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Item 1 Cover Page
WHealthy Empowerment Network
20780 W. Chartwell Drive
Kildeer, IL 60047
www.WHealthyEmpowerment.com
www.WHealthyEmpowermentNetwork.com
April 14, 2026
This brochure provides information about the qualifications and business practices of
WHealthy Empowerment Network. If you have any questions about the contents of this
brochure, please contact us at (419) 340-6462. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any
state securities authority. Registration as a registered investment advisor does not imply a
certain level of skill or training.
Additional information about WHealthy Empowerment Network also is available on the
SEC’s website at www.adviserinfo.sec.gov.
Item 2 Material Changes
Since the last filing of this brochure on January 27, 2026, the following changes have occurred:
• The entire brochure for SEC Registration.
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Item 3 Table of Contents
Brochure
Item 1 Cover Page ................................................................................................................................. i
Item 2 Material Changes ...................................................................................................................... ii
Item 3 Table of Contents ..................................................................................................................... iii
Item 4 Advisory Business .................................................................................................................... 4
Item 5 Fees and Compensation ............................................................................................................ 5
Item 6 Performance-Based Fees and Side-by-Side Management ........................................................ 8
Item 7 Types of Clients ........................................................................................................................ 8
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 8
Item 9 Disciplinary Information ......................................................................................................... 11
Item 10 Other Financial Industry Activities and Affiliations ............................................................. 11
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........ 11
Item 12 Brokerage Practices .............................................................................................................. 12
Item 13 Review of Accounts .............................................................................................................. 17
Item 14 Client Referrals and Other Compensation ............................................................................ 17
Item 15 Custody ................................................................................................................................. 18
Item 16 Investment Discretion ........................................................................................................... 18
Item 17 Voting Client Securities ........................................................................................................ 18
Item 18 Financial Information ........................................................................................................... 19
Item 1 Cover Page for Brochure Supplement .................................................................................... 20
Item 2 Educational Background and Business Experience ................................................................ 21
Item 3 Disciplinary Information ......................................................................................................... 22
Item 4 Other Business Activities ........................................................................................................ 22
Item 5 Additional Compensation ....................................................................................................... 22
Item 6 Supervision ............................................................................................................................. 22
Item 1 Cover Page for Brochure Supplement .................................................................................... 24
Item 2 Educational Background and Business Experience ................................................................ 25
Item 3 Disciplinary Information ......................................................................................................... 26
Item 4 Other Business Activities ........................................................................................................ 26
Item 5 Additional Compensation ....................................................................................................... 26
Item 6 Supervision ............................................................................................................................. 26
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Item 4 Advisory Business
WHealthy Empowerment Network is an investment advisor firm registered in the states of Illinois,
Wisconsin, Ohio and Arizona, since March 2025.
The principal owners of WHealthy Empowerment Network are Erin Zylka, CFP®, AIF®,
Managing Partner, and Elizabeth Schneider, CFP®, Managing Partner. Ms. Zylka does business
for WHealthy Empowerment Network through a “doing business as” (dba) name, Kona Financial
Planning. Ms. Schneider does business for WHealthy Empowerment Network through dba name
Infinity Wealth Company, LLC.
Advisory Services
WHealthy Empowerment Network’s (or “Advisor”) principal service is providing fee-based
investment management and comprehensive financial planning services. The Advisor practices
custom management of portfolios, on a discretionary basis, according to the client’s objectives.
The Advisor’s primary approach is to use a tactical allocation strategy aimed at reducing risk and
increasing performance. The Advisor may use any of the following to accomplish this objective:
exchange listed securities, over-the-counter securities, foreign securities, warrants, corporate debt
securities, commercial paper, CDs, , municipal securities, mutual funds, United States government
securities, and options in securities. The Advisor measures and selects mutual funds by using
various criteria, such as the fund manager’s tenure, and/or overall career performance. The
Advisor may recommend, on occasion, redistributing investment allocations to diversify the
portfolio in an effort to reduce risk and increase performance. The Advisor may recommend
specific stocks to increase sector weighting and/or dividend potential. The Advisor may
recommend employing cash positions as a possible hedge against market movement which may
adversely affect the portfolio. The Advisor may recommend selling positions for reasons that
include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure
to a specific security or class of securities, overvaluation or overweighting of the position(s) in the
portfolio, change in risk tolerance of client, or any risk deemed unacceptable for the client’s risk
tolerance.
While the Advisor will provide ongoing supervision and management of existing legacy positions
in certain securities products (e.g., existing variable life insurance, variable annuities, and limited
partnerships investing in real estate and oil and gas interests). However, the Advisor will not
recommend new investments in such products and will not accept commissions or other charges
on the sale of those products. Investment advisor representatives are not insurance licensed and
will not recommend investments in any specific insurance product.
The Advisor will analyze each client’s unique investment profile to determine whether
concentration limits should apply to asset allocations. Facts and circumstances differ for each
client and concentration limits may not be applicable to the managed account. Some securities
issuers require investors to meet a certain threshold on annual income or net worth (for example,
“accredited investors” and “qualified clients”). WHealthy Empowerment Network will only
recommend investments where the investment is suitable, and the client meets the issuer’s
applicable investor requirements.
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When deemed appropriate for the Client, WHealthy Empowerment Network may hire Sub-
Advisors to manage all or a portion of the assets in the Client account. WHealthy Empowerment
Network has full discretion to hire and fire Sub-Advisor as we deem suitable. Sub-Advisor will
maintain the models or investment strategies agreed upon between Sub-Advisor and WHealthy
Empowerment Network. Sub-Advisor will execute trades on behalf of WHealthy Empowerment
Network in Client accounts. WHealthy Empowerment Network will be responsible for the overall
direct relationship with the Client. WHealthy Empowerment Network retains the authority to
terminate the Sub-Advisor relationship at WHealthy Empowerment Network’s discretion.
Financial Planning and Consulting
In addition to investment management services where comprehensive financial planning is
inclusive in the advisory fee, WHealthy Empowerment Network may provide separate financial
planning and consulting services to some of its clients. The Advisor’s financial planning and
consulting services may include recommendations for portfolio customization based on the client’s
investment objectives, goals and financial situation, recommendations relating to investment
strategies as well as tailored investment advice. Financial planning and consulting may also
include non-investment advice such as developing strategies to achieve retirement or other
financial goals,
tax optimization strategies, cash flow and budgeting analysis and
recommendations, financing and financial education, estate planning, and asset protection
strategies. Not all clients will receive a written financial plan or report. For example, the scope
of services may limit the Advisor to providing only in-person consultations in order to keep fees
lower for the client. Alternatively, the client may request a written report for consulting services,
or a written financial plan for financial planning services. The Advisor’s scope of services, as
agreed in writing with the client in the Financial Planning Agreement, will determine how the
client is provided with discussion and analysis of their financial planning and consulting needs.
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WHealthy Empowerment Network will tailor its advisory services to its client’s individual needs
based on meetings and conversations with the client. If clients wish to impose restrictions on
investing in certain securities or types of securities, the Advisor will address those restrictions with
the client to have a clear understanding of the client’s requirements.
WHealthy Empowerment Network does not provide portfolio management services to wrap fee
programs.
As of December 31, 2025, WHealthy Empowerment Network had $107,770,717 of client assets
under management on a discretionary basis.
Item 5 Fees and Compensation
Investment Management Fees
Pursuant to an investment advisory contract signed by each client, the client will pay WHealthy
Empowerment Network an annual management fee, payable quarterly in advance. New account
fees will be prorated from the inception of the account to the end of the first quarter.
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The structure and level of our advisory fee will vary by client based upon the services provided
and other considerations deemed relevant by WHealthy Empowerment Network and the
Investment Advisor Representative managing the client relationship, but will typically take the
form of a percentage of assets under management ranging from 0.5% to 1.5% per annum. For
example, a client with a family member requiring long-term care may need consistent income
generation from their investments; conversely, a client with no children and high income may not
need access to funds for 20+ years and could withstand 5+ years of their investment principal being
locked up in an alternative investment. Even if both clients have the same amount of assets under
management at the firm, WHealthy Empowerment Network’s investment recommendations will
vary substantially. Furthermore, while conservative investments in U.S. Government bonds tend
to require less oversight, investments in alternative assets require deep research and due diligence
prior to directing capital towards the investment. Thus, the time and complexity required to advise
these two different clients is a consideration deemed relevant by WHealthy Empowerment
Network's when determining the management fee that will be agreed in the investment advisory
contract.
The specific manner in which WHealthy Empowerment Network’s fees are charged is established
in the investment advisory contract. For certain clients, fees will be calculated based on the value
of portfolio assets of the account managed by the Advisor as of the close of business on the last
business day of the preceding quarter, multiplied by a breakpoint tiered schedule of fees. For other
clients, fees will be calculated at the beginning of each calendar year and clients will be charged
on a fixed fee basis (payable quarterly). For example, a $200,000 account billed on a fixed fee
basis at a rate of 0.9% would be calculated as follows: ($200,000 x 0.9%) / 4 quarters = $450 per
quarter. The Advisor’s fee rate may be adjusted if there is a decline in the value of the client’s
account, and will be discussed and agreed with the client in advance.
These fees are negotiable. Investment management fees will be directly deducted from the client
account on a quarterly basis by the qualified custodian. The client will give written authorization
permitting the Advisor to be paid directly from their account held by the custodian. The custodian
will send a statement at least quarterly to the client.
WHealthy Empowerment Network may also utilize the services of a Sub-Advisor to manage
Clients’ investment portfolios by executing a Sub-Advisor agreement with another registered
investment advisor. When using a Sub-Advisor, the Client will not pay additional fees. The Sub-
Advisor fees are inclusive of the total fee disclosed by WHealthy Empowerment Network.
Clients will receive comprehensive financial planning services as a complement to the advisory
fee paid for investment management.
Financial Planning and Consulting Fees
WHealthy Empowerment Network will charge a fixed fee for financial planning and consulting
services in the range of $3,000 to $5,000 as negotiated and contracted for with the client. Financial
planning and consulting fees are based on the estimated number of hours it will take to complete
the financial plan or report, as well as the type and complexity of the services. In addition to a
higher fixed fee being based on the added complexity of advanced services, a higher fixed fee will
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be based on the additional time expected to complete the services. Complexity of services is
considered regardless of the level of client assets being managed by the Advisor, if any.
Where the complexity, time, and effort required to provide the services will, at the discretion of
the Advisor, exceed $5,000 in fees, the Advisor will discuss this with the client in advance and
agree to a higher fee range. For example, a small business owner client requesting consulting
services that include valuation of the business and planning and preparation for the sale of the
business will incur additional fees and costs associated with the valuation services, charged by a
third-party valuation firm, and the Advisor will, as liaison with the third-party valuation firm,
spend additional time managing the relationship and analyzing the valuation results, as well as
rendering advice on the various aspects and consequences of the business sale. Furthermore, the
Advisor, as liaison between the client and the client’s third-party accountant/CPA firm, would
develop a financial plan based on the planned proceeds of the sale and with tax consequences in
mind. These services are generally beyond the scope of services for most clients, and would
increase the complexity and time required (and therefore the fees) by the Advisor to provide such
services.
Financial planning and consulting services may be provided on a one-time basis or an annual
recurring basis. One-time fixed fee-based clients are billed in advance at the time of signing the
agreement with the Advisor. Annual recurring fixed fee-based clients are billed quarterly, in
advance. If the client terminates the Agreement with the Advisor prior to the Advisor's completion
of the financial planning services, the Advisor will refund to the client a pro-rata share of the fee
the client paid. The Advisor will refund the pro-rata fee to the client within five days of delivery
of the financial plan.
For each of the Advisor's services described above, the Client may terminate these services within
five business days of the effective date of an Agreement signed with the Advisor without any
payment of the Advisor's fee.
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All fees paid to WHealthy Empowerment Network for investment advisory services are separate
and distinct from the expenses charged by mutual funds to their shareholders and the product
sponsor in the case of variable insurance products. These fees and expenses are described in each
fund’s or variable product’s prospectus. These fees will generally include a management fee and
other fund expenses. Client is responsible for all expenses related to the ordinary servicing of the
account, including custodial and securities transaction fees charged by the custodian and executing
broker-dealer, and/or platform fees. Other non-ordinary fees or fees incurred at the direction of
the Client shall be paid by the Client. The Advisor’s fee is separate and distinct from the custodian
and execution fees.
A client may be able to invest in products recommended by the firm directly, without the services
of WHealthy Empowerment Network, and these services may be available through other firms not
affiliated with WHealthy Empowerment Network. In that case, the client would not receive the
services provided by WHealthy Empowerment Network, which are designed, among other things,
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to assist the client in determining which products or services are most appropriate to each client’s
financial condition and objectives.
At no time will WHealthy Empowerment Network accept or maintain custody of a client’s funds
or securities except for authorized fee deduction.
WHealthy Empowerment Network’s fees are payable in advance. Upon termination, any fees paid
in advance will be prorated to the date of termination and any unearned fees will be refunded to
client.
Neither WHealthy Empowerment Network nor its supervised persons accept compensation for the
sale of securities or other investment products, including asset-based sales charges or service fees
from the sale of mutual funds.
Item 6 Performance-Based Fees and Side-by-Side Management
WHealthy Empowerment Network does not charge performance-based fees.
Item 7 Types of Clients
The Advisor will offer its services to individuals, trusts, estates, charitable organizations, and
corporations or other business entities.
The Advisor does not have any minimum requirements for opening or maintaining an account.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
The Advisor may utilize fundamental, technical, or cyclical analysis techniques in formulating
investment advice or managing assets for clients.
Fundamental analysis of a business involves analyzing its financial statements and health, its
management and competitive advantages, and its competitors and markets. Fundamental analysis
is performed on historical and present data but with the goal of making financial forecasts. There
are several possible objectives: to conduct a company stock valuation and predict its probable price
evolution; to make a projection on its business performance; to evaluate its management and make
internal business decisions; and to calculate its credit risk.
Technical analysis is a method of evaluating securities by relying on the assumption that market
data, such as charts of price, volume and open interest can help predict future (usually short-term)
market trends. Technical analysis assumes that market psychology influences trading in a way
that enables predicting when a stock will rise or fall.
Cyclical analysis of economic cycles is used to determine how these cycles affect the returns of an
investment, an asset class or an individual company’s profits. Cyclical risks exist because the
broad economy has been shown to move in cycles, from periods of peak performance followed by
a downturn, then a trough of low activity. Between the peak and trough of a business or other
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economic cycle, investments may fall in value to reflect the uncertainty surrounding future returns
as compared with the recent past.
The methods of analysis and investment strategies followed by the Advisor are utilized across all
of the Advisors clients, as applicable. One method of analysis or investment strategy is not more
significant than the other as the Advisor is considering the client’s portfolio, risk tolerance, time
horizon and individual goals. However, the client should be aware that with any trading that occurs
in the client account, the client will incur transaction and administrative costs.
Investing includes the risk that the value of an investment can be negatively affected by factors
specifically related to the investment (e.g., capability of management, competition, new inventions
by other companies, lawsuits against the company, labor issues, patent expiration, etc.), or to
factors related to investing and the markets in general (e.g., the economy, wars, civil unrest or
terrorism around the world, concern about oil prices or unemployment, etc.).
Risks of fundamental analysis may include risks that market actions, natural disasters, government
actions, world political events or other events not directly related to the price or valuation of a
specific company’s fundamental analysis can adversely impact the stock price of a company
causing a portfolio containing that security to lose value. Risks may also include that the historical
data and projections on which the fundamental analysis is performed may not continue to be
relevant to the operations of a company going forward, or that management changes or the business
direction of management of the company may not permit the company to continue to produce
metrics that are consistent with the prior company data utilized in the fundamental analysis, which
may negatively affect the Advisor’s estimate of the valuation of the company.
The primary risks in technical analysis are that the factors used to analyze the price, trends and
volatility of a security may not be replicated, or the outcomes of such analysis will not be the same
as in past periods where similar combinations existed. Because of the reliance on trends, technical
analysis can signal buying at market peaks and selling at market troughs.
In cyclical analysis, economic or business cycles may not be predictable and may have many
fluctuations between long-term expansions and contractions. Also, the lengths of the economic
cycles may be difficult to predict with accuracy. Therefore, the risk of cyclical analysis is the
difficulty in predicting economic trends and consequently the changing value of securities that
would be affected by these changing trends.
All investments involve some degree of risk. In finance, risk refers to the degree of uncertainty
and/or potential financial loss inherent in an investment decision. In general, as investment risks
rise, investors seek higher returns to compensate themselves for taking such risks. Clients need to
be aware that investing in securities involves risk of loss that clients need to be prepared to bear.
Every saving and investment product has different risks and returns. Differences include how
readily investors can get their money when they need it, how fast their money will grow, and how
safe their money will be. The primary risks faced by investors include:
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Business Risk
With a stock, you are purchasing a piece of ownership in a company. With a bond, you are loaning
money to a company. Returns from both of these investments require that the company stays in
business. If a company goes bankrupt and its assets are liquidated, common stockholders are the
last in line to share in the proceeds. If there are assets, the company’s bondholders will be paid
first, then holders of preferred stock. If you are a common stockholder, you get whatever is left,
which may be nothing.
Volatility Risk
Even when companies aren’t in danger of failing, their stock price may fluctuate up or
down. Large company stocks as a group, for example, have lost money on average about one out
of every three years. A stock’s price can be affected by factors inside the company, such as a
faulty product, or by events the company has no control over, such as political or market events.
Inflation Risk
Inflation is a general upward movement of prices. Inflation reduces purchasing power, which is a
risk for investors receiving a fixed rate of interest. The principal concern for individuals investing
in cash equivalents is that inflation will erode returns.
Interest Rate Risk
Interest rate changes can affect a bond’s value. If bonds are held to maturity the investor will
receive the face value, plus interest. If sold before maturity, the bond may be worth more or less
than the face value. Rising interest rates will make newly issued bonds more appealing to investors
because the newer bonds will have a higher rate of interest than older ones. To sell an older bond
with a lower interest rate, you might have to sell it at a discount.
Liquidity Risk
This refers to the risk that investors won’t find a market for their securities, potentially preventing
them from buying or selling when they want. This can be the case with the more complicated
investment products. It may also be the case with products that charge a penalty for early
withdrawal or liquidation such as a certificate of deposit (CD).
The Advisor does not primarily recommend a particular type of security. However, clients are
advised that many unexpected broad environmental factors can negatively impact the value of
portfolio securities causing the loss of some or all of the investment, including changes in interest
rates, political events, natural disasters, and acts of war or terrorism. Further, factors relevant to
specific securities may have negative effects on their value, such as competition or government
regulation. Also, the factors for which the company was selected for inclusion in a client portfolio
may change, for example, due to changes in management, new product introductions, or lawsuits.
The risks associated with utilizing Sub-Advisors include:
• Manager Risk
o Sub-Advisor fails to execute the stated investment strategy
• Business Risk
o Sub-Advisor has financial or regulatory problems
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• The specific risks associated with the portfolios of the Sub-Advisor’s which is disclosed in
the Sub-Advisor’s Form ADV Part 2.
Item 9 Disciplinary Information
Neither WHealthy Empowerment Network nor its management persons have had any legal or
disciplinary events, currently or in the past.
Item 10 Other Financial Industry Activities and Affiliations
Neither WHealthy Empowerment Network nor any of its management persons are registered, or
have an application pending to register, as a broker-dealer or a registered representative of a
broker-dealer.
Neither WHealthy Empowerment Network nor any of its management persons are registered or
have an application pending to register, as a futures commission merchant, commodity pool
operator, a commodity trading advisor, or an associated person of the foregoing entities.
WHealthy Empowerment Network may also utilize the services of a Sub-Advisor to manage
Clients’ investment portfolios. Sub-Advisor will maintain the models or investment strategies
agreed upon between Sub-Advisor and WHealthy Empowerment Network. Sub-Advisor executes
all trades on behalf of WHealthy Empowerment Network in Client accounts. WHealthy
Empowerment Network will be responsible for the overall direct relationship with the Client.
WHealthy Empowerment Network retains the authority to terminate the Sub-Advisor relationship
at WHealthy Empowerment Network’s discretion.
The Sub-Advisor recognizes that WHealthy Empowerment Network has full discretion over
clients’ models, portfolios, and accounts and that the Sub-Advisor operates in a limited, sub-
advisory capacity. The Sub-Advisor will not outsource trading, operations, or any services to
additional traders or sub-advisors.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
WHealthy Empowerment Network is registered as a state registered investment advisor and has
adopted as an industry best practice a Code of Ethics that sets forth the basic policies of ethical
conduct for all managers, officers, and employees of the Advisor. In addition, the Code of Ethics
governs personal trading by each employee of WHealthy Empowerment Network deemed to be
an Access Person and is intended to ensure that securities transactions effected by Access Persons
of WHealthy Empowerment Network are conducted in a manner that avoids any conflict of interest
between such persons and clients of the Advisor or its affiliates. WHealthy Empowerment
Network collects and maintains records of securities holdings and securities transactions effected
by Access Persons. These records are reviewed to identify and resolve conflicts of interest.
WHealthy Empowerment Network will provide a copy of the Code of Ethics to any client or
prospective client upon request.
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WHealthy Empowerment Network does not recommend to clients, or buy or sell for client
accounts, securities in which the firm or a related person has a material financial interest.
WHealthy Empowerment Network and/or its investment advisor representatives may from time to
time purchase or sell products that they may recommend to clients. This practice creates conflicts
of interest in that personnel of WHealthy Empowerment Network can take advantage of the
advance knowledge of firm securities trading and trade their personal accounts ahead of the client
trades or recommend trades in client accounts that may affect the price of the securities owned by
the investment advisor representatives. To mitigate these conflicts, WHealthy Empowerment
Network has adopted a Code of Ethics as noted above. WHealthy Empowerment Network’s Code
of Ethics is available upon request. Finally, supervised persons of registered investment advisors
are fiduciaries by law and are required to put the client’s interest before those of the firm and
themselves.
WHealthy Empowerment Network requires that its investment advisor representatives follow its
basic policies and ethical standards as set forth in its Code of Ethics.
Investment advisor representatives of WHealthy Empowerment Network may trade for their own
accounts securities that are being traded for client accounts at or about the same time. To mitigate
the conflict of interest in such circumstances, WHealthy Empowerment Network’s policy is to
require the trading of all relevant client accounts prior to the trading of their own accounts. The
Chief Compliance Officer examines personal trading activities of WHealthy Empowerment
Network’s personnel to verify compliance with this policy.
Item 12 Brokerage Practices
If requested by the client, WHealthy Empowerment Network may suggest brokers or dealers to be
used based on execution and custodial services offered, cost, quality of service and industry
reputation. WHealthy Empowerment Network will consider factors such as commission price,
speed and quality of execution, client management tools, and convenience of access for both the
Advisor and client in making its suggestion. WHealthy Empowerment Network intends to
recommend that our clients use Charles Schwab & Co., Inc., a registered broker-dealer, member
SIPC, as the qualified custodian.
The custodian and brokers we use
WHealthy Empowerment Network does not maintain custody of your assets, although we are
deemed to have custody of your assets if you give us authority to withdraw assets from your
account (see Item 15 – Custody, below). Your assets must be maintained in an account at a
“qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use
Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified
custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab
will hold your assets in a brokerage account and buy and sell securities when we instruct them to.
While we recommend that you use Schwab as custodian/broker, you will decide whether to do so
and will open your account with Schwab by entering into an account agreement directly with them.
We do not open the account for you, although we may assist you in doing so. Not all advisors
require their clients to use a particular broker-dealer or other custodian selected by the advisor.
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Even though your account is maintained at Schwab, we can still use other brokers to execute trades
for your account as described below (see “Your brokerage and custody costs”).
How we select brokers/custodians
We seek to recommend a custodian/broker that will hold your assets and execute transactions
on terms that are overall most advantageous when compared with other available providers and
their services. We consider a wide range of factors, including:
• Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers,
check requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-
traded funds (ETFs), etc.)
• Availability of investment research and tools that assist us in making investment
decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, security and stability
• Prior service to us and our clients
• Availability of other products and services that benefit us, as discussed below (see
“Products and services available to us from Schwab”)
Your brokerage and custody costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately
for custody services but is compensated by charging you commissions or other fees on trades that
it executes or that settle into your Schwab account. Certain trades (for example, many mutual
funds, ETFs, and online stock and options trades) may not incur Schwab commissions or
transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your
account in Schwab’s Cash Features Program. For some accounts, Schwab may charge you a
percentage of the dollar amount of assets in the account in lieu of commissions. In addition to
commissions and asset-based fees, Schwab charges you a flat dollar amount as a “prime broker”
or “trade away” fee for each trade that we have executed by a different broker-dealer but where
the securities bought or the funds from the securities sold are deposited (settled) into your Schwab
account. These fees are in addition to the commissions or other compensation you pay the
executing broker/dealer. Because of this, in order to minimize your trading costs, we have Schwab
execute most trades for your account. We have determined that having Schwab execute most trades
is consistent with our duty to seek “best execution” of your trades. Best execution means the most
favorable terms for a transaction based on all relevant factors, including those listed above (see
“How we select brokers/custodians”).
Products and services available to us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms
like us. They provide our clients and us with access to their institutional brokerage services
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(trading, custody, reporting and related services), many of which are not typically available to
Schwab retail customers. Schwab also makes available various support services. Some of those
services help us manage or administer our clients’ accounts, while others help us manage and grow
our business. Schwab’s support services are generally available on an unsolicited basis (we
don’t have to request them) and at no charge to us. Following is a more detailed description of
Schwab’s support services:
Services that benefit you
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access or that would require
a significantly higher minimum initial investment by our clients. Schwab’s services described in
this paragraph generally benefit you and your account.
Services that may not directly benefit you
Schwab also makes available to us other products and services that benefit us but may not directly
benefit you or your account. These products and services assist us in managing and administering
our clients’ accounts. They include investment research, both Schwab’s own and that of third
parties. We may use this research to service all or a substantial number of our clients’ accounts,
including accounts not maintained at Schwab. In addition to investment research, Schwab also
makes available software and other technology
that:
• provide access to client account data (such as duplicate trade confirmations and account
•
statements)
facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
facilitate payment of our fees from our clients’ accounts
• provide pricing and other market data
•
• assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance
providers
• Marketing consulting and support
Schwab may provide some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab may also discount or waive its fees for some of these
services or pay all or a part of a third party’s fees.
WHealthy Empowerment Network
Page 14
Our interest in Schwab’s services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services. These services are not contingent
upon us committing any specific amount of business to Schwab in trading commissions or assets
in custody. This creates an incentive to recommend that you maintain your account with Schwab,
based on our interest in receiving Schwab’s services that benefit our business and Schwab’s
payment for services for which we would otherwise have to pay rather than based on your interest
in receiving the best value in custody services and the most favorable execution of your
transactions. This is a potential conflict of interest. We believe, however, that our selection of
Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily
supported by the scope, quality, and price of Schwab’s services (see “How we select
brokers/custodians”) and not Schwab’s services that benefit only us.
WHealthy Empowerment Network may receive proprietary research services or other products as
a result of recommending Schwab, which may result in the client paying higher commissions than
those obtainable through other brokers. If WHealthy Empowerment Network does receive such
products or services, it will follow procedures which ensure compliance with Section 28(e) of the
Securities Exchange Act of 1934 or applicable state securities rules.
The firm seeks to obtain the most favorable net results for clients’ price, execution quality, services
and commissions. Although the firm seeks competitive commission rates, it may pay commissions
on behalf of clients which may be higher than those available from other brokers in order to receive
other services. The firm may enter into such transactions so long as it determines in good faith
that the amount of commission paid was reasonable in relation to the value of the brokerage and
research services provided by the broker. The services that may be considered in this
determination of reasonableness may include (1) advice, either directly or through publications or
writing, as to the value of securities, the advisability of investing in, purchasing or selling
securities, and the availability of securities or purchasers or sellers of securities; (2) analysis and
reports concerning issuers, industries, securities, economic factors and trends, portfolio strategy,
and the performance of accounts; or (3) effecting securities transactions and performing functions
incidental thereto. Such research furnished by broker-dealers may be used to service any or all of
WHealthy Empowerment Network’s clients and may be used in connection with accounts other
than those that pay commissions to the broker-dealers providing the research. In particular, third-
party research provided by broker-dealers may be used to benefit all of the firm’s clients. This
creates a conflict of interest in that the firm has an incentive to select or recommend a broker-
dealer based on its interest in receiving the research or other products or services, rather than on
the clients’ interest in receiving most favorable execution.
Benefits received may be used as soft dollars provided that:
• The service is primarily for the benefit of WHealthy Empowerment Network’s clients
• The commission rates are competitive with rates charged by comparable broker-dealers;
and
• WHealthy Empowerment Network does not guarantee a minimum amount of commissions
to any broker-dealer.
WHealthy Empowerment Network
Page 15
WHealthy Empowerment Network does not receive client referrals from any broker-dealer or third
party as a result of the firm selecting or recommending that broker-dealer to clients.
WHealthy Empowerment Network recommends that all clients use a particular broker-dealer for
execution and/or custodial services. The broker-dealer is recommended based on criteria such as,
but not limited to, reasonableness of commissions charged to the client, tools and services made
available to the client and the Advisor, and convenience of access to the account trading and
reporting. The client will provide authority to WHealthy Empowerment Network to direct all
transactions through that broker-dealer in the investment advisory agreement.
As an investment advisory firm, WHealthy Empowerment Network has a fiduciary duty to seek
best execution for client transactions. While best execution is difficult to define and challenging
to measure, there is some consensus that it does not solely mean the achievement of the best price
on a given transaction. Rather, it appears to be a collective consideration of factors concerning the
trade in question. Such factors include the security being traded, the price of the trade, the speed
of the execution, apparent conditions in the market, and the specific needs of the client. WHealthy
Empowerment Network’s primary objectives when placing orders for the purchase and sale of
securities for client accounts is to obtain the most favorable net results taking into account such
factors as 1) price, 2) size of order, 3) difficulty of execution, 4) confidentiality and 5) skill required
of the broker. WHealthy Empowerment Network may not necessarily pay the lowest commission
or commission equivalent as specific transactions may involve specialized services on the part of
the broker.
WHealthy Empowerment Network does not permit clients to direct brokerage.
WHealthy Empowerment Network may combine orders into block trades when more than one
account is participating in the trade. This blocking or bunching technique must be equitable and
potentially advantageous for each such account (e.g. for the purposes of reducing brokerage
commissions or obtaining a more favorable execution price). Block trading is performed when it
is consistent with the duty to seek best execution and is consistent with the terms of WHealthy
Empowerment Network’s investment advisory agreements. Equity trades are blocked based upon
fairness to client, both in the participation of their account, and in the allocation of orders for the
accounts of more than one client. Allocations of all orders are performed in a timely and efficient
manner. All managed accounts participating in a block execution receive the same execution price
(average share price) for the securities purchased or sold in a trading day. Any portion of an order
that remains unfilled at the end of a given day will be rewritten on the following day as a new
order with a new daily average price to be determined at the end of the following day. Due to the
low liquidity of certain securities, broker availability may be limited. Open orders are worked
until they are completely filled, which may span the course of several days. If an order is filled in
its entirety, securities purchased in the aggregated transaction will be allocated among the accounts
participating in the trade in accordance with the allocation statement. If an order is partially filled,
the securities will be allocated pro rata based on the allocation statement. WHealthy Empowerment
Network may allocate trades in a different manner than indicated on the allocation statement (non-
pro rata) only if all managed accounts receive fair and equitable treatment.
WHealthy Empowerment Network
Page 16
Trade Error Policy
We have internal controls for the prevention of trade or model allocation errors, however, on
occasion, errors may occur. We recommend that you regularly review your custodial statements.
In the event you identify an error, you have 90 days from your statement date to notify us of its
existence. Upon notification, we will perform an analysis of the reported discrepancy. If the Firm
is responsible for the error, we will seek to correct the error in a way that returns your account to
where it would have been had the error not occurred. If you notify us of a potential error more than
90 days after your statement date and the Firm is responsible for the error, the Firm will reimburse
you for any damage caused to your account from the date of the error through 90 days after your
statement date. We maintain a record of identified errors, including details of the original
transaction and the corrective actions. The trade error resolution process varies depending on the
policies and practices of the custodian where the relevant client account is maintained. Clients may
obtain additional information about the trade error policies and practices applicable to their account
by contacting the Firm.
Item 13 Review of Accounts
The firm reviews client accounts on a continuous and ongoing basis, but no less frequently than
annually or when conditions would warrant a review based on market conditions or changes in
client circumstances. Triggering factors may include WHealthy Empowerment Network
becoming aware of a change in client’s investment objective, a change in market conditions,
change of employment, or a change in recommended asset allocation weightings in the account
that exceed a predefined guideline. The nature of the review is to determine if the client account
is still in line with the client’s stated objectives. Financial plans, once prepared and delivered to
the client are not reviewed again unless the client requests a financial plan be updated. Client
accounts and financial plans are reviewed by Erin Zylka, CFP®, AIF®, and Elizabeth Schneider,
CFP®.
The client is encouraged to notify the Advisor and investment advisor representative if changes
occur in his/her personal financial situation that might materially affect his/her investment plan.
The client will receive written statements no less than quarterly from the custodian. In addition,
the client will receive other supporting reports from mutual funds, asset managers, trust companies
or other custodians, insurance companies, broker-dealers, and others who are involved with client
accounts. WHealthy Empowerment Network does not deliver separate client reports.
Item 14 Client Referrals and Other Compensation
WHealthy Empowerment Network is not compensated by anyone for providing investment advice
or other advisory services except as previously disclosed in this Brochure.
WHealthy Empowerment Network does not directly or indirectly compensate any person who is
not a supervised person for client referrals.
WHealthy Empowerment Network
Page 17
Item 15 Custody
WHealthy Empowerment Network does not take or accept physical custody of client funds or
securities, but is deemed to have custody by virtue of its ability to withdraw advisory fees directly
from client accounts (please see Item 5 which describes the safeguards around direct fee
deduction). As noted in Item 13 above, clients will receive statements not less than quarterly from
the qualified custodian, and we encourage you to review those statements carefully. Any
discrepancies should be immediately brought to the firm’s attention.
Trade Error Policy
We have internal controls for the prevention of trade or model allocation errors, however, on
occasion, errors may occur. We recommend that you regularly review your custodial statements.
In the event you identify an error, you have 90 days from your statement date to notify us of its
existence. Upon notification, we will perform an analysis of the reported discrepancy. If the Firm
is responsible for the error, we will seek to correct the error in a way that returns your account to
where it would have been had the error not occurred. If you notify us of a potential error more than
90 days after your statement date and the Firm is responsible for the error, the Firm will reimburse
you for any damage caused to your account from the date of the error through 90 days after your
statement date. We maintain a record of identified errors, including details of the original
transaction and the corrective actions. The trade error resolution process varies depending on the
policies and practices of the custodian where the relevant client account is maintained. Clients may
obtain additional information about the trade error policies and practices applicable to their account
by contacting the Firm.
Item 16 Investment Discretion
WHealthy Empowerment Network generally has discretion over the selection and amount of
securities to be bought or sold in client accounts without obtaining prior consent or approval from
the client for each transaction. However, these purchases or sales may be subject to specified
investment objectives, guidelines, or limitations previously set forth by the client and agreed to by
WHealthy Empowerment Network.
Discretionary authority will only be provided upon full disclosure to the client. The granting of
such authority will be evidenced by the client’s execution of an Investment Advisory Agreement
containing all applicable limitations to such authority. All discretionary trades made by WHealthy
Empowerment Network will be in accordance with each client’s investment objectives and goals.
Item 17 Voting Client Securities
WHealthy Empowerment Network will not vote, nor advise clients how to vote, proxies for
securities held in client accounts. The client clearly keeps the authority and responsibility for the
voting of these proxies. Also, WHealthy Empowerment Network cannot give any advice or take
any action with respect to the voting of these proxies. The client and WHealthy Empowerment
Network agree to this by contract. Clients will receive proxy solicitations from their custodian
and/or transfer agent.
WHealthy Empowerment Network
Page 18
Item 18 Financial Information
WHealthy Empowerment Network does not require or solicit prepayment of more than $1,200 in
fees per client, six months or more in advance, and is not required to file a balance sheet.
WHealthy Empowerment Network has discretionary authority over client accounts and is not
aware of any financial condition that will likely impair its ability to meet contractual commitments
to clients. If WHealthy Empowerment Network does become aware of any such financial
condition, this Brochure will be updated and clients will be notified.
WHealthy Empowerment Network has never been subject to a bankruptcy petition.
WHealthy Empowerment Network
Page 19
Item 1 Cover Page for Brochure Supplement
Erin Zylka, CFP®, AIF®
WHealthy Empowerment Network
20780 W. Chartwell Drive
Kildeer, IL 60047
(419) 340-6462
April 14, 2026
This brochure supplement provides information about Erin Zylka, CFP®, AIF® that
supplements the WHealthy Empowerment Network brochure. You should have received a
copy of that brochure. Please contact Erin Zylka if you did not receive WHealthy
Empowerment Network’s brochure or if you have any questions about the contents of this
supplement.
is available on the SEC’s website at
Additional information about Erin Zylka
www.adviserinfo.sec.gov.
WHealthy Empowerment Network
Page 20
Item 2 Educational Background and Business Experience
Erin Zylka, CFP®, AIF®, Managing Partner, was born in 1984. Ms. Zylka earned a Bachelor of
Science degree in Biology and Chemistry and a Masters of Business Administration (MBA) degree
in Finance from The University of Toledo. Ms. Zylka earned the Certified Financial Planner
certificate after attending the College for Financial Planning (2017-2020).
Ms. Zylka co-founded WHealthy Empowerment Network and has served as Managing Partner
since December 2024. Ms. Zylka is also the Owner of Zylka Financial Services, LLC dba Kona
Financial Planning, since June 2021. Previously, Ms. Zylka has held the following positions:
•
•
•
•
Investment Advisor Representative at Mariner Platform Solutions, LLC (06/2021 –
03/2025)
Investment Advisor Representative at Resolute Wealth Advisor, Inc. (12/2017 – 06/2021)
Investment Advisor Representative at Strategic Investment Advisors, LLC (06/2012 –
12/2017)
Investment Advisor Representative at Ameritas Investment Corp. (05/2010 – 06/2012)
Ms. Zylka is certified for financial planning services in the United States by Certified Financial
Planner Board of Standards, Inc. (“CFP Board”) and may therefore refer to herself as a
CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional. Ms. Zylka may use
these and CFP Board’s other certification marks (the “CFP Board Certification Marks”). The
CFP® certification is voluntary. No federal or state law or regulation requires financial planners
to hold the CFP® certification. You may find more information about the CFP® certification at
www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience,
and ethics. To become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university
and complete CFP Board-approved coursework at a college or university through a CFP
Board Registered Program. The coursework covers the financial planning subject areas
CFP Board has determined are necessary for the competent and professional delivery of
financial planning services, as well as a comprehensive financial plan development
capstone course. A candidate may satisfy some of the coursework requirement through
other qualifying credentials.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination
is designed to assess an individual’s ability to integrate and apply a broad base of financial
planning knowledge in the context of real-life financial planning situations.
• Experience – Complete 6,000 hours of professional experience related to the personal
financial planning process, or 4,000 hours of apprenticeship experience that meets
additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former
CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code
of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical
and practice standards for CFP® professionals.
WHealthy Empowerment Network
Page 21
Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board
Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a
commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore,
act in the best interests of the client, at all times when providing financial advice and
financial planning. CFP Board may sanction a CFP® professional who does not abide by
this commitment, but CFP Board does not guarantee a CFP® professional's services. A
client who seeks a similar commitment should obtain a written engagement that includes a
fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two years to
maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and
keep up with developments in financial planning. Two of the hours must address the Code
and Standards.
The Accredited Investment Fiduciary® (AIF) Designation certifies that the recipient has
specialized knowledge of fiduciary standards of care and their application to the investment
management process. To receive the AIF Designation, the individual must meet prerequisite
criteria based on a combination of education, industry experience, and/or ongoing professional
development, complete a training program, successfully pass a comprehensive, closed-book final
examination under the supervision of a proctor and agree to abide by the Code of Ethics. In order
to maintain the AIF Designation, the individual must annually renew their affirmation of the Code
of Ethics and complete six hours of continuing education. The Designation is administered by the
Center for Fiduciary Studies, the standards-setting body of fi360.
Item 3 Disciplinary Information
There are no legal or disciplinary events or proceedings to report concerning Ms. Zylka.
Item 4 Other Business Activities
Ms. Zylka is the Owner of Zylka Financial Services, LLC dba Kona Financial Planning, since June
2021. Kona Financial Planning is the “doing business as” (dba) branch office name for Ms.
Zylka’s WHealthy Empowerment Network business.
Item 5 Additional Compensation
Ms. Zylka does not receive compensation or other economic benefit from anyone who is not a
client for providing advisory services.
Item 6 Supervision
Erin Zylka, CFP®, AIF®, Managing Partner, Chief Compliance Officer, monitors the investment
advisory activities, personal investing activities, and adherence to the Advisor’s compliance
program and Code of Ethics of the WHealthy Empowerment Network supervised persons on a
WHealthy Empowerment Network
Page 22
continuous basis using various methods, including periodic inspection and review of client
securities positions and transaction activity, obtaining certifications of compliance with company
policies and procedures from those supervised, and obtaining and reviewing brokerage statements
or transactions and holdings reports of the supervised persons. Erin Zylka can be reached at (419)
340-6462.
WHealthy Empowerment Network
Page 23
Item 1 Cover Page for Brochure Supplement
Elizabeth Schneider, CFP®
WHealthy Empowerment Network
20780 W. Chartwell Drive
Kildeer, IL 60047
Branch Office:
2821 Post Road
Stevens Point, WI 54481
(715) 703-9191
April 14, 2026
This brochure supplement provides information about Elizabeth Schneider, CFP® that
supplements the WHealthy Empowerment Network brochure. You should have received a
copy of that brochure. Please contact Elizabeth Schneider if you did not receive WHealthy
Empowerment Network’s brochure or if you have any questions about the contents of this
supplement.
Additional information about Elizabeth Schneider is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 Educational Background and Business Experience
Elizabeth Schneider, CFP®, Managing Partner, was born in 1968. Ms. Schneider attended DePaul
University (2010 – 2011) and University of Wisconsin, Stevens Point (1986 – 1987) but has no
post-high school degree. Ms. Schneider earned the Certified Financial Planner certificate after
attending the College for Financial Planning (2001 – 2005).
Ms. Schneider co-founded WHealthy Empowerment Network and has served as Managing Partner
since December 2024. Ms. Schneider is also the Owner and Managing Member at Infinity Wealth
Company, LLC, since February 2022. Previously, Ms. Schneider has held the following positions:
•
Investment Advisor Representative at Mariner Platform Solutions, LLC (03/2022 –
03/2025)
• Partner Advisor at AdvicePeriod (06/2018 – 03/2022)
• Registered Representative at Investment Advisor Representative at CliftonLarsonAllen
•
Wealth Advisors (08/2011 – 12/2012)
Investment Advisor Representative at Clifton Gunderson Wealth Advisors (10/2001 –
02/2012)
• Registered Representative at CG Brokerage L.L.C. (08/2006 – 08/2011)
• Registered Representative at Cap Pro Brokerage Services, Inc. (07/2001 – 10/2005)
• Registered Representative at Edward Jones (09/1999 – 06/2001)
• Registered Representative at Associated Investment Services, Inc. (12/1997 – 09/1999)
• Registered Representative at Essex National Securities, Inc. (05/1995 – 12/1997)
Ms. Schneider is certified for financial planning services in the United States by Certified Financial
Planner Board of Standards, Inc. (“CFP Board”) and may therefore refer to herself as a
CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional. Ms. Schneider may
use these and CFP Board’s other certification marks (the “CFP Board Certification Marks”). The
CFP® certification is voluntary. No federal or state law or regulation requires financial planners
to hold the CFP® certification. You may find more information about the CFP® certification at
www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience,
and ethics. To become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university
and complete CFP Board-approved coursework at a college or university through a CFP
Board Registered Program. The coursework covers the financial planning subject areas
CFP Board has determined are necessary for the competent and professional delivery of
financial planning services, as well as a comprehensive financial plan development
capstone course. A candidate may satisfy some of the coursework requirement through
other qualifying credentials.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination
is designed to assess an individual’s ability to integrate and apply a broad base of financial
planning knowledge in the context of real-life financial planning situations.
WHealthy Empowerment Network
Page 25
• Experience – Complete 6,000 hours of professional experience related to the personal
financial planning process, or 4,000 hours of apprenticeship experience that meets
additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former
CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code
of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical
and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board
Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a
commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore,
act in the best interests of the client, at all times when providing financial advice and
financial planning. CFP Board may sanction a CFP® professional who does not abide by
this commitment, but CFP Board does not guarantee a CFP® professional's services. A
client who seeks a similar commitment should obtain a written engagement that includes a
fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two years to
maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and
keep up with developments in financial planning. Two of the hours must address the Code
and Standards.
Item 3 Disciplinary Information
There are no legal or disciplinary events or proceedings to report concerning Ms. Schneider.
Item 4 Other Business Activities
Ms. Schneider is also the Owner and Managing Member at Infinity Wealth Company, LLC, since
February 2022. Infinity Wealth Company, LLC is the “doing business as” (dba) branch office
name for Ms. Schneider’s WHealthy Empowerment Network business.
Item 5 Additional Compensation
Ms. Schneider does not receive compensation or other economic benefit from anyone who is not
a client for providing advisory services.
Item 6 Supervision
Erin Zylka, CFP®, AIF®, Managing Partner, Chief Compliance Officer, monitors the investment
advisory activities, personal investing activities, and adherence to the Advisor’s compliance
program and Code of Ethics of the WHealthy Empowerment Network supervised persons on a
continuous basis using various methods, including periodic inspection and review of client
securities positions and transaction activity, obtaining certifications of compliance with company
WHealthy Empowerment Network
Page 26
policies and procedures from those supervised, and obtaining and reviewing brokerage statements
or transactions and holdings reports of the supervised persons. Erin Zylka can be reached at (419)
340-6462.
WHealthy Empowerment Network
Page 27