WILLIAM JOSEPH CAPITAL MANAGEMENT, INC.

PART 2A OF FORM ADV: FIRM BROCHURE William Joseph Capital Management, Inc. 210 Redstone Hill Rd, Unit 5, Bristol, CT 06010 (860) 973-3214 info@WJCMLLC.com June 1, 2025 This brochure provides information about the qualifications and business practices of William Joseph Capital Management, Inc. If you have any questions about the contents of this brochure, please contact us at (860) 973-3214 or by email at info@WJCMLLC.com. 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. Additional information about William Joseph Capital Management, Inc. is available on the SEC’s website: www.adviserinfo.sec.gov. WJCM ADV Part 2A – 6.2025 Page 1  ITEM 2: MATERIAL CHANGES There are no material changes since our last update on March 1, 2025. WJCM ADV Part 2A – 6.2025 Page 2  ITEM 3: TABLE OF CONTENTS Part 2A of Form ADV: Firm Brochure ............................................................................................................................. 1 Item 2: Material Changes ..................................................................................................................................................... 2 Item 3: Table of Contents ..................................................................................................................................................... 3 Item 4: Advisory Business ................................................................................................................................................... 4 Item 5: Fees and Compensation ........................................................................................................................................ 7 Item 6: Performance-Based Fees and Side-By-Side Management ................................................................... 12 Item 7: Types of Clients ..................................................................................................................................................... 12 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss .......................................................... 12 Item 9: Disciplinary Information ................................................................................................................................... 14 Item 10: Other Financial Industry Activities and AfZiliations ........................................................................... 15 Item 11: Code of Ethics, Client Transactions, and Personal Trading .............................................................. 16 Item 12: Brokerage Practices .......................................................................................................................................... 17 Item 13: Review of Accounts ........................................................................................................................................... 19 Item 14: Client Referrals and Other Compensation ............................................................................................... 19 Item 15: Custody ................................................................................................................................................................... 20 Item 16: Investment Discretion ...................................................................................................................................... 21 Item 17: Voting Client Securities ................................................................................................................................... 22 Item 18: Financial Information ...................................................................................................................................... 22 WJCM ADV Part 2A – 6.2025 Page 3  ITEM 4: ADVISORY BUSINESS Firm Description William Joseph Capital Management, Inc. (“WJCM”, “we”, “our”) is an investment advisory firm registered with the SEC and headquartered in Connecticut. Founded in 2015, our principal owners are Mr. Matthew Thomas Sweeney, Mr. Joseph “Jody” Elzie Goss, and Mr. Justin Bolmgren. We offer: • Advisory Services • Financial Planning Services These services combined are called Wealth Management. You will have either one advisor on your account, or several advisors assigned to your relationship. Wealth Management Services may be provided under the name “Admiralty Private Client Group”. Advisory Services We provide portfolio management and investment advisory services based on your financial and investment profile. You agree to promptly notify us of any changes to this information. Our services can include creating an Investment Policy Statement (IPS) and managing your portfolio on a discretionary or non-discretionary basis. We use qualified custodians like Schwab Advisor Services to maintain physical custody of your funds and securities. We use other custodians such as insurance companies and mutual fund companies. After discussing your Zinancial proZile, the Advisor will recommend a suitable advisory program. You can also choose another program or custodian we offer. To tailor our services to your needs, you'll complete a conZidential investor proZile with details about your investment goals, income requirements, time horizon, and risk tolerance. Our aim is to provide the best investment advisory services to help you achieve your Zinancial goals. Example: If you have a goal of saving for retirement in 20 years, we will create an IPS that outlines your current financial situation, risk tolerance, and investment objectives. We will then manage your portfolio to align with these goals, making adjustments as needed. Restrictions You can place reasonable restrictions on the types of investments made on your behalf. If we believe the restrictions are not reasonable, we may not accept or may terminate the account. Example: You may request that we avoid investing in certain industries, such as tobacco or fossil fuels. We will accommodate these restrictions as long as they are reasonable and do not hinder our ability to manage your portfolio effectively. Advisory Services Program Using AssetMark Our firm offers a comprehensive advisory services program through the AssetMark platform, which leverages the expertise of sub-advisors to enhance investment strategies and optimize portfolio WJCM ADV Part 2A – 6.2025 Page 4  performance. This program is designed to provide clients with access to specialized knowledge and niche market opportunities, ensuring a diversified and well-managed investment approach. Program Description In our advisory services program, we collaborate with AssetMark, a leading provider of wealth management solutions. AssetMark's platform integrates a network of sub-advisors who bring specialized expertise in various asset classes and investment strategies. These sub-advisors conduct in-depth market research and analysis, utilizing advanced analytical tools and financial models to identify investment opportunities. They are responsible for portfolio construction and management, aligning with clients' investment goals and risk tolerance. Sub-advisors also monitor portfolio performance and implement risk management techniques, such as portfolio rebalancing and hedging, to ensure optimal outcomes. Conflict of Interest Disclosure AssetMark pays us revenue sharing compensation on most assets we manage on their platform. In return, they can market their services to our advisors and clients. This incentivizes us to recommend AssetMark over other platforms. However, you are not obliged to use AssetMark, and we will always suggest appropriate programs for you. Our Role in the Program As the primary advisor, our role is to oversee the overall investment strategy and maintain direct relationships with our clients. We carefully select and engage sub-advisors through the AssetMark platform based on their expertise and track record. Our responsibilities include: 1. Selection and Due Diligence: We conduct thorough due diligence to select sub-advisors who meet our high standards of performance and compliance. 2. Integration and Coordination: We integrate sub-advisor insights into our broader investment strategy, ensuring alignment with clients' objectives. 3. Monitoring and Supervision: We continuously monitor sub-advisor performance and compliance, utilizing AssetMark's technology platform for real-time data sharing and effective supervision. 4. Client Communication: We maintain open communication with our clients, providing regular updates on portfolio performance and any adjustments made by sub-advisors. By leveraging the specialized skills of sub-advisors through the AssetMark platform, we aim to deliver superior investment outcomes and a high level of service to our clients Custom Management We create and monitor a portfolio based on your goals, objectives, time horizon, and risk tolerance. The investment options available depend on the platform custodian and plan sponsor. Example: If you have a high risk tolerance and a long investment horizon, we may recommend a portfolio with a higher allocation to equities. Conversely, if you have a low risk tolerance and a shorter time WJCM ADV Part 2A – 6.2025 Page 5  horizon, we may recommend a more conservative portfolio with a higher allocation to fixed income securities. Selection of Sub-Advisors (Third-Party Managers) We may refer you to sub-advisors or overlay managers for asset management. These sub-advisors have discretionary authority to manage your account. We assist in identifying your risk tolerance and investment objectives. We will monitor your account, update your information on the account, and be a central communications point for you. Example: If you prefer a specialized investment strategy, such as investing in emerging markets, we may refer you to a sub-advisor with expertise in that area. The sub-advisor will manage your investments, while we provide oversight and ensure that their strategy aligns with your overall financial plan. Wealth Management Services This combines Financial Planning and Investment Management Services. Implementation of our recommendations is at your discretion. There may be a conflict of interest if we recommend our own services. Example: If you engage us for Wealth Management Services, we will create financial plana such as retirement planning, tax planning, or estate planning, among others. We will also manage your investments to align with this plan. If we recommend our own investment management services, we will disclose any potential conflicts of interest. Employer Sponsored Plans We provide advisory and consulting services to retirement plans subject to ERISA. We act as 3(21) fiduciaries under ERISA for these plans. Example: If you are a plan sponsor, we can help you select and monitor investment options for your plan, provide participant education, and ensure that the plan complies with ERISA regulations. Fee-Based Insurance Products We manage no-load insurance products like annuities and life insurance. You will sign a fee-based agreement with the carrier for these services. Example: If you purchase a no-load annuity, we can manage the sub-accounts within the annuity to align with your overall financial plan. You will pay a fee for this management service, which will be disclosed in the agreement with the insurance carrier. Financial Planning and Consulting Services We provide recommendations on asset allocation, financial planning, and consulting services. These services may include retirement planning, education planning, estate planning, and more. Implementation of recommendations is at your discretion. Neither we nor our Advisors provide legal or tax advice when acting as Advisors for WJCM. You should consult with an appropriately licensed attorney or tax professional. WJCM ADV Part 2A – 6.2025 Page 6  Example: If you need help planning for your child's education, we can create a financial plan that includes saving strategies, investment recommendations, and projections of future education costs. You can choose to implement our recommendations or seek other options. Conflict of Interest Advisors may have their own business entities for marketing purposes. These entities are independently owned and operated. When offering services, the advisors are under our supervision. See Item 10. Other Financial Industry Activities and Affiliations. Example: An advisor may have a separate business for tax preparation services. While they may use this business for marketing purposes, any financial planning or investment management services they provide will be under our supervision and subject to our compliance policies. IRA Rollover Recommendations We act as fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable when providing investment advice for retirement accounts. We must act in your best interest and disclose any conflicts of interest. 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 designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Example: If you are considering rolling over your 401(k) to an IRA, we will provide advice on the best options for your situation. We will disclose any potential conflicts of interest, such as if we receive compensation for managing the IRA. Assets Under Management As of January 1, 2025, we manage $469 million in assets on a discretionary basis. ITEM 5: FEES AND COMPENSATION General Overview of Fee Calculation and Disclosure WJCM ADV Part 2A – 6.2025 Page 7  At William Joseph Capital Management, Inc. (WJCM), we believe in transparency and clarity when it comes to our fees and compensation. Here is a general overview of how our fees are calculated and disclosed to clients: 1. Fee Calculation Methods Fees can be calculated using various methods, including: • End-of-Quarter Balance: Based on the account balance at the end of the prior quarter. • Beginning-of-Quarter Balance: Based on the account balance at the beginning of the quarter. • Average Daily Balance: Based on the average daily balance of the account during the quarter. • Average Monthly Balance: Based on the average monthly balance of the account during the quarter. 2. Disclosure of Fees We provide full disclosure of all fees and compensation to clients before they enter an advisory relationship with us. This includes: • Fee Schedule: A detailed fee schedule outlining the types of fees, the calculation methods, and the billing frequency. This is included in your Investment Advisory Contract. Fees charged by custodians, platforms and sub-advisors are disclosed in their respective disclosure documents. Example: Before you engage us for advisory services, you will receive a fee schedule that outlines the advisory fees, calculation methods, and billing frequency. You will also sign a client agreement that includes the specific fees and terms. Regular account statements will provide transparency and ensure that you are fully informed about the fees charged. 3. Termination of Account If you decide to close an account, the fee charged in the account will be pro-rated based on the number of days in the quarter for which investment management services were provided to you. If you are charged your fee in advance, you will receive a pro-rated refund for the number of days in the quarter for which we did not provide investment management services. Some custodians may charge a termination fee. WJCM does not receive any portion of their termination fee. This is described in the program documents you receive when you opened the account. By providing clear and detailed information about our fees and compensation, we aim to ensure that clients understand the costs associated with our services and can make informed decisions about their financial planning and investment management needs. Advisory Services Fees Fees are negotiated based on the size of the account, relationship, and services provided. Generally, fees range between 0.60% and 1.35% annually, billed quarterly. Fees may be calculated based on the account WJCM ADV Part 2A – 6.2025 Page 8  balance at the end of the prior quarter, beginning of the quarter, average daily balance, or average monthly balance. Example: If your account balance is $500,000 and the annual fee is 1%, you will be charged $5,000 per year, billed quarterly at $1,250 per quarter. Custom Management Fees Negotiable based on your needs and complexity. Fees may be calculated in advance or arrears and may include accrued income. If the fee is based on the value of the account, including accrued income, the account balance used to calculate the fee may not be the same as the balance you receive from the custodian. Accrued income is dividends or interest that are earned, but not yet paid. Example: If you have a complex financial situation that requires a customized investment strategy, we will negotiate a fee based on the level of service required. This fee may be higher or lower than our standard fees. Wealth Management Fees Wealth Management Services is the combination of Investment Management Services and Financial Planning Services. If you engage us for Wealth Management services, you will receive Financial Planning Services included in the fees for Investment Management Services. In cases where the scope and difficulty of the Financial Planning Services will cause a larger than normal amount of work, additional hourly fees may be charged upon mutual agreement by both parties. The fee will be based on a tiered schedule which is detailed in the Wealth Management Contract. Employee-Sponsored Plans Fees Negotiable based on needs and complexity. Fees may be calculated in advance or arrears and may include accrued income, as described above. Example: If you are a plan sponsor, we will negotiate a fee based on the size and complexity of your plan. This fee may be charged quarterly in arrears based on the plan's assets. Co-Advisory and Sub-Advisor Programs Fees Fees vary by program and are disclosed in the co-advisor's brochure. Fees may be charged in advance or arrears and may include accrued income. Example: If you choose to work with a sub-advisor, their fees will be disclosed in their brochure. These fees may be charged quarterly in advance based on the account balance at the end of the prior quarter. Other Fees and Expenses You may incur additional fees such as brokerage commissions, transaction fees, and mutual fund fees. These are not shared with us. Example: If you invest in mutual funds, you will pay fees to the mutual fund company, which are disclosed in the fund's prospectus. You may also pay transaction fees to the brokerage firm for buying and selling securities. WJCM ADV Part 2A – 6.2025 Page 9  Financial Planning and Consulting Fees 1. Fixed Fees Fixed fees are charged for creating comprehensive financial plans or providing specific financial analyses. The rate for fixed fees varies based on the scope and complexity of the services provided. Fixed fees are negotiated with the client and disclosed in the Financial Planning Agreement. This can also be an ongoing arrangement with an annual fee. Example: If you engage us for a comprehensive financial plan that includes retirement planning, tax planning, and estate planning, the fixed fee may be $5,000. This fee is determined based on the complexity of your financial situation and the level of detail required in the plan. Scope of Services Covered by Fixed Fees • Comprehensive Financial Planning: Includes a detailed analysis of your financial situation, goal setting, and recommendations for achieving your financial objectives. This may cover areas such as retirement planning, tax planning, estate planning, education planning, and risk management. • Specific Financial Analysis: Includes targeted analysis and recommendations for specific financial issues, such as evaluating investment options, analyzing insurance needs, or developing a debt management strategy. Example: If you need a specific financial analysis to evaluate the benefits of refinancing your mortgage, we may charge a fixed fee of $1,000 for this service. The fee covers the analysis, recommendations, and a detailed report. Billing and Payment for Fixed Fees Fixed fees can be billed in various ways, including: • Upfront Payment: A portion of the fixed fee may be paid in advance, with the remainder due • upon completion of the plan or analysis. Installments: The fixed fee may be billed in installments as the plan or analysis is developed and delivered to the client. • Quarterly Payments: Some fixed financial planning fees can be paid quarterly, depending on the agreement with the client. • Annual Payments: You may enter into an arrangement for ongoing financial planning and consulting for an annual fee, payable in installments. Example: For a comprehensive financial plan with a fixed fee of $5,000, you may be required to pay $2,500 upfront and the remaining $2,500 upon delivery of the final plan. Alternatively, the fee may be billed in four quarterly installments of $1,250 each. 2. Hourly Fees WJCM ADV Part 2A – 6.2025 Page 10  Hourly fees are charged for ongoing financial planning and consulting services. The rate for hourly fees is negotiable and disclosed in the Financial Planning Agreement. Hourly fees provide flexibility for clients who need ongoing advice and support without committing to a fixed fee. Example: If you require ongoing financial planning services, such as regular check-ins and updates to your financial plan, we may charge an hourly rate of $250. The total fee will depend on the number of hours spent on your case. Scope of Services Covered by Hourly Fees • Ongoing Financial Planning: Includes regular updates to your financial plan, monitoring progress toward your goals, and making adjustments as needed. • Consulting Services: Includes advice and support for specific financial issues, such as investment strategy, tax planning, or retirement planning. Example: If you need ongoing financial planning services and we spend 10 hours per quarter working on your case, the total fee for the quarter would be $2,500 (10 hours x $250 per hour). Billing and Payment for Hourly Fees Hourly fees are typically billed on a monthly or quarterly basis, depending on the agreement with the client. Clients receive detailed invoices that outline the hours worked and the services provided. Example: If you engage us for hourly financial planning services and we spend 5 hours in a month working on your case, you will receive an invoice for $1,250 (5 hours x $250 per hour) at the end of the month. Additional Considerations • Negotiability: Both fixed and hourly fees are negotiable based on the client's needs and the complexity of the services provided. We strive to offer competitive and fair pricing for our financial planning and consulting services. • Scope of Work: The specific scope of work and the associated fees are clearly defined in the Financial Planning Agreement. This ensures that clients understand the services they will receive, and the costs involved. • No Prepayment of Fees: We do not require or solicit prepayment of fees six months or more in advance. This ensures that clients are not exposed to financial risk related to the prepayment of advisory fees. Example: If you engage us for a specific financial analysis with a fixed fee of $2,000, the Financial Planning Agreement will outline the scope of the analysis, the total fee, and the payment terms. You may be required to pay $1,000 upfront and the remaining $1,000 upon completion of the analysis. By providing clear and detailed information about our financial planning and consulting fees, we aim to ensure that clients understand the costs associated with our services and can make informed decisions about their financial planning needs. WJCM ADV Part 2A – 6.2025 Page 11  ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance-based fees or participate in side-by-side management. ITEM 7: TYPES OF CLIENTS We serve individuals, high-net-worth individuals, charitable organizations, and businesses. There is no minimum account size for Advisory Services. For other programs, co-advisory programs and sub-advisor arrangements, please refer to the Disclosure Brochure for the Platform for any minimum requirements that may apply. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS Co-Advisory and Sub-Advisory Programs If we recommend that you use a co-advisory or sub-advisory program, we will provide advice regarding which sub-advisor or program to use and which investment managers to use within the program. We regularly monitor the performance of each investment manager and will recommend a different investment manager when we believe it is appropriate. Methods of Analysis We use various methods of analysis to provide investment advice to clients. Each method has its own risks: • Technical Analysis: This method involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. o Risk: There is no guarantee that past trends will reoccur. Market conditions can change rapidly, and relying solely on historical data may lead to inaccurate predictions. • Fundamental Analysis: This method involves analyzing individual companies and their industry groups by reviewing their financial statements, product lines, management expertise, and industry outlook. The resulting data is used to measure the true value of the company's stock compared to the current market value. o Risk: Different analysts may interpret financial data differently, leading to varying conclusions. Additionally, unforeseen events such as changes in management or regulatory changes can impact a company's performance. • Cyclical Analysis: This method involves evaluating recurring price patterns and trends based on business cycles. o Risk: The lengths of economic cycles may be difficult to predict with accuracy. There is no guarantee that past trends will reoccur and result in the expected outcome. Economic cycles can be influenced by numerous factors, including political events and global economic conditions. WJCM ADV Part 2A – 6.2025 Page 12  • Quantitative Analysis: This method involves understanding how a sector or security will behave based on mathematical and statistical criteria such as the value of assets, cost of capital, and historical projections of sales. o Risk: Not all variables are considered in quantitative models. There is no guarantee that the formulas or processes used will result in an accurate projection. Market conditions can change in ways that are not captured by historical data. • Qualitative Analysis: This method involves using subjective judgment based on unquantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. o Risk: A subjective review can be influenced by a person's past experiences or personal biases. It may not result in an accurate assessment. Qualitative factors can be difficult to measure and may not always predict future performance. Investment Strategies We employ various investment strategies to help clients achieve their financial goals. Each strategy carries its own risks: • Asset Allocation: We believe that asset allocation across diverse investments is the key to long- term success in reaching client objectives. Your portfolio is customized to your specific investment objectives and risk tolerance. o Risk: Diversification does not eliminate the risk of loss. Different asset classes may perform poorly at the same time, leading to potential losses. • Concentrated Positions: Your portfolio may contain one or more highly concentrated investment positions or sectors. o Risk: Concentrated positions increase the potential volatility within a portfolio, thus increasing the risk of loss. If the concentrated investment performs poorly, it can have a significant negative impact on the overall portfolio. • Small Capitalization Companies: Assets may be invested in smaller, less established companies. o Risk: Both debt and equity securities of such issuers tend to be more volatile than larger, more established companies. Such volatility could adversely impact client portfolios. Smaller companies may also have limited resources and may be more susceptible to economic downturns. • Large Capitalization Companies: Large cap stocks can perform differently from other segments of the equity market. o Risk: Large capitalization companies may be less flexible in evolving markets or unable to implement change as quickly as smaller capitalization companies. They may also face regulatory scrutiny and competitive pressures. • Non-U.S. Investments: We may recommend that you invest your funds in securities (debt, equity, currencies, derivatives, etc.) of companies domiciled outside the United States. o Risk: Such investments expose the account to risks that may not exist in the domestic market, such as governmental economic policies, currency exchange rate fluctuations, imposition of exchange control regulation, withholding taxes, limitations on the removal of funds or other assets, possible nationalization of assets or industries, political difficulties, and political instability in foreign nations. WJCM ADV Part 2A – 6.2025 Page 13  Risks of Specific Securities Utilized We generally seek investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. However, each type of security carries its own risks: • Mutual Funds: Investing in mutual funds carries the risk of capital loss, and you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. They can be of bond (fixed income) nature (lower risk) or stock (equity) nature (higher risk). o Risk: Mutual funds are subject to market risk, interest rate risk, and credit risk. The value of mutual fund shares can fluctuate based on the performance of the underlying securities. • Equity Investments: Equity investment generally refers to buying shares of stocks by an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the stock increases. o Risk: There is an innate risk involved when purchasing a stock that it may decrease in value, and the investment may incur a loss. Stocks are subject to market risk, economic risk, and company-specific risk. • Fixed Income Investments: Fixed income is an investment that offers fixed periodic payments in the future that may involve economic risks such as inflationary risk, interest rate risk, default risk, repayment of principal risk, etc. o Risk: Fixed income securities are subject to interest rate risk, credit risk, and inflation risk. Changes in interest rates can affect the value of fixed income investments, and issuers may default on their payments. • Exchange Traded Funds (ETFs): Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). ETFs may also be priced at a discount or premium to the value of the assets within the fund. o Risk: ETFs are subject to market risk, tracking error risk, and liquidity risk. The value of ETF shares can fluctuate based on the performance of the underlying securities, and there may be discrepancies between the ETF's market price and its net asset value (NAV). Risk of Loss Investing in securities involves risks, including the loss of principal. Securities fluctuate in value. You should understand and be prepared for these fluctuations in value and the potential of loss. Example: If you invest in a diversified portfolio of stocks and bonds, the value of your investments may fluctuate based on market conditions. During a market downturn, the value of your portfolio may decrease, resulting in potential losses. It is important to have a long-term investment strategy and be prepared for short-term volatility. ITEM 9: DISCIPLINARY INFORMATION We have no disciplinary information to report. WJCM ADV Part 2A – 6.2025 Page 14  ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Insurance Affiliations Some of our Investment Advisor Representatives (IARs) are also licensed insurance agents. They may recommend insurance products and receive commissions for the sale of these products. Some IARs may provide a written or verbal review of your current life, disability, or health insurance plans. This may be an element of financial planning, but the IAR may provide it for free. As a result of the review, they may recommend you purchase an insurance product. The IAR will receive additional compensation from the insurance company for the sale of the insurance product. This creates a conflict of interest as the IAR may be incented to sell an insurance product based on the anticipated compensation rather than your need for insurance. Example: If an IAR reviews your life insurance coverage and recommends a new policy, they may receive a commission from the insurance company. We disclose this conflict to you and ensure that the recommendation is in your best interest. You are not obligated to purchase the insurance from the IAR and may find comparable insurance at a lower cost from another insurance agent. Our IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials. These businesses are legal entities of the IARs and are independently owned and operated. When offering financial planning or investment management services, the IARs are under our supervision, and the services are provided through us. These IARs may offer other services to non-WJCM clients, and when they do so, their activities are not under our supervision. We have arrangements with the following IARs' legal entities: Joseph E. Goss, Ltd. (dba The Producers Firm) Integrity Financial Marketing, LLC (dba Stateline Senior Services, LLC) • • Health Insurance Quote Service, Inc. • Roberson, Tierney & Associates, LLC • • Synergy Independent Financial Solutions, LP • Legacy Retirement Group, LLC • Abacus Financial Advisors, LLC • Ricci & Co. CPAs and Consultants LLC • Waypoint Wealth Planning and Investment Advisors • CMA Financial Group, Inc (dba CMA Health Agency) Financial Consulting Services For an asset-based fee, we may contract directly with third-party firms, including broker-dealers, to provide advisory consulting services to their clients. These services do not include any assumption of discretionary authority over any brokerage accounts and do not include the monitoring of securities positions. Our services are limited to advice and analysis. Example: We may provide consulting services to a broker-dealer's clients, offering advice on asset allocation and investment strategies. We do not manage the accounts directly or monitor the securities positions. WJCM ADV Part 2A – 6.2025 Page 15  Affiliated Insurance Agency William Joseph Capital Management, Inc. has an affiliated insurance agency called Wealth Preservation Specialist, LLC, which offers insurance products through its dba, William Joseph Insurance. Advisors associated with Wealth Preservation Specialist, LLC will receive compensation for the sale of insurance products. Example: If you purchase an insurance product through Wealth Preservation Specialist, LLC, the advisor will receive a commission. We disclose this arrangement to you and ensure that the recommendation is in your best interest. Item 11: CODE OF ETHICS, CLIENT TRANSACTIONS, AND PERSONAL TRADING Code of Ethics William Joseph Capital Management, Inc. (WJCM) and its employees adhere to high ethical standards, ensuring we act in the best interests of our clients and comply with all applicable laws and regulations. Our Code of Ethics requires integrity, competence, diligence, and respect in all professional activities. Personal Trading Our personnel must prioritize clients' interests over their own and comply with all securities laws. Employees are prohibited from recommending securities in which they have a material Zinancial interest. Prohibition on Insider Trading Employees are forbidden from trading based on material non-public information or sharing such information with others. Reporting and Monitoring Employees must report personal securities transactions and holdings to our Chief Compliance OfZicer (CCO), who reviews these reports for compliance and potential conZlicts of interest. Pre-Clearance of Trades Certain personal securities transactions require pre-clearance from the CCO to prevent conZlicts of interest. Gifts and Entertainment Employees are prohibited from accepting or giving gifts or entertainment that could inZluence their decision-making or create a conZlict of interest. Con@identiality Employees must maintain the conZidentiality of client information, using secure methods to secure and transmit data. WJCM ADV Part 2A – 6.2025 Page 16  ITEM 12: BROKERAGE PRACTICES Selecting Brokerage Firms We can work with multiple custodians and may recommend a specific custodian to you based on your needs. You may pay the custodian a fee for services that is higher than another custodian may charge for the same services. You may direct us to use a specific custodian, but we cannot guarantee the operational ability to work with that custodian. If we can work with your directed custodian, we will not have the authority to negotiate commissions or obtain volume discounts. Also, we may not be able to achieve best execution by utilizing the custodian you direct. Example: If you prefer to use a specific custodian because of their reputation or services, we will accommodate your request if possible. However, this may result in higher transaction costs or less favorable execution compared to other custodians we typically work with. Research and Other Soft-Dollar Benefits We receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). These soft-dollar arrangements are consistent with the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. These benefits are used to service all client accounts. We do not try to allocate these benefits to client accounts proportionately to their size or profitability. We benefit by not having to produce or pay for the research, products, or services, and we will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that our acceptance of soft dollar benefits may result in higher commissions charged to the client. Example: If we receive research reports or trading software from a broker-dealer as part of a soft-dollar arrangement, we may be incentivized to direct trades to that broker-dealer. This could result in higher transaction costs for clients, but the research and tools we receive can enhance our ability to manage client portfolios effectively. Best Execution We believe in using custodians that provide the best services at competitive rates. The reasonableness of commission rates is based on several factors, including the broker's ability to provide professional services, execution, the broker's reputation, experience and financial stability of the broker or dealer, and the quality of service rendered by the broker or dealer in transactions. Best execution is not measured solely by reference to commission rates. Paying a broker a higher commission rate than another broker might charge is permissible if the difference in cost is reasonably justified by the quality of the brokerage services offered. Example: If a broker-dealer charges slightly higher commissions but provides superior execution quality and customer service, we may choose to use that broker-dealer to ensure that client trades are executed efficiently and accurately. Order Aggregation It is our practice to aggregate transactions across multiple client accounts whenever possible. This practice is intended to achieve more favorable execution and to reduce overall costs to clients. However, this is not possible when using third-party managers. When transactions are aggregated, the costs are WJCM ADV Part 2A – 6.2025 Page 17  shared equally and on a pro-rata basis between all accounts included in the aggregation. We will not favor any account over another. Example: If we need to buy shares of a particular stock for multiple client accounts, we may aggregate the orders into a single large order. This can result in better pricing and lower transaction costs for all clients involved in the aggregated order. Trade Errors If a trade error occurs when entering a trade on behalf of a client, our policy is to restore a client’s account to the position it should have been in had the trade error not occurred. If the trade correction results in a loss, the client will not incur the loss. If the correction results in a gain, the gain is handled according to the policy of the custodian or third-party manager. We will never benefit from a trade error if it results in a gain. For more information, please refer to the account agreement of your custodian, or the disclosure document of the third-party manager. Example: If we mistakenly buy 100 shares of a stock instead of 10 shares for your account, we will correct the error by selling the excess shares. If this results in a loss, we will cover the loss. If it results in a gain, the gain will be handled according to the custodian's policy, and we will not benefit from the error. Directed Brokerage You may direct us to use a particular broker-dealer to execute some or all transactions for your account. In these cases, you will negotiate the terms and arrangements for the account with that broker-dealer, and we will not seek better execution services or prices from other broker-dealers. As a result, you may pay higher commissions or other transaction costs or receive less favorable net prices on transactions for your account than would otherwise be the case. Subject to our duty of best execution, we may decline your request to direct brokerage if we believe such directed brokerage arrangements would result in additional operational difficulties. Example: If you have an existing relationship with a broker-dealer and prefer to use them for your trades, you can direct us to do so. However, this may result in higher costs or less favorable execution compared to other broker-dealers we typically use. Brokerage for Client Referrals We do not receive client referrals from broker-dealers or third parties in exchange for using their brokerage services. Example: We do not enter arrangements where a broker-dealer refers clients to us in exchange for directing trades to them. Our selection of broker-dealers is based solely on their ability to provide the best execution and services for our clients. Advisors Using AssetMark Advisors using AssetMark as a co-advisor may receive an allowance or “growth support” for reimbursement or direct payment of qualified expenses incurred by the Advisor based on their participation in AssetMark-sponsored events, marketing initiatives, or use of technology resources and tools. This program creates a financial incentive for Advisors to recommend that you invest assets WJCM ADV Part 2A – 6.2025 Page 18  through the AssetMark Platform. You may choose one of the other third-party platforms in our program. As of this filing, most of our assets under management are with AssetMark. Example: If an advisor participates in an AssetMark-sponsored event and receives reimbursement for travel expenses, this creates an incentive for the advisor to recommend AssetMark's platform to clients. We disclose this arrangement to you and ensure that any recommendations are in your best interest. ITEM 13: REVIEW OF ACCOUNTS Periodic Reviews We conduct regular reviews of client accounts to ensure that the investment strategies and asset allocations remain aligned with the client's financial goals and risk tolerance. These reviews are conducted by our Investment Advisor Representatives (IARs) and may occur quarterly, semi-annually, or annually, depending on the client's needs and preferences. Review Triggers In addition to periodic reviews, we may conduct additional reviews based on certain triggering events. These events may include significant market movements, changes in your financial situation, or specific requests from you. Example: If there is a significant market downturn, we may conduct an unscheduled review of your account to assess the impact on your portfolio and determine if any adjustments are needed to mitigate potential losses. Regular Reports You will receive monthly or quarterly portfolio statements from the custodian holding your assets Client Responsibilities We encourage clients to actively participate in the review process and to notify us of any changes in their financial situation, goals, or risk tolerance. This information is crucial for ensuring that our investment strategies remain aligned with your needs. Example: If you experience a significant life event, such as retirement or the birth of a child, it is important to inform your IAR so that we can adjust your investment strategy to reflect your new financial goals and circumstances. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Client Referrals We may enter into referral arrangements with other persons or entities, known as solicitors, who refer clients to us. In these cases, we will pay the solicitor a referral fee for introducing clients to us. The WJCM ADV Part 2A – 6.2025 Page 19  referral fee is typically a percentage of the advisory fees we receive from the referred client. This arrangement creates a conflict of interest because the solicitor has an incentive to refer clients to us based on the compensation received, rather than on the client's best interests. Example: If a financial planner refers you to us and we agree to pay them 20% of the advisory fees we earn from managing your account, this creates a conflict of interest. We disclose this arrangement to you and ensure that the referral is in your best interest. Other Compensation We do not receive any additional compensation from third parties for providing investment advice to clients. However, our Investment Advisor Representatives (IARs) may receive compensation from other sources, such as commissions for the sale of insurance products or fees for providing financial planning services. These arrangements create potential conflicts of interest, which we disclose to clients. ITEM 15: CUSTODY Custody of Client Assets William Joseph Capital Management, Inc. (WJCM) does not have physical custody of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. These custodians are responsible for the safekeeping of your assets and will provide you with regular account statements. Example: If you open an investment account with us, your assets will be held by a qualified custodian such as Schwab Advisor Services. Schwab will be responsible for holding your funds and securities, processing transactions, and providing you with account statements. Account Statements You will receive account statements from the custodian(s) holding your funds and securities at least quarterly. These statements provide detailed information about your account, including account balances, transaction history, and any fees or expenses charged to your account. It is important to carefully review these statements for accuracy and to ensure that all transactions are correct. Example: If your account is held with Schwab, you will receive quarterly statements from Schwab that detail the value of your investments, any transactions that occurred during the reporting period, and any fees charged to your account. Advisory Fee Deduction The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. Example: If our advisory fee is 1% annually, billed quarterly, and your account balance is $500,000, you will be charged $1,250 per quarter. This fee will be deducted from your account by the custodian, and the deduction will be reflected on your account statement. WJCM ADV Part 2A – 6.2025 Page 20  Client Responsibilities You should carefully review account statements for accuracy and promptly report any discrepancies to us and the custodian. If you have a question regarding account statements or if you did not receive a statement from the custodian, please contact us at the contact information provided on the front page of this brochure. Example: If you notice an unauthorized transaction or an error in the account balance on your statement, you should contact both WJCM and the custodian immediately to resolve the issue. Standing Letters of Authorization (SLOA) In some cases, clients may grant us the authority to transfer funds between their accounts or to third parties through a Standing Letter of Authorization (SLOA). While this does not constitute physical custody, it does grant us limited authority over the client's assets. We follow strict procedures to ensure that these transfers are conducted in accordance with the client's instructions and regulatory requirements. Example: If you provide us with an SLOA to transfer funds from your investment account to your bank account on a regular basis, we will follow your instructions and ensure that the transfers are accurately reflected on your account statements. ITEM 16: INVESTMENT DISCRETION Discretionary Authority for Trading Our Investment Advisor Representatives (IARs) may customize investment portfolios and/or use third- party investment managers. These third-party investment managers require you to give them discretionary trading authority. We also request discretionary authority. This means that, without obtaining your consent, we have the authority to determine the third-party investment manager you use, the investments to be bought or sold, or the amount of securities to be bought or sold. Discretionary authority is granted via a limited power of attorney executed by you. Example: If you grant us discretionary authority, we can make investment decisions on your behalf, such as buying or selling stocks, bonds, or mutual funds, without needing to obtain your approval for each transaction. This allows us to respond quickly to market conditions and manage your portfolio more effectively. Non-Discretionary Authority You have the right to decline to implement any advice provided by us on a non-discretionary basis. In a non-discretionary arrangement, we provide investment recommendations, but you retain the final decision-making authority. We will only execute transactions with your explicit approval. Example: If you prefer to have more control over your investments, you can choose a non-discretionary arrangement. In this case, we will provide you with investment recommendations, but you must approve each transaction before it is executed. WJCM ADV Part 2A – 6.2025 Page 21  Custodian Selection and Commission Rates You approve the custodian to be used to house assets/investments and the commission rates paid to the custodian. We do not receive any portion of the transaction fees or commissions paid by the client to the custodian on any given transaction. Example: If you choose to use Schwab as your custodian, you will approve the commission rates charged by Schwab for executing trades. We do not receive any portion of these commissions, ensuring that our recommendations are based solely on your best interests. ITEM 17: VOTING CLIENT SECURITIES Proxy Votes You are responsible for voting your own proxies. However, we can assist you. If you own investments, you are a direct shareholder and can exercise your right as a shareholder to vote on proxies. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, the materials would be forwarded directly to you by mail, unless you have authorized us to contact you by electronic mail, in which case we would forward any electronic solicitation to vote proxies. Example: If you hold shares in a company and there is a shareholder vote on a corporate action, such as a merger or election of directors, you will receive proxy materials from the custodian. You can vote on these matters directly, or you can ask us for guidance on how to vote. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in said class action settlement or litigation, nor do we initiate or participate in litigation to recover damages on your behalf for damages because of said actions, misconduct, or negligence of said party. Example: If a company in which you hold shares is involved in a class action lawsuit, you will need to monitor the situation and decide whether to participate in the lawsuit. We do not provide legal advice or representation in such matters. ITEM 18: FINANCIAL INFORMATION Financial Condition We do not have any financial situation that will result in our inability to meet our contractual commitments to you. We are financially stable and have adequate resources to provide the advisory WJCM ADV Part 2A – 6.2025 Page 22