor), Stephanie James (Partner, Managing Director of Advisor Services and Senior Financial Advisor), Sean Roberts (Principal and Portfolio Manager/Peer Reviewer), and Daniel Esquirell (Principal & Senior Financial Advisor). 44  Party Management Referral Services & Independent Third Party Management Services Selection of Other Advisors Services Third ‑ ‑ ‑ Clients who elect to participate in our selection of other advisors' services will have their accounts reviewed in accordance with the third party Manager’s internal review procedures, as described in each referred Manager's investment management agreement (“IMA”) and related disclosure documents. These reviews are intended to ensure that portfolio activity and allocations remain consistent with the Client’s objectives and risk parameters. Wescott’s role under the program includes ongoing monitoring of accounts managed by the independent Managers to assess whether strategies and target allocations remain generally consistent with client objectives and overall best interests. This monitoring by the Client’s IAR and designated supervisory and advisory personnel does not include day to day management or monitoring of individual securities or account activity. ‑ ‑ Retirement Plan & Pension Consulting Services While the underlying securities in retirement plan and pension consulting services accounts are continually monitored, Wescott reviews the plan's investment options at least quarterly, subject to the same review cadence and evaluative considerations as the Wealth Management Program services accounts, as described above. Additional reviews may also be conducted by Mark McCarron (Partner & Chief Investment Officer). Financial Planning & Consulting Services Financial Planning & Consulting Services, MRK Powered by Wescott Initial Wealth Management Plan Services (“MRK PBW”) Financial planning and consulting services reviews and plan updates occur at intervals that reflect each Client’s evolving needs and circumstances. The Chief Compliance Officer or a Designated will typically review financial planning and consulting deliverables upon completion prior to delivery to confirm consistency with the Client’s stated objectives and the agreed upon scope of services. ‑ Clients are encouraged to notify Wescott of any material changes to their personal or financial circumstances that may affect the relevance of an existing financial plan. Such changes may include, but are not limited to, marriage, divorce, birth, death, inheritance, litigation, retirement, job loss, or disability. More frequent reviews may be recommended as Clients approach significant life transitions, such as a job change or retirement. Wescott generally recommends that Clients receiving these services meet with their IAR at least annually to determine whether updates are warranted. Additional reviews may be conducted at the Client’s request or as otherwise agreed. Written plan updates may be provided in connection with a review and, if applicable, are subject to Wescott’s then current hourly rate, with any additional fees requiring the Client’s prior approval. ‑ Clients participating solely in hourly financial planning or consulting services do not receive ongoing account reviews unless otherwise agreed in writing. ‑ Asset Allocation Services Where Wescott provides non discretionary asset allocation services, review frequency depends on the agreed scope and whether ongoing review services are included in the engagement. Clients retain discretion over implementation decisions unless separately agreed. Wescott Trust Services Trustee services accounts receiving ongoing investment advisory services are reviewed consistent with the applicable investment management review framework described above and the governing trust/advisory agreements. Trustee services and related trust arrangements are further described in the applicable program documentation. 45  Services Not Typically Involving Ongoing Account Reviews Education Seminars & Workshop Services, Legacy SUNSET & PIMA Programs (where services are limited to legacy contractual terms) Educational seminars and workshop services are intended for educational purposes and do not involve ongoing account reviews unless otherwise agreed in writing. Legacy programs are reviewed and supported as provided under the applicable legacy agreements. Client Communications & Reporting At account inception, Clients receiving portfolio management services or other ongoing advisory services generally direct their qualified custodian to provide account statements at least quarterly, reflecting all account activity during the applicable reporting period. (See Item 15: Custody for additional information.) In addition to statements provided by a Client’s custodian, Wescott provides the following reports to Clients, as applicable: Portfolio Management Services Clients receiving portfolio management services under Wescott’s Wealth Management Program, Entrada® Management Program, MRK Powered by Wescott Wealth Management Program (“PARTNERS Program”), and Family Office Solution Services receive quarterly written reports, as appropriate, based on the advisory service selected and the account established. These reports summarize account performance, balances, and holdings, and remind Clients to notify their IAR of any changes in financial circumstances or investment objectives, as well as whether they wish to impose or modify investment restrictions. ‑ Pension & Retirement Plan Consulting Services Clients receiving retirement plan and pension consulting services generally receive reports directly from the plan’s custodian or third party administrator (“TPA”), as contracted for by the plan sponsor. In addition, Wescott provides the plan sponsor or administrator with an annual report covering overall manager performance, general market commentary and outlook, and information regarding any recommended changes to asset allocation models. ‑ ‑ ‑ Selection of Other Advisors Services party management referral services or Clients participating in the selection of other advisors' services (third party management services) will generally receive account statements and reports directly independent third from the third party Manager and/or the Manager’s selected custodian, as described in the applicable investment management agreement (“IMA”) and related disclosures. Clients should refer to the TPM’s agreement and disclosure documents for specific reporting practices. ‑ Financial Planning & Consulting Services Reporting Clients receiving financial planning and consulting services, including MRK Powered by Wescott Initial Wealth Management Plan services, receive written reports, deliverables, or plan updates summarizing Wescott’s analysis, recommendations, and conclusions, as requested or recommended and as agreed in writing. These materials may address long term cash flow, investments, estate and tax planning issues, insurance, retirement, and charitable giving. Clients receiving hourly financial planning or consulting services do not receive ongoing account reports unless otherwise agreed in writing. Services Not Subject to Ongoing Account Reporting Educational seminars and workshop services do not include ongoing account reporting. Legacy SUNSET and PIMA Programs are supported in accordance with the terms of applicable legacy agreements and generally do not include ongoing reporting beyond what is provided by the account custodian or otherwise agreed in writing. 46  ‑ Clients are encouraged to promptly review all custodial statements, confirmations, and reports upon receipt and to compare the documents with any supplemental reports provided by Wescott. Clients should evaluate account performance against appropriate benchmarks, where applicable, and promptly notify their IAR and the custodian of any questions, discrepancies, or concerns. Differences between custodial statements and Wescott provided reports may occur due to timing, valuation, or reporting methodology differences and do not necessarily indicate an error. Clients should contact their IAR with any questions regarding the custody, safety, or security of their assets, or regarding any statement, confirmation, or report received. If a Client identifies, or believes there may be, an inaccuracy or discrepancy, they should promptly notify both the custodian and Wescott— and in all cases before the next statement cycle—so the matter may be reviewed and addressed as appropriate. A written notice should follow any verbal communications. Item 14: Client Referrals & Other Compensation ___________________________________________________________________________________________ Client Referrals Wescott receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends, and other similar sources. The Adviser does not compensate for these referrals except as otherwise disclosed herein. Preferred Qualified Custodian Economic Benefits Wescott receives an economic benefit from its recommended Qualified Custodians in the form of support products and services, which are provided as part of its arrangement to recommend that clients maintain accounts with these custodians. These benefits can include access to support products and services that help us manage Client accounts and operate our business. Such benefits offset costs that the Adviser would otherwise be required to bear directly. While Clients do not incur additional costs for assets held at a recommended custodian, they should be aware of potential conflicts of interest, as it provides Wescott with an incentive to recommend custodians that offer these products and services. In selecting a custodian, Clients should consider the products and services provided by each custodian, the benefits those services provide to Wescott, and the related conflicts of interest. (See Item 12: Brokerage Practices for disclosures on research and other benefits we may receive from our relationship with your account Custodian.) Related Benefits ‑ Mutual Fund & Investment Product Certain custodians, mutual fund companies, fund sponsors, or fund distributors may provide Wescott Associates and investment professionals with access to educational programs, marketing materials, product information, due diligence resources, or occasional attendance at conferences or similar events. In addition, certain mutual funds may pay distribution or servicing fees (such as Rule 12b 1 fees), as disclosed in the applicable fund prospectuses. These fees are typically paid from fund assets or by fund affiliates and do not appear as separate charges on Client ‑ account statements. ‑ Neither the firm nor its IARs receive higher compensation for recommending one mutual fund or investment product over another, and individual compensation does not vary based on the specific funds or products recommended. Nevertheless, the availability of fund sponsored educational or marketing benefits creates a conflict of interest, as it could influence Wescott or its personnel to favor investment products associated with such benefits. No portion of these payments is derived from brokerage commissions generated by Client transactions. 47  Referral Relationships Fidelity Wealth Advisor Solutions® Wescott participates in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), pursuant to which Strategic Advisers, LLC (“Strategic Advisers”) refers prospective Clients to our firm. Strategic Advisers is a registered investment adviser and an affiliate of Fidelity Investments. Wescott is independent and not affiliated with Strategic Advisers or any Fidelity Investments company. Strategic Advisers does not supervise, manage, or control Wescott’s advisory activities and has no responsibility for, or oversight of, Wescott’s provision of investment management or other advisory services to Clients. Under the WAS Program, Strategic Advisers acts as a Promoter for Wescott. In exchange for client referrals, Wescott pays referral fees directly to Strategic Advisers based on assets under management attributable to Clients referred through the WAS Program and their household members. Clients do not pay these referral fees. Specifically, Wescott pays Strategic Advisers: • An annual fee equal to 0.10% of assets identified by Strategic Advisers as fixed income assets. • An annual fee equal to 0.25% of all other assets held in the referred Client accounts. In addition, Wescott pays Strategic Advisers a $50,000 annual program participation fee to participate in the WAS Program. The WAS Program is designed to help investors identify independent investment advisers. Any referral made by Strategic Advisers does not constitute a recommendation or endorsement of Wescott’s advisory services, investment strategies, or personnel. To receive referrals under the WAS Program, Wescott must satisfy certain eligibility and participation criteria. Wescott’s selection for participation may also be influenced by its broader business relationships with Strategic Advisers and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its participation in the WAS Program, Wescott has a potential conflict of interest, as we may have an incentive to recommend that Clients use affiliates of Strategic Advisers, including FBS, for brokerage execution, custody, and clearing services. This incentive may exist regardless of whether a Client was referred through the WAS Program. To address this conflict, Wescott has agreed not to charge Clients advisory fees outside the standard fee ranges disclosed in this brochure to offset solicitation fees paid to Strategic Advisers, and the Adviser remains subject to its fiduciary duty to recommend custodians and broker dealers based on best execution, cost, and the Client’s best interests. ‑ Pursuant to its agreement with Strategic Advisers, Wescott has agreed not to solicit referred Clients to transfer brokerage accounts away from affiliates of Strategic Advisers or to establish accounts with alternative custodians, except where Wescott’s fiduciary obligations would require otherwise. ‑ If a referred Client elects to transfer assets from affiliates of Strategic Advisers to another custodian, Wescott is required to pay Strategic Advisers a one time fee equal to 0.75% of the transferred assets. As a result, Wescott may have an incentive to suggest that referred Clients and their household members maintain custody of their accounts with affiliates of Strategic Advisers. Participation in the WAS Program does not limit Wescott’s obligation to act in the clients’ best interests or to select custodians and broker dealers consistent with its duty to seek best execution. ‑ ‑ Referrals to Other Service Professionals From time to time, and upon request or when appropriate based on a Client’s needs, Wescott may refer Clients to unaffiliated third party service providers, such as attorneys or accountants. Such professionals may also refer individuals seeking investment advisory services to Wescott independently. No compensation is paid or received by either party in connection with these mutual referrals. 48  ‑ Party Managers Selection of Other Investment Advisers & Third party managers (“Managers or “TPMs”) or other independent Wescott may recommend unaffiliated third ‑ investment advisers in connection with its selection of other advisors services. Clients who elect to engage a TPM will enter into a separate investment management agreement directly with the referred party, which governs the terms of that relationship. Clients should review the applicable referred Manager’s agreements and disclosure documents for information regarding services, compensation, and potential conflicts of interest. ‑ Wescott does not receive referral fees, solicitation compensation, or other remuneration from unaffiliated third party managers solely for referring Clients to their services, except as otherwise disclosed in this brochure. Where applicable, Wescott may receive compensation from Clients under its own advisory agreement for ongoing advisory services, including manager selection, monitoring, and oversight. Clients enter into separate advisory agreements with both Wescott and the TPM; Wescott’s compensation is not paid solely for referrals. Wescott Professional Alliance Wescott created the Wescott Professional Alliance program, a referral program connecting licensed CPAs and legal professionals for revenue sharing and collaboration, to secure Client referrals to our advisory firm. The adviser receives an economic benefit from any referral made through this program. Conflicts of Interest Wescott does not receive any additional economic benefits from Client referrals or advisory services, and does not accept, or allow, our related persons to accept any form of compensation, including cash, sales awards, or other prizes, from a non-Client in conjunction with the advisory services we provide to our Clients except as disclosed herein. ‑ related arrangements, the To mitigate potential conflicts of interest associated with economic benefits or referral Adviser has adopted comprehensive compliance policies and procedures, including a written Code of Ethics, to which the firm and all Associates are required to adhere. These policies are designed to ensure that referrals and compensation arrangements are handled transparently and in accordance with applicable regulatory standards. Wescott is committed to making referrals and investment recommendations based solely on the appropriateness of the services or products for each Client’s individual needs, objectives, and circumstances, and not on any financial incentives received by the firm or its personnel. A copy of our Code of Ethics is available to Clients and prospective Clients for review upon request at no cost. Item 15: Custody ___________________________________________________________________________________________ Custody of Client Assets Wescott does not maintain physical custody of Client funds or securities. Client assets are held by independent, unaffiliated qualified custodians pursuant to each Client’s Advisory Agreement and a separate custodial or brokerage agreement between the Client and their custodian. All checks, funds, wire transfers, and securities move directly between the Client and the custodian. Authority to Deduct Advisory Fees (Limited Custody) Wescott’s authority with respect to Client assets is limited to deducting advisory fees directly from Client custodial accounts, provided the Client has authorized such fee deduction in writing. Wescott is not otherwise authorized to withdraw, transfer, or take possession of Client funds, securities, or other property. Clients authorize fee deduction directly with their qualified custodian, typically using the custodian’s required form or written instructions. The custodian debits the Client’s account and provides the Client with notice of each fee deduction. 49  ‑ Wescott’s authority to deduct fees constitutes limited custody under Rule 206(4) 2 of the Advisers Act. Wescott complies with the custody requirements applicable to advisers with limited custody by maintaining Client assets with qualified custodians and ensuring that Clients receive account statements directly from the custodian at least quarterly. Custodial statements reflect all account activity, including holdings, balances, transactions, and advisory fees deducted. Clients are encouraged to review custodial statements promptly upon receipt and to contact Wescott if they have questions or do not receive a statement from their custodian. Writing Authority, and Standing Letters of Authorization (“SLOAs”) party wire transfers, check ‑ ‑ Wire Transfers, Check Certain advisory services may permit third writing authority, or standing letters of ‑ authorization (“SLOAs”), but only where expressly authorized by the Client in writing and permitted under the applicable Advisory Agreement or selected advisory services program documents. Where authorized, Wescott or persons associated with the firm may facilitate wire transfers from a Client’s account to one or more third parties designated in writing by the Client without obtaining separate written writing authority for Client accounts. Such written consent for each transaction or may have signatory or check authorization constitutes an SLOA. ‑ ‑ An adviser with authority to conduct third party wire transfers or sign checks on a Client’s behalf is deemed to have custody of Client assets in the affected accounts. However, Wescott is not required to undergo a surprise annual audit provided that it complies with the conditions outlined in applicable SEC guidance, including that: 1. The Client provides a written, signed instruction to the qualified custodian identifying the third-party by name, address, and/or account number. 2. The Client authorizes their adviser in writing to direct transfers to the designated third-party on a specified schedule or from time to time. 3. The qualified custodian verifies the Client’s authorization (including signature review) and promptly provides a funds transfer notice to the Client after each transfer. ‑ 4. The Client retains the ability to terminate or modify the instruction at any time. 5. The adviser has no authority or ability to designate or change the identity, address, or other information of the designated third-party. 6. The adviser maintains records demonstrating that the designated third-party is not a related person of the advisera nd does not share the same address with the firm. 7. The qualified custodian provides the Client with an initial notice confirming the standing instruction and an annual notice reconfirming the instruction. Where Wescott facilitates SLOAs or similar arrangements, Wescott seeks to structure such authority in accordance with applicable SEC guidance and to maintain required documentation and safeguards so that such authority, when properly implemented, does not, by itself, trigger the surprise examination requirement. Clients who participate in our selection of other advisors' services and referral program(s) will follow the custody party and SLOA procedures of the independent referred Manager(s). Clients should review all applicable third agreements and disclosures for details regarding the TPM’s custody practices and authorization requirements. ‑ Item 16: Investment Discretion ___________________________________________________________________________________________ Account Management Style Wescott’s investment advisory services are offered to Clients on a discretionary and non-discretionary advisory basis. Details of the relationship are disclosed fully before any advisory relationship commences, and additional information for the account is provided. 50  The management style is reflected in each Client's executed Advisory Agreement. Discretionary Authority Under discretionary management authority, Wescott executes securities transactions for Clients without obtaining prior consent for each transaction. Discretionary authority includes the ability to determine the securities to buy or sell, the amount of each transaction, and the timing of such transactions. Clients grant discretionary authority through written authorization, which provides Wescott with discretion to manage investments, reinvestments, and related transactions for the account in accordance with the applicable advisory program, advisory agreement, related program documents, and information provided to the Client’s Investment Adviser Representative (collectively, the Client’s “Investment Guidelines”), as amended from time to time by mutual agreement. Imposed Investment Restrictions.”) Discretionary authority is limited to assets within a Client’s managed accounts. Clients may impose investment restrictions or otherwise limit discretionary authority by providing written instructions, and may amend such restrictions by submitting updated written instructions. (See “Client ‑ ‑ Clients generally grant Wescott a limited power of attorney as part of the account opening documentation submitted to their custodian. Except for positions specifically identified by the Client, such as securities the Client has requested to retain, Wescott is not required to obtain advance consent for individual trades. Under this management structure, the Client’s Investment Adviser Representative provides ongoing investment management services and exercises discretionary authority in a manner consistent with the Client’s stated investment objectives. The advisory agreement remains in effect, notwithstanding a Client’s incompetence or disability, until terminated by written notice. discretionary authority, Clients retain decision ‑ ‑ ‑ Non-Discretionary Authority discretionary basis, subject to a Wescott may, in its discretion, agree to provide advisory services on a non making control separate agreement with the Client. Under non ‑ over their accounts and must initiate or pre approve all investment transactions before they are executed. While the Client’s IAR may recommend securities or investment strategies based on the Client’s objectives and circumstances, no transaction will be placed without the Client’s consent. ‑ ‑ Because Client approval is required for each transaction, delays in execution may occur if Wescott is unable to obtain Client consent promptly. As a result, orders for non discretionary accounts may be placed after orders for discretionary accounts and executed at less favorable prices, particularly for securities other than mutual funds, which generally transact at the same daily net asset value. In addition, non discretionary accounts are not included in aggregated trades and therefore do not benefit from shared execution costs or average pricing, which can result in higher transaction costs, less favorable execution, or performance differences compared to discretionary accounts. ‑ ‑ Where Wescott is responsible for arranging or effecting transactions in a non discretionary account, and the Client accepts the Adviser’s recommendations, the IAR will provide ongoing advisory services consistent with the applicable Advisory Agreement. For non discretionary accounts in which Wescott does not arrange or effect transactions, advisory services are provided periodically as agreed, rather than on a continuous management basis. ‑ Non discretionary authority remains in effect, notwithstanding a Client’s incompetence or disability, until terminated by written notice. Clients and Wescott will execute all required documentation to establish appropriate trading authorization with the custodian. 51  Discretionary Authority Across Advisory Services ‑ ‑ Discretionary & Non The scope of Wescott’s investment discretion and trading authority varies by advisory service and is governed by the applicable Advisory Agreement and related documentation. In certain programs, including selection of other advisors' services and certain others, investment discretion and trading authority may reside with a third party manager, trustee, plan fiduciary, or the Client, rather than with Wescott. In such cases, Clients will enter into separate agreements governing those relationships, and Wescott will not exercise trading authority except as expressly agreed in writing. Clients should refer to the applicable agreements and disclosures for details regarding discretion, execution, reporting, and oversight responsibilities. Item 17: Voting Client Securities ___________________________________________________________________________________________ Proxy Voting Where authorized by Clients, Wescott votes proxies on their behalf. Wescott relies on recommendations provided by Broadridge, an independent firm specializing in shareholder voting analysis and corporate governance, which publishes widely recognized governance policies and voting recommendations on specific matters. Wescott generally follows Broadridge’s recommendations when they are consistent with sound corporate governance principles and are intended to maximize shareholder value. Any potential conflicts of interest are mitigated by reliance on Broadridge’s independent recommendations. ‑ When Wescott is authorized to vote proxies, Clients may not direct Wescott’s vote on individual proxy voting authority at any time. Clients may request solicitations; however, Clients may revoke Wescott’s proxy information regarding proxies voted on their behalf by contacting Carrie Delgott, Chief Compliance Officer at T: 215 979 1600 or via email at cdelgott@wescott.com. ‑ ‑ Clients who do not authorize Wescott to vote proxies will receive proxy materials directly from the applicable security issuer, qualified custodian, transfer agent, insurance company, annuity issuer (or their designated custodian), or other third party service provider, as applicable. In such cases, Clients are solely responsible for exercising their proxy voting rights. ‑ ‑ covered accounts, proxy voting authority generally resides with the plan fiduciary, as provided in the covered accounts unless voting authority for ERISA ‑ ‑ For ERISA governing plan documents. Wescott does not accept proxy expressly authorized in writing by the plan fiduciary. ‑ ‑ ‑ party money managers or managed account party manager’s investment management agreement and Form ADV, ‑ party manager to vote proxies on their behalf. party manager’s agreements and disclosures for information regarding ‑ From time to time, Wescott may recommend unaffiliated third platforms. Where permitted under the third Clients participating in such programs may authorize the third Clients should review the applicable third proxy voting policies, procedures, and responsibilities. ‑ ‑ Clients are advised that while IARs may respond to Client questions regarding proxy materials, doing so does not confer or imply proxy voting decisions unless voting authority. Clients remain responsible for making all proxy proxy authority has been expressly granted to Wescott in writing. ‑ ‑ Class Action Suits, Claims, Bankruptcies, Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisers to Clients. 52  Wescott has no duty or obligation to evaluate a Client's eligibility, advise, or submit claims to participate in the proceeds of securities class action settlements or other related legal actions, to determine if securities held by the Client are subject to a pending or resolved class-action lawsuit, or to act for the Client in any manner concerning legal proceedings involving securities currently or previously held by the Client's account or securities issuers. Wescott does not provide legal or tax advice, engage in any activity that might be deemed to constitute the practice of law or accountancy, or act for the Client in any manner concerning legal proceedings involving securities held or previously held by the Client's account or the issuers of such securities. Wescott is not obligated to forward copies of written or electronic notices of any legal actions, proceedings, or materials affecting such securities. It is the Client's responsibility to respond to any legal actions or proceedings involving the securities purchased or held in their account and/or initiate litigation to recover damages if they may have been injured as a result of the actions, misconduct, or negligence by the corporate management of issuers of such securities. Item 18: Financial Information ___________________________________________________________________________________________ Balance Sheet Requirement Wescott does not require nor solicit prepayment of more than $1,200 in fees per Client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair the Adviser’s Ability to Meet Contractual Commitments Wescott does not have any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to Clients. Neither Wescott nor its management persons have been the subject of any arbitration award or found liable in a civil, self regulatory organization, or administrative proceeding involving allegations of fraud, false statements or omissions, theft, embezzlement, or other dishonest, unfair, or unethical practices. ‑ Bankruptcy Disclosure Neither Wescott nor any of its management persons has been the subject of a bankruptcy petition in the past ten years. Item 19: Requirement for State Registered Advisers ___________________________________________________________________________________________ Wescott’s registration with the United States Securities and Exchange Commission became effective on June 11, 1987. As an SEC-registered firm, we are not required to respond to this item. 53