Wlth Capital Management, LLC

WLTH Capital Management, LLC Form ADV Part 2A – Disclosure Brochure Effective: May 28, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of WLTH Capital Management, LLC (“WLTH Capital” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at 480-795-4475. WLTH Capital is a registered investment advisor with the U.S. Securities and Exchange Commission. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about WLTH Capital to assist you in determining whether to retain the Advisor. Additional information about WLTH Capital and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335594. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of WLTH Capital. For convenience, the Advisor has combined these documents into a single disclosure document. WLTH Capital believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. WLTH Capital encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since its initial filing on March 3rd 2025: • The Advisor has added disclosure regarding family fee calculations. Please see Item 5 for more information. • The Advisor has added services for third-party access platforms. Please see Item 4 and Item 5 for more information. • The Advisor has also started providing 3(38) retirement plan advisory services to its Clients. Please see Item 4 and Item 5 for more information. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335594. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 480-795-4475. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................................... 3 Item 4 – Advisory Services .................................................................................................................................... 4 A. Firm Information .............................................................................................................................................................. 4 B. Advisory Services Offered ............................................................................................................................................... 4 C. Client Account Management ........................................................................................................................................... 6 D. Wrap Fee Programs ........................................................................................................................................................ 6 E. Assets Under Management ............................................................................................................................................. 6 Item 5 – Fees and Compensation ......................................................................................................................... 7 A. Fees for Advisory Services.............................................................................................................................................. 7 B. Fee Billing........................................................................................................................................................................ 8 C. Other Fees and Expenses .............................................................................................................................................. 8 D. Advance Payment of Fees and Termination ................................................................................................................... 9 E. Compensation for Sales of Securities ............................................................................................................................. 9 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9 Item 7 – Types of Clients ..................................................................................................................................... 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 10 A. Methods of Analysis ...................................................................................................................................................... 10 B. Risk of Loss ................................................................................................................................................................... 10 Item 9 – Disciplinary Information ........................................................................................................................ 11 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 12 A. Code of Ethics ............................................................................................................................................................... 12 B. Personal Trading with Material Interest ......................................................................................................................... 12 C. Personal Trading in Same Securities as Clients ........................................................................................................... 12 D. Personal Trading at Same Time as Client .................................................................................................................... 12 Item 12 – Brokerage Practices ............................................................................................................................ 12 A. Recommendation of Custodian[s] ................................................................................................................................. 12 B. Aggregating and Allocating Trades ............................................................................................................................... 13 Item 13 – Review of Accounts ............................................................................................................................. 13 A. Frequency of Reviews ................................................................................................................................................... 13 B. Causes for Reviews ...................................................................................................................................................... 13 C. Review Reports ............................................................................................................................................................. 14 Item 14 – Client Referrals and Other Compensation ........................................................................................ 14 A. Compensation Received by WLTH Capital ................................................................................................................... 14 B. Compensation for Client Referrals ................................................................................................................................ 15 Item 15 – Custody ................................................................................................................................................. 15 Item 16 – Investment Discretion ......................................................................................................................... 15 Item 17 – Voting Client Securities ....................................................................................................................... 15 Item 18 – Financial Information ........................................................................................................................... 15 Form ADV Part 2B – Brochure Supplement ....................................................................................................... 17 Privacy Policy ....................................................................................................................................................... 26 WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 3  Item 4 – Advisory Services A. Firm Information WLTH Capital Management, LLC (“WLTH Capital” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Delaware. WLTH Capital was founded in March 2025 and is owned and operated by Cean Kenefick- Rogers (Managing Member and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by WLTH Capital. B. Advisory Services Offered WLTH Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, and businesses (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. WLTH Capital's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services WLTH Capital provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary management and financial planning services. WLTH Capital works closely with each Client to identify their investment goals, objectives, and risk tolerances in order to create a portfolio allocation consistent with the Client’s investment objectives. WLTH Capital will construct a portfolio primarily consisting of mutual funds and exchanged traded funds (“ETFs”). The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. WLTH Capital provides a variety of financial planning and consulting services to Clients as part of its overall wealth management service. The Advisor will prepare a written financial plan for the Client. The financial plan will cover the Client’s assets, liabilities, goals, and objectives. The financial plan will encompass one or more areas of need including but not limited to investment strategies, investment supervisory services, financial consultations, pension and profit sharing, endowments, foundations, and business accounts. WLTH Capital also provides standalone financial planning and consulting services. Financial planning or consulting may include services including but not limited to estate planning, tax planning, and investment planning. WLTH Capital may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Foundations / Legacy Program Services For Clients that do not meet the account minimum relationship size for our wealth management services, WLTH Capital offers the Foundations Program and Legacy Program. The Foundations Program is intended for young professionals accumulating assets with a goal of becoming a full-service wealth management Client. The Legacy Program is intended for retired Clients in the decumulation phase with their assets. WLTH Capital will generally manage Client portfolios in an identical manner to its wealth management services with one exception. Under these programs, WLTH Capital will consider each Client account as its own separate portfolio when making investment decisions, whereas in our wealth management services, WLTH Capital will manage all Client accounts as one portfolio and attempts to minimize the impact of tax inefficient assets by holding them in tax favorable accounts if possible. This concept is known as asset location and is only available in our wealth management services. The WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 4  Foundations/Legacy Program does not use asset location as each account is managed on its own. This can result in the Client being subjected to a less tax efficient total portfolio and Clients should consult with their tax consultant prior to determining to enroll in this offering. The availability of our human capital is managed through different pricing structures and constraints to ensure sufficient resources for all Clients. Clients in this offering may not be invited to all client service and appreciation events. Clients will receive two meetings per year with a Foundations Program or Legacy Program planning team member and have access to financial planning software. Additionally, Clients will receive the same quarterly performance report as other Clients. At no time will WLTH Capital accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Share Class Selection Policy – WLTH Capital maintains a share class selection policy that it follows in making investment recommendations and selecting investments for discretionary Client accounts. This policy is subject to periodic review and may change from time to time, without notice to Clients. Ultimately, WLTH Capital’s policy is intended to purchase the most appropriate share class available. The policy depends on a Client’s investment strategy as follows. For WLTH Capital’s aggressive strategies, when WLTH Capital initially purchases a mutual fund for a Client account, it will generally recommend and select an institutional share class when the purchase price is equal to or exceeds $10,000. It will also typically recommend and select an institutional share class for any additional investment in that same mutual fund when the additional purchase value equals or exceeds $4,000 and will typically not sell the institutional share class unless the $4,000 threshold is met. In all other instances, it will select the retail share class or other share class that does not impose transaction fees to acquire the share class. For WLTH Capital’s conservative strategies, when WLTH Capital initially purchases a mutual fund for a Client account, it will generally recommend and select an institutional share class when the purchase price is equal to or exceeds $20,000. It will also typically recommend and select an institutional share class for any additional investment in that same mutual fund when the additional purchase value equals or exceeds $4,000 and will typically not sell the institutional share class unless the $4,000 threshold is met. In all other instances, it will select the retail share class or other share class that does not impose transaction fees to acquire the share class. If a Client only has holdings in institutional share classes, then WLTH Capital would be forced to sell those holdings in the event a Client requests a distribution. Although the different share class does not impact the fund's management style or objective, the Client will incur higher annual expenses for the retail class shares (approximately 0.25% of the Client's assets in the fund). WLTH Capital has conducted analysis of a sample of its Clients’ accounts and has reason to believe that this policy reduces its Clients’ investment expenses, but there is no guarantee that this policy will result in lower investment expenses for any individual client. Participant Account Management – As part of the Advisor’s Wealth Management Services, the Advisor will use a third-party platform to facilitate the discretionary investment management of held away assets such as defined contribution plan participant accounts. The platform enables the Advisor to gain access to the Client account[s] without having access through the Client’s login credentials. The Client will be provided an electronic link that will WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 5  allow the connection of Client account[s] to the platform. The Advisor is not affiliated with the platform and does not receive any compensation from the platform. Cash Management Services The Advisor also provides standalone cash management services. In such instances, the Advisor will buy, sell, trade and/or allocate in and among cash management solutions, money market mutual funds, short-term bonds, bank products, government issued treasuries, notes, bills, and other cash or cash-like investments as appropriate based on the Client’s needs. Retirement Plan Advisory Services Plan Sponsors may engage WLTH Capital to serve as a 3(38) Fiduciary to their plan and assume investment discretion over the Plan. In such instances, the Plan Sponsor shall authorize this discretion to select and implement the Plan investment options. Services generally include: • Vendor Analysis • Employee Enrollment and Education Tracking • Investment Policy Statement (“IPS”) Support • Investment Management • Performance Reports • Ongoing Investment Recommendation and Assistance • ERISA 404(c) Assistance • Benchmarking Services Third-Party Access Platforms The Advisor may use third-party platforms to access, aggregate, or manage certain client accounts that are held away from the Advisor’s primary custodians, such as employer-sponsored retirement plans or other externally maintained accounts. These platforms allow clients to grant the Advisor authorized access to account information and, where permitted, limited account management capabilities. Access to such accounts is provided solely at the client’s direction and subject to the permissions granted by the client through the third-party platform. Recommendations to have assets managed through a third-party platform pose a conflict between the interests of the Advisor and the interests of the Client. Assets managed through a third- party platform increases the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to have the Advisor manage held-away assets by the Advisor. C. Client Account Management Prior to engaging WLTH Capital to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. WLTH Capital tailors the portfolio to align with each Client’s investment goals and objectives. While the Client may make requests or suggestions regarding the portfolio’s investment decisions, WLTH Capital may not accommodate restrictions on trading that the Advisor does not believe are in the Client’s best interest. D. Wrap Fee Programs WLTH Capital does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by WLTH Capital. E. Assets Under Management As of December 31, 2025, WLTH manages $229,766,959 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 6  Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreement with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid quarterly in advance pursuant to the terms of the wealth management agreement. Fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees are based on the following schedule: Assets Under Management ($) Annual Rate (%) Up to $1,000,000 $1,000,001 to $2,000,000 $2,000,001 to $3,000,000 $3,000,001 to $4,000,000 $4,000,001 and above 1.00% 0.80% 0.70% 0.60% 0.50% WLTH Capital requires a $10,000 annual minimum fee. The minimum fee is charged $2,500 per quarter in the event the Client’s account[s] are less than $1,000,000 in assets under management. The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by WLTH Capital will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Family Fee Calculations- The Advisor may aggregate family accounts for purposes of determining the applicable tier under the fee schedule above. The resulting rate applies to each account within the family group. For purposes of this section, a family group may include spouses or domestic partners, immediate family members, and related trusts, entities, or retirement accounts. The Advisor generally considers clients eligible for family billing where the primary relationship generates a minimum of $30,000 in annual advisory fees. Clients must provide written consent to participate in a family billing arrangement. All clients participating in a family group are subject to a minimum quarterly fee of $500. New accounts are incorporated into the family billing group at the start of the next billing cycle following approval, and accounts removed from the group revert to the standard fee schedule at the start of the next billing period. Material changes in family composition will trigger a reassessment of eligibility and a corresponding adjustment to the fee structure. If the primary client no longer meets the minimum fee threshold or terminates their relationship with the Advisor, the family billing arrangement will be reevaluated and related accounts may revert to the standard fee schedule. WLTH Capital reserves the right to approve or deny family billing arrangements, modify family composition, and apply or waive minimum fees at its discretion. Third-Party Access Platforms For assets managed through a third-party platform, the Client is not charged any additional platform fees. The Advisor bears the cost of the platform in order to service these Client assets. Advisory fees apply to assets accessed and managed through the platform as part of the Client’s assets under management, as disclosed above. Foundations / Legacy Program Services Investment advisory fees for Foundations and Legacy Program Services is 1.25% annually paid quarterly in advance. Fees are based on the market value of assets under management at the end of the prior calendar quarter. Clients with assets under management reaching $1,000,000 will be transitioned to wealth management services in the following quarter and will remain as long as the account[s] value stays above $1,000,000. Additionally, new Clients in the Foundations Program will be charged an initial $1,000 onboarding fee. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 7  The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning Services WLTH Capital offers standalone financial planning services for a fixed engagement fee ranging up to $10,000 per engagement. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total costs will be determined prior to engaging for these services. Cash Management Services Cash management fees are 0.10% annually paid quarterly in advance pursuant to the terms of the cash management agreement. Cash management fees are based on the market value of assets under management at the end of the prior calendar quarter. The cash management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by WLTH Capital will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Retirement Plan Advisory Services Fees Fees for retirement plan advisory services are charged an annual asset-based fee of up to 0.3% billed advance, pursuant to the terms of the agreement. Retirement plan fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees may be negotiable depending on the size and complexity of the Plan. B. Fee Billing Wealth Management Services / Foundations / Legacy Program / Cash Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with WLTH Capital at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by WLTH Capital to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Clients who have engaged the Advisor for investment advisory services may make additions to and withdrawals from account[s] at any time. However, reconciliations are performed if, on any given day, assets in excess of $10,000 are deposited into or withdrawn from an account after the start of the quarterly billing period. An adjustment will be made in the form of a credit or debit the following billing period to reflect the interim change in portfolio value from the date of the deposit/withdrawal until the end of the quarter. Financial Planning Services Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. Retirement Plan Advisory Services Fees WLTH Capital is compensated for its services at the beginning of the quarter before advisory services are rendered. Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than WLTH Capital, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 8  execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by WLTH Capital are separate and distinct from these custody and execution fees. In addition, all fees paid to WLTH Capital for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of WLTH Capital, but would not receive the services provided by WLTH Capital which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by WLTH Capital to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services / Foundations / Legacy Program / Cash Management Services WLTH Capital may be compensated for its services in advance of the quarter in which services are rendered. Either party may terminate the agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services WLTH Capital requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non- transferable without the Client’s prior consent. Retirement Plan Advisory Services Fees Either party may request to terminate their services with WLTH Capital in whole or in part, by providing advance written notice to the other party. The Client shall be responsible for investment advisory fees up to and including the effective date of termination. [OR if Advance] The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan services agreement with the Advisor is non-transferable without the Client’s written approval. E. Compensation for Sales of Securities WLTH Capital does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management WLTH Capital does not charge performance-based fees for its investment advisory services. The fees charged by WLTH Capital are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. WLTH Capital does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 9  Item 7 – Types of Clients WLTH Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, and businesses. WLTH Capital generally requires a minimum annual fee of $10,000 to effectively implement its wealth management services. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis WLTH Capital primarily employs a fundamental analysis method in developing investment strategies for its Clients. Research and analysis from WLTH Capital are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. WLTH Capital generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. WLTH Capital will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, WLTH Capital may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. WLTH Capital will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 10  The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving WLTH Capital or management person. WLTH Capital values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335594. Item 10 – Other Financial Industry Activities and Affiliations A. Broker-Dealer Affiliation Neither the Advisor nor management person[s] have any active or pending registrations or affiliations with a broker- dealer. B. Futures Merchant Neither the Advisor nor management person[s] have any active or pending registrations or affiliations with a futures commission merchant, commodity pool operator, or commodity-trading advisor. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 11  C. Material Relationships Neither the Advisor nor management person[s] have material relationships or arrangements that are material to the Advisor’s business or to Clients. D. Selection of Other Advisors The Advisor does not utilize third party money managers. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics WLTH Capital has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with WLTH Capital (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. WLTH Capital and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of WLTH Capital’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at 480-795-4475. B. Personal Trading with Material Interest WLTH Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. WLTH Capital does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. WLTH Capital does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients WLTH Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by WLTH Capital requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While WLTH Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will WLTH Capital, or any Supervised Person of WLTH Capital, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] WLTH Capital does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize WLTH Capital to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, WLTH Capital does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 12  Where WLTH Capital does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by WLTH Capital. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. WLTH Capital may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. The Advisor will generally recommend that Clients establish their account[s] with Fidelity Clearing & Custody Solutions and related entities of Fidelity Investments, Inc. (collectively “Fidelity”) or Charles Schwab & Co., Inc. (“Schwab”), each a FINRA-registered broker-dealer and member SIPC. Fidelity or Schwab will serve as the Client’s “qualified custodian”. The Advisor maintains an institutional relationship with both Fidelity and Schwab, whereby the Advisor receives economic benefits. Please see Item 14 – Client Referrals and Other Compensation below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. WLTH Capital does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - WLTH Capital does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where WLTH Capital will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). WLTH Capital will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. WLTH Capital will execute its transactions through the Custodian as authorized by the Client. WLTH Capital may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons and periodically by the Chief Compliance Officer of WLTH Capital. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 13  changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify WLTH Capital if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by WLTH Capital WLTH Capital is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. WLTH Capital does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. WLTH Capital may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, WLTH Capital may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform - Fidelity As noted in Item 12, The Advisor has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such services, the Advisor has an incentive to continue to use or expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship with Fidelity remains in the best interests of the Advisor’s Clients in connection with its fiduciary obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software, vendors, and related support without cost or at a discount because the Advisor renders wealth management services to Clients that maintain assets at Fidelity The software and related systems support benefit the Advisor and indirectly benefit the Clients. However, all services provided may not be utilized for all Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of these economic benefits from Fidelity creates a conflict of interest as these economic benefits may influence the Advisor's recommendation of Fidelity as a Custodian over another custodian that does not furnish similar software, systems, back-office support, and/or other economic benefits. Notwithstanding the conflicts noted herein, the Advisor firmly believes that Fidelity provides the Client and the Advisor with excellent value and support. Participation in Institutional Advisor Platform - Schwab The Advisor has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like the Advisor. As a registered investment advisor participating on the Schwab Advisor Services platform, the Advisor receives access to software and related support without cost because the Advisor renders Wealth management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits can influence the Advisor's recommendation of Schwab over a custodian that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 14  Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to the Advisor that may not benefit the Client, including: educational conferences and events, start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. The Advisor believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody WLTH Capital does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct WLTH Capital to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by WLTH Capital to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion WLTH Capital generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by WLTH Capital. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by WLTH Capital will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities WLTH Capital does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither WLTH Capital, nor its management, have any adverse financial situations that would reasonably impair the ability of WLTH Capital to meet all obligations to its Clients. Neither WLTH Capital, nor any of its Advisory Persons, WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 15  have been subject to a bankruptcy or financial compromise. WLTH Capital is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 16  Form ADV Part 2B – Brochure Supplement for Cean N. Kenefick-Rogers, CFP®, CFA®, AIF®, CPWA® Principal and Chief Compliance Officer Effective: May 28, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Cean N. Kenefick-Rogers, CFP®, CFA®, AIF®, CPWA®, (CRD# 4751006) in addition to the information contained in the WLTH Capital Management, LLC (“WLTH Capital” or the “Advisor”, CRD# 335594) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the WLTH Capital Disclosure Brochure or this Brochure Supplement, please contact us at 480-795-4475. Additional information about Mr. Kenefick-Rogers is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4751006. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 17  Item 2 – Educational Background and Business Experience Cean N. Kenefick-Rogers, CFP®, CFA®, AIF®, CPWA®, born in 1980, is dedicated to advising Clients of WLTH Capital as its Principal and Chief Compliance Officer. Mr. Kenefick-Rogers earned his Bachelor’s Degree in Finance from the University of Arizona in 2003. Additional information regarding Mr. Kenefick-Rogers’s employment history is included below. Employment History: 04/2025 to Present Ironwood Wealth 05/2015 to 04/2025 Principal and Chief Compliance Officer, WLTH Capital Management, LLC Managing Member and Chief Compliance Officer, Management, LLC CERTIFIED FINANCIAL PLANNER® professional I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 18  all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. • Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Chartered Financial Analyst™ (“CFA®”) The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and awarded by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA® Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. Also, CFA® charter holders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of Professional Conduct. CFA® is a trademark owned by CFA® Institute. Accredited Investment Fiduciary™ (“AIF®”) The AIF® mark is held by the Center for Fiduciary Studies, LLC, a Fiduciary360 (fi360) company. The professional designations awarded by fi360 demonstrate the focus on all the components of a comprehensive investment process, related fiduciary standards of care, and commitment to excellence. AIF® designees undergo an initial training program, annual continuing education, and pledge to abide by the designation's code of ethics. investment Since October 2002, the Accredited Investment Fiduciary™ (AIF®) designation has been the mark of commitment to a standard of fiduciary investment excellence. Those who earn the AIF® mark successfully complete a specialized program on fiduciary standards of care and subsequently passed a comprehensive examination. AIF® designees demonstrate a thorough understanding of fi360's Prudent Practices for investment advisors and stewards. Certified Private Wealth Advisor™ (“CPWA®”) The CPWA® designation signifies that an individual has met initial and on-going experience, ethical, education, and examination requirements for the professional designation, which is centered on private wealth management topics and strategies for high-net-worth clients. Prerequisites for the CPWA® designation are: A Bachelor’s degree from an accredited college or university or one of the following designations or licenses: CIMA®, CIMC®, CFA®, CFP®, ChFC®, or CPA® license; have an acceptable regulatory history as evidenced by FINRA Form U-4 or other regulatory requirements and five years of professional client-centered experience in financial services or a related industry. CPWA® designees have completed a rigorous educational process that includes self-study requirements, an in-class education component, and successful completion of a comprehensive examination. CPWA® designees are required to adhere to IMCA’s Code of Professional Responsibility and Rules and Guidelines for the use of the Marks. CPWA® designees must report 40 hours of continuing education credits, including two ethics hours every two years to maintain the certification. The designation is administered through the Investment Management Consultants Association™ (IMCA®). Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Kenefick-Rogers. Mr. Kenefick-Rogers has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Kenefick-Rogers. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 19  extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Kenefick-Rogers. However, we do encourage you to independently view the background of Mr. Kenefick-Rogers on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4751006. Item 4 – Other Business Activities Wellington Estates Homeowner Association Treasurer Mr. Kenefick-Rogers acts as the treasurer of the Wellington Estates Homeowner Association. Mr. Kenefick-Rogers is responsible for handling the funds of the homeowner association. No compensation is received in this role. Mr. Kenefick-Rogers spends less than 5% of his time in this capacity per month. Item 5 – Additional Compensation Mr. Kenefick-Rogers is dedicated to the investment advisory activities of WLTH Capital’s Clients. Mr. Kenefick-Rogers does not receive any additional forms of compensation. Item 6 – Supervision Mr. Kenefick-Rogers serves as the Principal and Chief Compliance Officer of WLTH Capital. Mr. Kenefick-Rogers can be reached at 480-795-4475. WLTH Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of WLTH Capital. Further, WLTH Capital is subject to regulatory oversight by various agencies. These agencies require registration by WLTH Capital and its Supervised Persons. As a registered entity, WLTH Capital is subject to examinations by regulators, which may be announced or unannounced. WLTH Capital is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 20  Form ADV Part 2B – Brochure Supplement for Richard J. Spadaro Wealth Advisor Effective: May 28, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Richard J. Spadaro (CRD# 5385937) in addition to the information contained in the WLTH Capital Management, LLC (“WLTH Capital” or the “Advisor”, CRD# 335594) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the WLTH Capital Disclosure Brochure or this Brochure Supplement, please contact us at 480-795-4475. Additional information about Mr. Spadaro is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5385937. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 21  Item 2 – Educational Background and Business Experience Richard J. Spadaro, born in 1985, is dedicated to advising Clients of WLTH Capital as a Wealth Advisor. Mr. Spadaro earned an MBA from the University of Maryland in 2012. Mr. Spadaro also earned a B.S. in Finance from Drexel University in 2007. Additional information regarding Mr. Spadaro’s employment history is included below. Employment History: Wealth Advisor, WLTH Capital Management, LLC Director of Business Development, Intel Corporation 05/2025 to Present 04/2014 to 09/2024 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Spadaro. Mr. Spadaro has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Spadaro. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Spadaro. However, we do encourage you to independently view the background of Mr. Spadaro on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5385937. Item 4 – Other Business Activities Mr. Spadaro is dedicated to the investment advisory activities of WLTH Capital’s Clients. Mr. Spadaro does not have any other business activities. Item 5 – Additional Compensation Mr. Spadaro is dedicated to the investment advisory activities of WLTH Capital’s Clients. Mr. Spadaro does not receive any additional forms of compensation. Item 6 – Supervision Mr. Spadaro serves as a Wealth Advisor of WLTH Capital and is supervised by Cean Kenefick-Rogers, the Chief Compliance Officer. Mr. Kenefick-Rogers can be reached at 480-795-4475. WLTH Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of WLTH Capital. Further, WLTH Capital is subject to regulatory oversight by various agencies. These agencies require registration by WLTH Capital and its Supervised Persons. As a registered entity, WLTH Capital is subject to examinations by regulators, which may be announced or unannounced. WLTH Capital is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 22  Form ADV Part 2B – Brochure Supplement for Rodney R. Weeks, CFA® Chief Investment Officer Effective: May 28, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Rodney R. Weeks, CFA®, (CRD# 8087121) in addition to the information contained in the WLTH Capital Management, LLC (“WLTH Capital” or the “Advisor”, CRD# 335594) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the WLTH Capital Disclosure Brochure or this Brochure Supplement, please contact us at 480-795-4475. Additional information about Mr. Weeks is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 8087121. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 23  Item 2 – Educational Background and Business Experience Rodney R. Weeks, CFA®, born in 1996, is dedicated to advising Clients of WLTH Capital as the Chief Investment Officer. Mr. Weeks earned bachelor’s in Finance from the University of Arizona in 2018. Additional information regarding Mr. Weeks’s employment history is included below. Employment History: 03/2026 to Present 09/2020 to 04/2026 Chief Investment Officer, WLTH Capital Management, LLC Portfolio Administrator, Portfolio Manager, CIO, Ironwood Wealth Management, LLC Analyst, JPMorgan Chase & Co 06/2017 to 09/2020 Chartered Financial Analyst™ (“CFA®”) The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and awarded by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA® Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. Also, CFA® charter holders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of Professional Conduct. CFA® is a trademark owned by CFA® Institute. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Weeks. Mr. Weeks has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Weeks. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Weeks. However, we do encourage you to independently view the background of Mr. Weeks on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 8087121. Item 4 – Other Business Activities RWCB LLC Mr. Weeks is also a Partner of RWCB LLC, a holding entity for real estate. In this capacity, Mr. Weeks is responsible for maintenance and collecting rent payments. Mr. Weeks is compensated for this activity and spends approximately 5% of his time per month in this capacity. Item 5 – Additional Compensation Mr. Weeks has an additional business activity where compensation is received that is detailed in Item 4 above. Item 6 – Supervision Mr. Weeks serves as the Chief Investment Officer of WLTH Capital and is supervised by Cean Kenefick-Rogers, the Chief Compliance Officer. Mr. Kenefick-Rogers can be reached at 480-795-4475. WLTH Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of WLTH Capital. Further, WLTH Capital is subject to regulatory oversight by various agencies. These agencies require registration by WLTH Capital and its Supervised Persons. As a registered entity, WLTH Capital is subject to examinations by regulators, which may be announced or unannounced. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 24  WLTH Capital is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 25  Privacy Policy Effective: May 28, 2026 Our Commitment to You WLTH Capital Management, LLC (“WLTH Capital” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. WLTH Capital (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. WLTH Capital does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements questionnaires and suitability Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 26  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No to: processing No Not Shared Yes Yes Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes WLTH Capital does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where WLTH Capital or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients WLTH Capital does not disclose and does not intend to disclose, non- public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at 480-795-4475. WLTH Capital Management, LLC 25 South Arizona Place, Suite 537, Chandler, AZ 85225 Phone: 480-795-4475 * Fax: 480-795-4482 Page 27