WILON WEALTH MANAGEMENT

Ra.or WILON WEALTH MANAGEMENT Firm Brochure- Form ADV Part 2A MARCH 16, 2026 This brochure provides information about the qualifications and business practices of Wilon Wealth Management. If you have any questions about the contents of this brochure, please contact us at (515) 225-9500 or by email at msonstot@wilonwm.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. Wilon Wealth Management is a registered investment advisor. Registration of an investment advisor does not imply any level of skill or training. Additional information about Wilon Wealth Management is also available on the SEC's website at www.adviserinfo.sec.gov. Wilon Wealth Management's CRD number is: 313185. 2400 86th Street, Suite 32, Urbandale, IA 50322 | 515-225-9500 msonstot@wilonwm.com | www.wilonwm.com  PAGE 2 Item 2. Material Changes Since our last annual updating amendment on March 25, 2025, Wilon Wealth Management has no material changes to report. Material changes relate to Wilon Wealth Management’s policies, practices or conflicts of interests. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 3 Item 3. Table of Contents Item 1. Cover Page 1 Item 2. Material Changes 2 Item 3. Table of Contents 3 Item 4. Advisory Business 4 Item 5. Fees and Compensation 7 13 Item 6. Performance-Based Fees and Side-by-Side Management Item 7. Types of Clients 13 14 Item 8. Methods of Analysis, Investment Strategies & Risk of Loss Item 9. Disciplinary Information 20 Item 10. Other Financial Industry Activities and Affiliations 20 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 22 Item 12. Brokerage Practices 24 Item 13. Review of Accounts 26 Item 14. Client Referrals and Other Compensation 27 Item 15. Custody 28 Item 16. Investment Discretion 28 29 Item 17. Voting Client Securities (Proxy Voting) Item 18. Financial Information 29 Privacy Policy Notice 30 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 4 Item 4. Advisory Business A. Description of the Advisory Firm Binnacle Investments, Inc. DBA Wilon Wealth Management (hereinafter “Wilon”) is a Corporation organized in the State of Iowa. The firm was formed in March 2007, and registered as an Investment Advisory Firm in April 2021. The principal owners are Matthew Onstot and Jason Wiltse. The Firm is a fiduciary and is required to act in the client’s best interest at all times. B. Advisory Business Financial Planning Services Wilon helps people grow and protect their wealth using our full-service wealth management process. Wilon’s Financial Planning services help individuals and families identify, clarify and act upon their financial and life goals. Key components: Investment Planning 1. Retirement Planning 2. Estate Planning 3. 4. Tax and Cash Flow Planning 5. Risk Management Planning 6. Charitable Planning 7. Education Planning Financial planning is not something that is completed. It is a continuous process. Wilon believes that all successful lifetime investing is goal focused and planning driven. As such, we aspire to engage clients that see the value in allowing the financial planning process to drive their asset management decisions, not the other way around. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 5 Asset Management Services Wilon offers ongoing asset management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Wilon creates an investment strategy for each client, which outlines the client’s current situation and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Wilon seeks to make investment decisions that are in accordance with the fiduciary duties owed to its accounts and without consideration of Wilon’s economic, investment or other financial interests. To meet its fiduciary obligations, Wilon attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Wilon’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Wilon’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent on a fair and equitable basis over time. Periods of Inactivity Wilon has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Wilon will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Wilon determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Wilon will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Third-Party Money Managers Wilon may determine that opening an account with a professional third-party money manager is in the client’s best interest. These programs allow clients to obtain portfolio management services that typically require higher minimum account sizes outside of the program. The money managers selected under these programs will have discretion to determine the securities they buy and sell within the account, subject to reasonable restrictions imposed by the client. Due to the nature of these programs, each of the independent money managers is obligated to provide you with a separate disclosure document. Clients should carefully review this document for important and specific program details, including pricing. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 6 Under these programs, Wilon may: Assist in the identification of investment objectives Recommend specific investment style and asset allocation strategies Assist in the selection of appropriate money managers and review performance and progress Recommend reallocation among managers or styles within the program Recommend the hiring and firing of money manages utilized by the client Clients should read the ADV Part 2 disclosure document of the money manager the client selects for complete details on the charges and fees that the client will incur. Types of Investments Wilon may also provide you with investment advice on: Mutual funds ETFs (exchange-traded funds) Index funds Index annuities REITs (real estate investment trusts) 529 college savings plans Alternative investments Insurance products (including annuities and life insurance) Note: This may not be an all-inclusive list. C. Client Tailored Services and Client Imposed Restrictions Wilon will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by Wilon on behalf of the client. Wilon may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Wilon from properly servicing the client account, or if the restrictions would require Wilon to deviate from its standard suite of services, Wilon reserves the right to end the relationship. D. Wrap Fee Programs Wilon does not participate in any wrap fee programs. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 7 E. Assets Under Management As of December 31, 2025, Wilon’s total assets under management are as follows: Discretionary Non-discretionary Total $264,137,161 $0 $264,137,161 Item 5. Fees and Compensation A. Fee Schedule Portfolio Management Fees Wilon uses the value of the account as of the last business day of the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty. Financial Planning Fees Fixed Fees The total financial planning fee is based on the scope and complexity of the client’s situation. The flat fee charged is from $2,500 up to $15,000. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 8 Hourly Fees Each client’s fee for service is different and is based on the specific needs and factors involved. The fee for these services is based on an hourly rate determined by the nature and complexity of the services requested. The negotiated hourly fee for these services is between $150 and $350. Clients may terminate the agreement without penalty, for full refund of Wilon’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Other Additional Fees Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Mutual Fund Fees: Mutual funds often offer multiple share classes with differing internal fee and expense structures. Wilon endeavors to identify and utilize the share class with the lowest internal fee and expense structure for each mutual fund. However, instances occur in which the lowest cost share class is not used. These instances include but are not limited to: Instances in which a certain custodian has a share class available that has a lower internal fee and expense structure than is available for the same mutual fund at other custodians. In such instances, Wilon will select the lowest cost share class available at the custodian that holds your account even though a lower cost share class is available at another custodian. Instances in which the custodian that holds your account offers others a share class with a lower internal fee and expense structure than what is available to Wilon at the same custodian. In such instances, Wilon will select the lowest cost share class that the custodian makes available. This situation sometimes occurs because the custodian places conditions on the availability of the lower cost share class that Wilon has determined are not appropriate to accept due to additional costs imposed by said conditions. Instances in which a share class with a lower internal fee and expense structure becomes available after the share class you hold was purchased. Wilon periodically monitors this circumstance. However, a share class with a lower internal fee may become available between the time of your purchase and Wilon’s next review. Instances in which a share class with a lower internal fee and expense structure than the share class you currently hold is available at your custodian, but where Wilon is prevented by either the custodian or the fund sponsor from converting to the lower cost share class. Additionally, Wilon does not convert to a share class with a lower internal fee and expense structure if the conversion will cause a taxable event or other expense/cost to you that negates the advantage of the lower cost share class. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 9 Non-Transaction Fee (NTF) Mutual Funds: When selecting investments for our clients’ portfolios we might choose mutual funds on your account custodian’s Non-Transaction Fee (NTF) list. This means that your account custodian will not charge a transaction fee or commission associated with the purchase or sale of the mutual fund. The mutual fund companies that choose to participate in your custodian’s NTF fund program pay a fee to be included in the NTF program. The fee that a mutual fund company pays to participate in the program is ultimately borne by the owners of the mutual fund including clients of our Firm. When we decide whether to choose a fund from your custodian’s NTF list or not, we consider our expected holding period of the fund, the position size and the expense ratio of the fund versus alternative funds. Depending on our analysis and future events, NTF funds might not always be in your best interest. Unmanaged Assets: From time to time, a Client may decide to hold certain securities or other property for which our Firm does not provide investment advisory services ("Unmanaged Assets") in the account(s) held at the Custodian or outside the Custodian. Unmanaged assets will be shown on Wilon reports as unmanaged assets. It is the client’s sole responsibility to verify the accuracy of the Unmanaged status of any and all investments in their accounts and to notify Wilon in writing of any corrections or adjustments that need to be made. Our Firm will have no duty, responsibility or liability whatsoever with respect to these assets, and therefore, our Firm will not charge an investment advisory fee. However, if you have an account that solely contains Unmanaged Assets, the Custodian may charge an account maintenance fee as disclosed in the Custodian account paperwork executed by the Client. In all cases, it is the clients sole responsibility to monitor, manage, and transact all Unmanaged Assets (securities and/or accounts). Regulatory Fees: To facilitate the execution of trades, regulatory Trading Activity Fees (TAF) are added to applicable sales transactions. The Securities and Exchange Commission (SEC) regulatory fee is assessed on client accounts for sell transactions, and a FINRA fee is assessed on client accounts for sell transactions, for certain covered securities. This fee is not charged by our Firm but is accessed and collected by the custodian. The Custodian that our Firm uses, is a FINRA member firm. These fees recover the costs incurred by the SEC and FINRA, for supervising and regulating the securities markets and securities professionals. The fee rates vary depending on the type of transaction and the size of that transaction. For more information on the SEC and FINRA fees, please visit their websites: www.sec.gov/fast-answers/answerssec31htm.html or www.finra.org/industry/trading-activity-fee. Treatment of Mutual Fund Share Classes Mutual funds often offer multiple share classes with differing internal fee and expense structures. Our firm’s planning methodology does not include the purchase of mutual fund portfolios. However, if mutual funds are transferred to our platform, they may not be the lowest cost share class option. Other instances that may not include the lowest share class include: These instances include but are not limited to: • Instances in which a certain custodian has a share class available that has a lower internal fee and expense structure than is available for the same mutual fund at other custodians: In such instances, our Firm will select the lowest cost share class available at the custodian that holds your account even though a lower cost share class is available at another custodian. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 10 • • • • Instances in which the custodian that holds your account offers others a share class with a lower internal fee and expense structure than what is available to our Firm at the same custodian: In such instances, our Firm will select the lowest cost share class that the custodian makes available. This situation sometimes occurs because the custodian places conditions on the availability of the lower cost share class that our Firm has determined are not appropriate to accept due to additional costs imposed by said conditions. Instances in which a share class with a lower internal fee and expense structure than the share class you currently hold is available at your custodian, but there are limitations as it relates to share class eligibility, custodian restrictions, or additional fees/taxes that the conversion would trigger: Our Firm cannot convert to a share class with a lower internal fee and expense structure if the account is ineligible (e.g., the fund company only allows certain types of registration types to use the share class or the account doesn’t meet the investment minimum for the share class) or if the fund company won’t accept a conversion if the share amount is too small. Our Firm also cannot convert to a lower internal fee and expense structure if the custodian will not allow it (e.g., custodial restrictions). Also, our Firm does not convert to a share class with a lower internal fee and expense structure if the conversion will cause a taxable event or other expense/cost to you that negates the advantage of the lower cost share class. Instances in which a Model Manager selects a share class for inclusion in a model that is not the lowest cost share class available: Our firm uses model managers that build investment portfolios that are designed to meet the needs of our clients and fall within in their risk scores. Our firm does not have the authority to modify or provide input to the selection of the securities in the model. Instances in which you make your own investment selections in a Client-Directed: Account In such circumstances, our Firm does not screen for the lowest mutual fund share class available. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a monthly or quarterly basis. Fees are paid in arrears. Payment of Third-Party Money Manager Fees The timing, frequency, and method of paying fees for the selection of third-party managers will depend on the specific third-party advisor selected. Fees for selection of SEI Private Trust company as third-party advisor are withdrawn directly from the client's accounts with client's written authorization. Fees are paid quarterly in arrears. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 11 Payment of Financial Planning Fees At the time of engagement, a deposit of up to 50% may be required with the balance due upon delivery of the requested services. Financial planning fees are paid via check. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by Wilon. Please see Item 12 of this brochure regarding broker-dealer/custodian. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 12 D. Prepayment of Fees As indicated above, some financial planning and other project fees are collected in advance while asset management fees are billed monthly or quarterly in arrears. Wilon does not collect prepayment of more than $1,200 in fees per client, six months or more in advance. E. Outside Compensation For the Sale of Securities to Clients Matthew Onstot, Jason Wiltse and Connor Peck are registered representatives of a broker- dealer. Matthew Onstot, Jason Wiltse, Brian Blankenburg and Connor Peck are also insurance agents. In these roles, they accept compensation for the sale of investment products to Wilon clients. 1. This is a Conflict of Interest Supervised persons may accept compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds to Wilon's clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of investment products for which the supervised persons receives compensation, Wilon will document the conflict of interest in the client file and inform the client of the conflict of interest. 2. Clients Have the Option to Purchase Recommended Products from Other Brokers Clients always have the option to purchase Wilon recommended products through other brokers or agents that are not affiliated with Wilon. 3. Commissions are not Wilon's Primary Source of Compensation for Advisory Services Commissions are not Wilon’s primary source of compensation for advisory services. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 13 4. Advisory Fees in Addition to Commissions or Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on investment products recommended to clients. Item 6. Performance-Based Fees and Side-by- Side Management Wilon does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7. Types of Clients Wilon generally provides services, which may include financial planning and asset management, to individuals, high-net-worth individuals, trusts, estates, charitable organizations and business entities. Wilon generally requires clients to have a minimum of $250,000 in investable assets. This threshold has been established to allow Wilon to provide a high level of personal service and attention which we believe our clients deserve. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 14 Item 8. Methods of Analysis, Investment Strategies & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis Personalized investment recommendations may be based upon any of the following considerations: Goals and objectives Time horizon Risk tolerance Current and future income needs Household allocation Tax consideration Liquidity requirements Need for inflation protection Asset class correlation Investment Philosophy When it comes to investing our clients' wealth, Wilon’s investment philosophy focuses on building an asset allocation across a broad array of asset classes to create portfolios appropriate for each clients’ risk tolerance. Focusing on the long term, keeping investment fees low and tax efficiency are also top priorities of our investment philosophy. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 15 Nitrogen (formally Riskalyze) Platform: The Firm does utilize Nitrogen, a third-party vendor tool to assist in identifying the client’s risk tolerance. Nitrogen technology assists financial planners in two critical tasks: (1) measuring the risk preferences of investors, and (2) applying these preference measurements to portfolio selection. Nitrogen summarizes an investor’s mean-variance risk aversion on a 99-point scale. In connection with this output, the Nitrogen tool “quantifies” the client’s indicated investment risk tolerance through the illustration of expected return (plus/minus) and investment volatility (investment variance) which uses past data to calculate expected variance. The Firm works with Nitrogen to customize client portfolios using a combination of existing holdings and recommended allocation strategies to provide the client with the desired risk score. Once the Risk Score is identified, the Firm prepares a strategy, which is also scored by Nitrogen tools. Generally, clients are recommended a mixture of strategies with various allocations, including strategies which focus on fixed income, growth, balanced, moderate, or aggressive investments, which correlate to the client’s risk score. B. Material Risks Involved Investing in securities directly or through ETF’s, mutual funds, or other vehicles, involves risk of loss that clients should be prepared to bear. All investments carry risk of loss, including complete loss. There is no guarantee that any investment strategy will meet its objective. Any past success off a particular investment strategy does not imply or guarantee future success. Depending on the investment strategy and type of investment vehicles used, clients may face the following investment risks. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 16 C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity Investments: Equity investments generally refer to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed Income Investments: Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset- backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 17 differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange- traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 18 Alternative Investments: Investments classified as "alternative investments" may include a broad range of underlying assets including, but not limited to, hedge funds, managed futures funds, long-short equity funds, private equity, venture capital, and registered, publicly traded securities. Alternative investments are speculative, not suitable for all clients and intended for only experienced and sophisticated investors who are willing to bear the high risk of the investment, which can include: loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices; lack of liquidity in that there may be no secondary market for the fund and none expected to develop; volatility of returns; potential for restrictions on transferring interest in the fund; potential lack of diversification and resulting higher risk due to concentration of trading authority with a single advisor; absence of information regarding valuations and pricing; potential for delays in tax reporting; less regulation and typically higher fees than other investment options such as mutual funds. The SEC may require investors be accredited to invest in these more speculative alternative investments. Investing in a fund that concentrates its investments in a few holdings may involve heightened risk and result in greater price volatility. Non-U.S. Securities: Non-U.S. Securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. D. Other Risks Asset Class Risk: The asset classes included in your portfolio may underperform in comparison to the market in general. Fund Manager Risk: Mutual fund managers may underperform within their respective asset classes. Market Risk: Investment in equity securities may be more volatile than other types of investments. Although the portfolios hold thousands of equity securities, a number of them (especially smaller companies) may become worthless. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 19 Liquidity Risk: There are numerous market trading risks, including the potential lack of an active market for investments held in your portfolio. Management Risk: The performance of client portfolios is subject to the risk that our investment strategy may not produce the intended results. Passive Investment Risk: We use passively managed portfolios which do not attempt to take defensive positions in declining markets. Leverage and Derivatives Risk: Within the funds, fund managers may enter into certain transactions that might include leverage or borrowing. They may also use derivatives which can create leverage. The use of leverage may cause a portfolio to liquidate account positions when it may not be advantageous to do so. Derivatives such as futures, options, and swap agreements can also lead to losses, particularly when derivatives are used to enhance return rather that offset risk. Regulatory Risk: The legal, tax, and regulatory environment worldwide in the financial industry is evolving. Changes in regulations affecting the financial industry, including Wilon, may have an adverse effect on our ability to pursue the investment strategies described above or the value of client portfolios. New laws and regulations or actions taken by regulators that restrict our ability to pursue our investment strategies or conduct business could adversely affect client portfolios. Legacy Holdings Risk: Securities that are brought to Wilon which are not subsequently sold and diversified fully into our models carry the potential for greater concentration and issuer risk that may result in greater volatility and a higher risk of loss than a fully diversified portfolio. Extraordinary Events: Global terrorist activity, including chemical, nuclear, and biological attacks, may negatively affect economic conditions, including sales, profits and productions of goods or services, and may materially affect prices or impair our trading facilities and infrastructure or the trading facilities and infrastructure of our custodians, or the exchanges on which securities are traded. Cybersecurity Risk: Being in the financial services industry, we acknowledge that cybersecurity risks exist for our firm. We are certainly mindful of them, focusing our efforts on maintaining and improving our policies and procedures in this area, striving to mitigate our risks. We also review our service providers’ policies and procedures regarding prevention and mitigation of their cybersecurity risks. Even with all best efforts of prevention and mitigation, a cyberattack or other unauthorized access could be directed at Wilon or one of our service providers, and thus there is a potential risk of loss. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 20 Artificial Intelligence and Machine Learning: Certain service providers utilized by the Firm to service client accounts have artificial intelligence components, such as our client relationship management system that utilizes artificial intelligence to summarize client meeting notes. The use of artificial intelligence and machine learning includes increased risk of data inaccuracies and security vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our clients, our Firm performs periodic due diligence of our service providers for assurance that the service providers have appropriate controls in place to protect our clients’ information and to limit data inaccuracies when artificial intelligence is used by the service provider. This is not intended to be an all-inclusive list of risks. Each client should review the fund prospectus for the specific risks related to each fund that is held in the client’s account. Item 9. Disciplinary Information There are no legal or disciplinary events that are related to Wilon’s business or the integrity of their management. Item 10. Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative As registered representatives of Purshe Kaplan Sterling Investments, Matthew Onstot, Jason Wiltse, and Connor Peck accept compensation for the sale of securities. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 21 B. Registration as a Futures Commission Merchant, Commodity Pool Operator or a Commodity Trading Advisor Neither Wilon nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Wilon’s Investment Advisor Representatives are registered representatives of Purshe Kaplan Sterling Investments and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment advisor. Wilon always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of Wilon in such individual’s capacity as a registered representative. Some of Wilon’s Investment Advisor Representatives are independent licensed insurance agents, and from time to time, will offer clients advice or products from those activities. The issuing insurance companies are not affiliated with Wilon. However, sometimes the fixed insurance product could be used as a replacement or alternative to the Wilon fixed income portion of a portfolio. Annuity products present their own differences from traditional fixed income securities, such as bonds, including, but not limited to liquidity, tax implications, and underlying fees. Unlike bonds, there is no secondary market for annuity products. Annuities also may be subject to caps, restrictions, fees and surrender charges as described in the annuity contract. Any annuity guarantees are backed by the financial strength and claims paying ability of issuer. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment advisor. Wilon always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of Wilon in connection with such individual's activities outside of Wilon. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 22 D. Selection of Other Advisors or Managers and How This Advisor is Compensated for Those Selections Wilon has discretion to choose third-party investment advisors to manage all or a portion of the client's assets. Clients will pay Wilon its standard fee in addition to the standard fee for the advisors to which it directs those clients. This relationship will be memorialized in each contract between Wilon and each third-party advisor. The fees will not exceed any limit imposed by any regulatory agency. Wilon will always act in the best interests of the client, including when determining which third-party investment advisor to recommend to clients. Wilon will ensure that all recommended advisors are licensed, or notice filed in the states in which Wilon is recommending them to clients. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Wilon has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Wilon's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests Wilon does not recommend that clients buy or sell any security in which a related person to Wilon or Wilon has a material financial interest. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 23 C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of Wilon may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of Wilon to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. Wilon will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 24 D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of Wilon may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of Wilon to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, Wilon will never engage in trading that operates to the client’s disadvantage if representatives of Wilon buy or sell securities at or around the same time as clients. Item 12. Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on Wilon’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and Wilon may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in Wilon's research efforts. Wilon will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. Wilon primarily recommends that clients use SEI Private Trust company as their custodian. Wilon may also recommend other custodians for certain types of securities. 1. Research and Other Soft-Dollar Benefits While Wilon has no formal soft dollars program in which soft dollars are used to pay for third party services, Wilon may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). Wilon may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 25 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and Wilon does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. Wilon benefits by not having to produce or pay for the research, products or services, and Wilon will have an incentive to recommend a broker- dealer based on receiving research or services. 2. Brokerage for Client Referrals Wilon receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use Wilon may require clients to use a specific broker-dealer to execute transactions. Not all advisors require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts Our trading policy is to implement all client orders on an individual basis. Therefore, we do not aggregate or “block” client transactions. Considering the types of investments we make in client accounts, we do not believe clients are hindered because we trade accounts individually. This is because we develop individualized investment strategies for clients and holdings will vary. Further, the investments we are responsible for trading in client accounts are typically limited to broadly traded positions and minor differences in price execution are not material to our overall investment strategy. Wilon will place all trades in the account electronically or by phone. Wilon assumes responsibility for any account losses for trading errors directly resulting from the Advisors failure to follow it trading procedures or a lapse in Advisor’s internal communication and will compensate Client for any corresponding losses. Client acknowledges, however, that Wilon will not be responsible for account errors or losses that occur when Wilon has used its best efforts to execute trades in a timely and 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 26 efficient manner. If trade or some portion of a trade is not affected or an electronic error occurs through no fault of Wilon, resulting in an account not being traded at the time or price initially intended or at the same time or at the same price as other clients, the resulting loss will not be considered a trading error for which Wilon is responsible. Wilon will not be responsible for trades that are not properly executed by any clearing firm, custodian, mutual fund, or insurance company, when Wilon properly submitted order. If Wilon makes a trade error that results in a gain to Client, the client will retain the gain. Item 13. Review of Accounts If Wilon prepares a written financial plan for a client, the plan is reviewed periodically as agreed upon with the client. Typically, financial plans are reviewed at least annually. Reviews may be conducted by any licensed employee of Wilon. Wilon reviews investment allocations at least annually. More frequent reviews may be provided upon request by a client or in the event of unusual market activity. At least annually, Wilon will attempt to contact each client to determine whether there have been any changes in the client's financial situation or investment objectives. At this time, Wilon will also attempt to determine whether the client wishes to impose reasonable restrictions on the management of the account or modify an existing restriction. Clients should notify Wilon if there have been any changes in the client’s financial situation or the way in which the client’s portfolio should be managed. Investment advisor representatives, who are knowledgeable about its management style, are available at Wilon’s office or by telephone on a reasonable basis to meet with the client at the client's request. Each client of Wilon’s advisory services is provided report detailing the client’s account(s) at least quarterly, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Wilon occasionally provides clients with newsletters and commentary containing general discussions of current market conditions. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 27 Item 14. Client Referrals and Other Compensation Wilon does not receive any economic benefit, directly or indirectly from any third party for advice rendered to Wilon's clients. Wilon currently has in place an arrangement with Steve Campbell for a solicitor fee of 30% of the net from clients he has referred to Wilon. All such referral activities are conducted in accordance with Rule 206(4)-3 under the Advisers Act, where applicable. Wilon has access to a variety of economic benefits, services, and products in connection with Wilon’s use of SEI’s investment advisor platform. The terms and availability of these benefits vary among advisors on the SEI platform (including Wilon) depending on the business conducted with SEI and other factors. These services generally help Wilon conduct its advisory business, but each specific benefit does not necessarily benefit each client. Beyond access to SEI investment products, these include conferences, seminars and other educational and networking activities, business entertainment, reimbursement of travel and attendance expenses, research and other investment support services (such as client proposal and other financial planning support), technical and operational solutions (including the SEI Wealth Platform), marketing assistance (including joint marketing designed to promote SEI investment products), compliance services, human resources consulting, risk management/insurance assistance, front office, middle office, back office and other administrative support (including providing clerical staff to assist in the completion of required paperwork), SEI attendance at client meetings, information technology services, continuity and succession planning, access to financing and banking options, trust services, portfolio reporting, automatic rebalancing, tax loss harvesting, waiver or payment of certain fees (including paying account transfer fees or other charges that Wilon or its clients would incur when changing service providers), vendor discounts, discount pricing on SEI services, and broader practice management consulting. These benefits may be provided via SEI, its affiliates, or third parties and may be made available to Wilon at no fee, at a discounted fee, or via financial compensation provided by SEI. Some of these offerings depend on Wilon conducting a minimum amount or type of current or expected future business with SEI, or having a minimum account size or amount of assets under management with SEI or invested in SEI investment products. Certain of these services or products, including those provided by or paid for by SEI, may be used by Wilon in connection with its general business activities, in addition to supporting Wilon’s interaction with 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 28 SEI systems. The benefits, services, products, or payments discussed herein may be significant to Wilon and create an incentive for the Wilon to utilize SEI services or investment products for its customers rather than other service providers or investment products. However, Wilon strives at all times to put the interests of its clients first, including when selecting custodians or investment products for clients. Wilon is independently owned and operated; it is not affiliated with SEI. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, Wilon will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion Wilon provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, Wilon generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, Wilon’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to Wilon. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 29 Item 17: Voting Client Securities (Proxy Voting) Wilon will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information Wilon neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. Neither Wilon nor its management has any financial condition that is likely to reasonably impair Wilon ability to meet contractual commitments to clients. Wilon has not been the subject of a bankruptcy petition at any time. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com  PAGE 30 Privacy Policy Notice We are committed to building relationships with our clients based on trust and confidence. An important part of that relationship includes maintaining the confidentiality of our clients’ nonpublic personal information. Wilon follows the policy below regarding the collection and protection of your personal information. Wilon will collect information about you for business purposes, such as evaluating your financial needs, processing your requests and transactions, and providing you quality service. The personal information we collect includes: Information you provide to us on applications, questionnaires and other forms (such as your name, address, social security number, occupation, assets, banking information, and income) Brokerage statements, mutual fund statements, or other information you authorize us to receive Information that we generate to service your account (such as trade tickets and account statements). In accordance with Regulation S-P, we will not disclose any non-public personal information to any non-affiliated third parties, except in the following circumstances: As necessary to provide the service that you have requested or authorized, or to maintain and service your account. As required by regulatory authorities or law enforcement officials who have jurisdiction over us. To the extent reasonably necessary to prevent fraud and unauthorized transactions. We restrict access to non-public personal information about you to only those employees and service providers who need to know that information to provide products or services to you. Firm employees are subject to a strict employment policy as well as our Code of Ethics regarding confidentiality. All other persons are restricted from accessing that information. We maintain physical, electronic, and procedural safeguards that comply with federal standards and Regulation S-P to guard your non-public personal information. We respect and value that you have entrusted us with your private financial information. Wilon is committed to preserving that trust by protecting and respecting the privacy of all our clients to the best of our ability. We will not disclose your non-public personal information unless it is required by law, with your direct consent, or as necessary to provide you with our services. We have not and will not sell your personal information to anyone, even if our formal client relationship ends. Our Firm provides a copy of its Privacy Policy to Clients at the time of account opening, upon request, and annually if the Policy is amended. 2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com