Overview

Average Client Assets
$3.6 million
Minimum Account Size
$250,000
SEC CRD Number
134076

Fee Structure

Primary Fee Schedule (DISCLOSURE DOCUMENT FOR ALL CLIENTS)

MinMaxMarginal Fee Rate
$0 $500,000 1.20%
$500,001 $1,000,000 1.10%
$1,000,001 and above 1.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $11,500 1.15%
$5 million $51,500 1.03%
$10 million $101,500 1.02%
$50 million $501,500 1.00%
$100 million $1,001,500 1.00%

Clients

HNW Share of Firm Assets
84.73%
Total Client Accounts
467
Discretionary Accounts
467

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Regulatory Filings

Primary Brochure: DISCLOSURE DOCUMENT FOR ALL CLIENTS (2026-03-02)

View Document Text
ITEM 1: COVER SHEET Disclosure Document Prepared: January 21, 2026 This brochure provides information about the qualifications and business practices of Wilson & Boucher Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at the telephone number above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Our e-mail for regulatory compliance is cco@wilsonboucher.com. Wilson & Boucher Capital Management, LLC is a registered investment advisor. Registration of an investment advisor does not imply any level of skill or training. The verbal and written communications of an investment adviser provide you with information you need to determine whether to hire or retain the advisor. Additional information about Wilson & Boucher Capital Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. ITEM 2 MATERIAL CHANGES Our previous annual update was dated January 9, 2025. Following is a summary of the material changes made to Part 2 since that amendment. Item 4: As of December 31, 2025, we manage assets of $280.4 million on a discretionary basis. Please contact us at (800) 381-8610 or by e-mail if you would like a copy of our updated Part 2. Additional information about us is also available on the SEC’s website at www.adviserinfo.sec.gov. ITEM 3 TABLE OF CONTENTS Item 1: Cover Sheet Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business ........................................................................................................................... 1 Who we are ............................................................................................................................................... 1 Services we offer....................................................................................................................................... 1 Assets under management......................................................................................................................... 1 Item 5: Fees and Compensation ................................................................................................................... 1 Investment Management Services............................................................................................................. 1 Financial Planning..................................................................................................................................... 2 Other Costs Involved ................................................................................................................................ 2 Item 6: Performance-Based Fees and Side-By-Side Management .............................................................. 3 Item 7: Types of Clients............................................................................................................................... 3 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss........................................................ 3 Item 9: Disciplinary Information ................................................................................................................. 4 Item 10: Other Financial Industry Activities and Affiliations ..................................................................... 4 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 4 Code of Ethics........................................................................................................................................... 4 Personal Trading for Associated Persons.................................................................................................. 5 Item 12: Brokerage Practices ....................................................................................................................... 5 The Custodian and Brokers We Use ......................................................................................................... 5 How We Select Brokers/Custodians ......................................................................................................... 5 Your Brokerage and Custody Costs.......................................................................................................... 6 Products and Services Available to Us From Schwab .............................................................................. 6 Our Interest in Schwab's Services............................................................................................................. 7 Aggregation of Orders .............................................................................................................................. 7 Soft Dollars ............................................................................................................................................... 8 Item 13: Review of Accounts....................................................................................................................... 8 Investment Management ........................................................................................................................... 8 Financial Planning..................................................................................................................................... 8 Item 14: Client Referrals and Other Compensation..................................................................................... 8 Other Compensation ................................................................................................................................. 8 Client Referrals ......................................................................................................................................... 8 Item 15: Custody.......................................................................................................................................... 9 Item 16: Investment Discretion.................................................................................................................... 9 Item 17: Voting Client Securities................................................................................................................. 9 Item 18: Financial Information .................................................................................................................. 10 ITEM 4: ADVISORY BUSINESS Who we are Wilson & Boucher Capital Management, LLC (referred to as “we,” “our,” “us,” or “Wilson & Boucher”), has been registered as an investment advisor since February 2005. Our principals are James Boucher and Benjamin Wilson. Services we offer For financial planning, the topics reviewed include assets, liabilities, cash flow, estate planning, income, expenses, retirement planning, life expectancy, and taxes. We offer general investment advice to our clients. This includes asset allocation, stock selection, and ongoing portfolio review. Investment portfolios are designed to meet your specific risk tolerance, time horizon, liquidity needs and investment objectives. Generally, this is done by gathering detailed information from each client and carefully monitoring each portfolio's asset allocation. You may place restrictions on the types of investments that we make in your account. We do not provide portfolio management services to a wrap fee program. Assets under management As of December 31, 2025, we manage assets of $280.4 million on a discretionary basis. We do not manage assets on a non-discretionary basis. ITEM 5: FEES AND COMPENSATION Investment Management Services Fees for investment management services are calculated as a percentage of assets under management. These fees are billed quarterly in advance, based on the assets under management as of the last day of the previous calendar quarter. Our standard fee schedule is: Account Value Annual Fee On the first $500,000 On the next $500,000 Assets over $1,000,000 1.20% 1.10% 1.00% Fees are negotiated based on the size and complexity of the portfolio to be managed. The firm typically includes cash for purposes of determining the assets under management to be billed. Additionally, fees are generally not prorated upon inception of the Agreement. In other words, we wait until the beginning of the new quarter to bill the client for assets under management and do not prorate any services if the advisory agreement is executed during the quarter. Page 1 You may provide authorization for us to deduct our fees directly from your investment account. Important information about the deduction of management fees:  You provide authorization for us to pull fees when you sign our client contract.  You will receive a detailed invoice each quarter which outlines our fees and how they are calculated at the same time we request payment from the custodian.  You will receive a statement from your custodian which shows your all transactions in your account, including the deduction of our fees.  You are responsible for reviewing the accuracy of the fees being billed, as the custodian will not do so. You may elect to pay by check rather than having us deduct payment directly from your account. If you would like to end our advisory relationship, you may do so by providing 30 days written notice. We will prorate the advisory fees received through the termination date and send you a refund of the prepaid, unearned portion of your fee. We process refund payments at the end of each month and will send you a check or refund your investment account. In either case we will provide a final invoice detailing the calculation of the refund. Financial Planning Financial planning services are provided for an hourly fee of $200. As an alternative, we may negotiate a flat fee. Generally the flat fee will range from $1,000 - $2,000. We request that you pay a deposit of 20% of the estimated fee when you engage us to provide services. You will receive a final invoice upon completion of the financial plan that is payable upon receipt. You may pay for financial planning services by check. The complexity of the plan is used to help negotiate financial planning fees. You may cancel our financial planning agreement at any time by providing written notice. Upon cancellation, we will present you with an invoice for time spent. We will provide a refund if the deposit is greater than the invoice amount. If additional fees are due from you, payment is due upon receipt of the invoice. We have a conflict of interest. When you implement the financial plan through us, we receive the customary fees as disclosed in the following section. You are not required to employ us to implement the financial plan, or implement the plan, or any portion of it, at all. Other Costs Involved In addition to our advisory fee shown above, you are responsible for paying fees associated with investing for your account. These fees include:  mutual fund loads (if applicable). These charges are paid to brokers as a form of commission.  management fees for ETFs and mutual funds. These are fees charged by the managers of the ETF or mutual fund and are a portion of the expenses of the ETF or mutual fund. Page 2  brokerage costs and transaction fees for any securities trades. These are generally charged by your custodian and/or executing broker.  bid-ask spread for fixed income transactions. Additional information about brokerage costs and what is provided by brokers can be found in “Item 12: Brokerage Practices.” We do not receive compensation for the sale of securities or other investment products. We believe the fees mentioned above are competitive; however you may be able to obtain similar services from other sources at a lower price. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not receive performance fees for managing accounts. ITEM 7: TYPES OF CLIENTS Generally, we provide advice to individuals, trusts and pension plans. Generally, we require that you maintain $250,000 under management with us. However, we may waive that minimum at our sole discretion. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Clients complete a detailed questionnaire which becomes the basis for constructing an investment portfolio specific to their particular needs. We use independent research to assess investment strategies and investments such as common stock, exchange traded funds, mutual funds, fixed income, etc. We generally do not engage in active trading strategies. For normal equity investing, the volatility of the market causes the value of equity securities to move higher and lower. Equity investing also involves the possible loss of principal. Fixed income securities are subject to default and interest rate risks. We manage fixed income interest rate risk by developing laddered maturities with individual bond and/or CD holdings. Investing in digital assets like bitcoin or ethereum, e.g., whether directly through an exchange or indirectly through another product, involves the general risks of investing in other investment vehicles. In addition, the value of digital assets are subject to significant fluctuations, can be highly volatile, and can change dramatically even intra-day. The price of digital assets could drop precipitously for a variety of reasons, including, but not limited to, a crisis of confidence in the network or a change in user preference to competing assets. Digital assets represent an emerging asset class. As a result, the market infrastructure through which it is exchanged and the regulatory foundation upon which it is regulated are still in their respective infancy when compared to more traditional assets like stocks, bonds, mutual funds, ETFs, or similar. Digital assets are not protected by the Federal Deposit Insurance Corporation or the Securities Investor Protection Page 3 Corporation. Any exposure to digital assets can result in substantial losses and bitcoin investors should be able to withstand significant if not complete loss of invested capital. Digital assets facilitate decentralized, peer-to-peer financial exchange and value storage that is used like money, without the oversight of a central authority or banks. The value of digital assets are wholly derived from their monetary premium and is not backed by any government, corporation, other identified body, or other physical assets. The exchange and availability of digital assets are dependent on the availability and proper functioning of the internet, the electronic platforms storing such digital assets, and the owner’s control and possession of any needed password or digital key. Any downtime, unavailability, cybersecurity breach, or loss of access is a risk that a digital asset investor should be prepared to bear. The loss, destruction, or compromise of a private key may result in a loss of the digital assets, typographical errors may lead to loss of the digital assets, and digital asset trade errors cannot be unwound. Accordingly, the indirect exposure to digital assets through securities of publicly listed companies is also susceptible to these risks. All investments involve different degrees of risk. You should be aware of your risk tolerance level and financial situations at all times. We cannot guarantee the successful performance of an investment and we are expressly prohibited from guaranteeing accounts against losses arising from market conditions. ITEM 9: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of the investment advisor and each investment advisor representative providing investment advice to you. We have no information of this type to report. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS As a registered investment advisor, we are required to disclose when we, or any of our principals, have any other financial industry affiliations. Neither Wilson & Boucher nor any of our principals have outside financial industry affiliations. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics We have adopted a set of enforceable guidelines (Code of Ethics), which describes unacceptable conduct by Wilson & Boucher and our associated persons. Summarized, this Code of Ethics prohibits us from: placing our interests before yours,  using non public information gathered when providing services to you for our own gains, or   engaging in any act, practice or course of business that is, or might be considered, fraudulent, deceptive, manipulative, or in violation of any applicable law, rule or regulation of a governmental agency. Please contact us if you would like to receive a full copy of this Code of Ethics. Page 4 Personal Trading for Associated Persons We may buy or sell some of same securities for you that we already hold in our personal account. We may also buy for our personal account some of the same securities that you already hold in your account. It is our policy not to permit our associated persons (or their immediate relatives) to trade in a way that takes advantage of price movements caused by your transactions. We may restrict trading for a particular security for our accounts or those of our associated person if there is a pending trade in that security in a client account. Trades for our accounts (and those of our associated persons) will be placed as part of a block trade with client trades, or individually after client trades have been completed. Additional information about block trades is provided in “Item 12: Brokerage Practices.” When our trades are placed after our client trades, we may receive a better or worse price than that received by the client. All persons associated with us are required to report all personal securities transactions to us quarterly. ITEM 12: BROKERAGE PRACTICES The Custodian and Brokers We Use We do not maintain custody of your assets that we manage, although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see “Item 15: Custody”). Your assets must be maintained in an account at a “qualified custodian,” generally a broker/dealer or bank. We recommend the retention of Charles Schwab & Co., Inc. (“Schwab”), a registered broker/dealer, member SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as your custodian/broker, you will decide whether to do so and will open your account by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. If you do not wish to place your assets with Schwab, then we cannot manage your account. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor. How We Select Brokers/Custodians We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others:  Combination of transaction execution services and asset custody services (generally without a separate fee for custody)  Capability to execute, clear, and settle trades (buy and sell securities for your account)  Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) Page 5  Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.)  Availability of investment research and tools that assist us in making investment decisions  Quality of services  Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices  Reputation, financial strength, and stability Prior service to us and our other clients   Availability of other products and services that benefit us, as discussed below (see “Products and Services Available to Us From Schwab”) Your Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How We Select Brokers/Custodians”). Products and Services Available to Us From Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage— trading, custody, reporting, and related services—many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services generally are available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:  Provide access to client account data (such as duplicate trade confirmations and account statements) Facilitate trade execution and allocate aggregated trade orders for multiple client accounts  Page 6 Provide pricing and other market data  Facilitate payment of our fees from our clients’ accounts   Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include:  Educational conferences and events  Consulting on technology, compliance, legal, and business needs Publications and conferences on practice management and business succession   Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. We use a variety of services from Schwab including security research sources, trading fee processing, educational conferences and client servicing. Our Interest in Schwab's Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our [selection/recommendation] of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select Brokers/Custodians”) and not Schwab’s services that benefit only us. Aggregation of Orders There are occasions on which portfolio transactions will be executed as part of concurrent authorizations to purchase or sell the same security for another client or one or more of our associated persons. We may choose to block (aggregate) trades for your account with those of other client accounts and personal accounts of persons associated with Wilson & Boucher. When we place a block trade, all participants included in the block receive the same price per share on the trade. The price is calculated by averaging the price of all of the shares traded. Due to the averaging of price over all of the participating accounts, aggregated trades could be either advantageous or disadvantageous. Commission costs are not averaged. You will pay the same commission whether your trade is placed as part of a block or on an individual basis. The objective of the aggregated orders will be to allocate the executions in a manner that is deemed equitable to the accounts involved. Page 7 Soft Dollars The receipt of goods and/or services from the required custodian in connection with providing advice to clients is seen by the regulators as “soft dollars.” The additional services we receive from Schwab, as disclosed in the section entitled “Products and Services Available to Us From Schwab” above, would fall under this description of soft dollars. ITEM 13: REVIEW OF ACCOUNTS Investment Management Jim Boucher, Portfolio Manager and Ben Wilson, Portfolio Manager continuously review investment portfolios. Asset allocations are reviewed and adjusted, as needed, for each account. We provide written quarterly reports to you. These reports contain the following information:  Cover letter about current issues Portfolio Appraisal  Portfolio Performance Summary   Client Billing Statement On an annual basis we also provide either this Part 2 or a statement of the material changes since the last filing of the Part 2. Financial Planning Financial plans are reviewed at client request. We recommend that you have a review done at least annually. Reviews are performed by Jim Boucher, Portfolio Manager and Ben Wilson, Portfolio Manager. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Other Compensation We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the referral arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12: Brokerage Practices”). Client Referrals We do not directly or indirectly compensate anyone for client referrals. Page 8 ITEM 15: CUSTODY If you give us authority to deduct our fees directly from your separately managed account, we have custody of those assets. In order to avoid additional regulatory requirements in these cases, we follow the procedures outlined in “Item 5: Fees and Compensation.” You will also receive quarterly statements directly from custodian of the account that details all transactions in the account. They will be sent to the email or postal mailing address you provided to the custodian. You should carefully review those statements promptly when you receive them. For accounts where the client has a standing letter of authorization that allows us to transfer money between accounts specified by the client, we are also deemed to have custody. We follow the guidance outlined in the Investment Adviser Association no- action letter dated February 21, 2017, for these accounts. A copy of this letter is available upon request. At no time do we accept physical custody of your assets. ITEM 16: INVESTMENT DISCRETION As one of the conditions of managing your account, you are required to provide discretionary authority for us to manage your assets. Discretionary authority means that you are giving us a limited power of attorney to place trades on your behalf. This limited power of attorney does not allow us to withdraw money from your account, other than advisory fees if you agree to give us that authority. You grant us discretionary authority by completing the following items:  Sign a contract with us that provides a limited power of attorney for us to place trades on your behalf. Any limitations to the trading authorization will be added to this agreement.  Provide us with discretionary authority on the new account forms that are submitted to the broker/dealer acting as custodian for your account(s). You may place restrictions on the types of securities we trade for your account. Restrictions could include:  instructions to hold specific securities. This might occur when the client has a large unrealized capital gain position or restrictions placed on company stock;; instructions to avoid trading in securities that might fall into industries (i.e., tobacco stocks); or  any other instructions or limitations that are consistent with our investment universe.  ITEM 17: VOTING CLIENT SECURITIES As a matter of policy and as a fiduciary to our clients, we have responsibility for voting proxies for your portfolio securities consistent with your best economic interests. We maintain written policies and procedures as to the handling, research, voting and reporting of proxy voting and make appropriate disclosures about our proxy policies and practices. Our policy and practice includes the responsibility to monitor corporate actions, receive and vote client proxies and disclose any potential conflicts of interest as well as making information available to clients about the voting of proxies for their portfolio securities and maintaining relevant and required records. You may provide direction regarding any particular proxy solicitation. Page 9 You may elect to retain the authority to vote the proxies yourself. In this case you will receive proxies and other related paperwork directly from your custodian. We will provide guidance about how to vote a particular proxy solicitation only upon request. ITEM 18: FINANCIAL INFORMATION We do not charge or solicit pre-payment of more than $1,200 in fees per client six months or more in advance. We have never filed for bankruptcy and are not aware of any financial conditions that are reasonably likely to impair our ability to meet our contractual obligations to clients. Page 10 BROCHURE SUPPLEMENT ITEM 1: COVER SHEET James B. Boucher Wilson & Boucher Capital Management, LLC 1480 Moraga Road, #C351 Moraga, CA 94556 (800) 381-8610 jim@wilsonboucher.com January 21, 2026 This Brochure Supplement provides information about James B. Boucher that supplements the Wilson & Boucher Capital Management, LLC Brochure. You should have received a copy of that Brochure. Please contact Ben Wilson, Managing Member at (800) 381-8610 or ben@wilsonboucher.com if you did not receive Wilson & Boucher Capital Management, LLC’s Brochure or if you have any questions about the content of this supplement. Additional information about James B. Boucher is available on the SEC’s website at www.adviserinfo.sec.gov. ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE James B. Boucher was born in 1961. Educational Background School Name University of California, Berkeley California State University, Hayward California State University, Hayward Degree BA MBA MPA Year 1984 1986 1987 Major(s) Rhetoric Finance Option Public Administration Employment Background 1/2005 - Present Wilson & Boucher Capital Management, LLC Managing Member. Duties include portfolio management, financial planning, investment research, compliance supervision, business development and general business administrative functions. Wilson & Boucher Capital Management, LLC Brochure Supplement James B. Boucher Employment Background (continued) 12/2006 – 5/2010 Life Force Technologies, LLC Chief Financial Officer. Budgeting, business plan development and consulting. 11/1998 – 3/2005 SDR Capital Management, Inc. Senior Portfolio Manager. Portfolio management, financial planning, investment research, business development and general business administrative functions. 6/1996 – 11/1998 The Pacific Bank, N.A. Marketing Manager and Investment Sales Division Administrative Manager. Managing the marketing functions for a niche private and mid-business bank. Also developed compliance procedures for the bank's investment sales division. 5/1987 – 6/1996 Wells Fargo Bank Vice President and Finance Manager. Budgeting, forecasting, and strategic planning. Professional Designations Certified Financial Planner (CFP) - 2006 The CFP designation is issued by the Certified Financial Planner Board of Standards, Inc. In order to receive a CFP designation, the candidate must have a bachelor’s degree or higher from an accredited college or university and have 3 years of full-time personal financial planning experience. In addition, the candidate must complete a CFP board-registered program or hold one of the following: CPA, ChFC, Chartered Life Underwriter (CLU), CFA, Ph.D. in business or economics, Doctor of Business Administration or attorney’s license. Once the designation is earned, the CFP must complete 30 hours of continuing education every 2 years. ITEM 3: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. There is no information of this type to report. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. Boucher is a Reserve Police Officer with the Walnut Creek Police Department and spends approximately 20 hours per month acting in that capacity. His duties, which are generally not performed during securities trading hours, include general law enforcement and security at public events. Beginning 10/26/2013 to current, Jim Boucher serves as the Secretary and Treasurer on the Board of Directors for Risoftdev, Inc. (a start-up technology company) located in Moraga, California and incorporated in Wyoming. He also serves as Chief Financial Officer. Limited duties include financial reporting, maintaining company minutes and records, and consulting. Page 2 Wilson & Boucher Capital Management, LLC Brochure Supplement James B. Boucher ITEM 5: ADDITIONAL COMPENSATION Mr. Boucher does not receive any economic benefit from any non-client for providing advisory services. ITEM 6: SUPERVISION Ben Wilson, Portfolio Manager, is responsible for the supervision of Mr. Boucher. His telephone number is (800) 381-8610. Page 3 BROCHURE SUPPLEMENT ITEM 1: COVER SHEET Benjamin D. Wilson Wilson & Boucher Capital Management, LLC 85 Bolinas Road, Suite 16 Fairfax, CA 94930 (800) 381-8610 ben@wilsonboucher.com January 21, 2026 This Brochure Supplement provides information about Benjamin D. Wilson that supplements the Wilson & Boucher Capital Management, LLC Brochure. You should have received a copy of that Brochure. Please contact James B. Boucher, Managing Member at (800) 381-8610 or jim@wilsonboucher.com if you did not receive Wilson & Boucher Capital Management, LLC’s Brochure or if you have any questions about the content of this supplement. Additional information about Benjamin D. Wilson is available on the SEC’s website at www.adviserinfo.sec.gov. ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Benjamin D. Wilson was born in 1970. He received an undergraduate degree in Economics from the University of California, Davis in 1992, and went on to obtain a Masters in Resource Economics from Colorado State University in 1996. Employment Background 1/2005 - Present Wilson & Boucher Capital Management, LLC Portfolio Manager. Duties include portfolio management, financial planning, investment research, business development and general business administrative functions. 10/2000 – 3/2005 SDR Capital Management, Inc. Senior Portfolio Manager. Portfolio management, financial planning, investment research, and business development. 6/1997 – 9/2000 Adventure Associates, Inc. Chief Financial Officer. Financial management, corporate training and program development. Wilson & Boucher Capital Management, LLC Brochure Supplement Benjamin D. Wilson Professional Designations Certified Financial Planner (CFP) - 2009 The CFP designation is issued by the Certified Financial Planner Board of Standards, Inc. In order to receive a CFP designation, the candidate must have a bachelor’s degree or higher from an accredited college or university and have 3 years of full-time personal financial planning experience. In addition, the candidate must complete a CFP board-registered program or hold one of the following: CPA, ChFC, Chartered Life Underwriter(CLU), CFA, Ph.D. in business or economics, Doctor of Business Administration or attorney’s license. Once the designation is earned, the CFP must complete 30 hours of continuing education every 2 years. ITEM 3: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. There is no information of this type to report. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. Wilson is not involved in any other business activities. ITEM 5: ADDITIONAL COMPENSATION Mr. Wilson does not receive any economic benefit from any non-client for providing advisory services. ITEM 6: SUPERVISION James B. Boucher, Managing Member, is responsible for the supervision of Mr. Wilson. His telephone number is (800) 381-8610. Page 2

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