WRIGHT WEALTH LLC

Item 1: Cover Page Wright Wealth LLC Two Ballpark Center 800 Battery Avenue SE, Suite 300 Atlanta, Georgia, 30339 (470) 607-0441 Form ADV Part 2A – Firm Brochure Dated: April 30, 2026 This Brochure provides information about the qualifications and business practices of Wright Wealth LLC. If you have any questions about the contents of this Brochure, please contact us at (678) 818-5257. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. is available on the SEC’s website at information about Wright Wealth LLC also Additional www.adviserinfo.sec.gov, which can be found using the firm’s CRD# 321215. Wright Wealth LLC is a Registered Investment Adviser. Registration does not imply any level of skill or training. 1  Item 2: Material Changes This version of our Brochure dated April 27, 2026, is an other than annual updating amendment. The last annual update of this Brochure was filed on March 31, 2026. The following are material changes to our Brochure since our last annual updating amendment: 2  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees and Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information Item 19: Requirements for State-Registered Advisers Form ADV Part 2B – Jeff Wright Form ADV Part 2B – Stephen Wade Form ADV Part 2B – Richard O Maurice Form ADV Part 2B – John Allan Duncan Form ADV Part 2B – Timothy S. Benbow 1 2 3 4 9 13 14 15 20 21 22 24 27 28 29 30 31 32 33 34 37 40 42 44 3  Item 4: Advisory Business Description of Advisory Firm Wright Wealth LLC is a Registered Investment Adviser principally located in the state of Georgia. We are a limited liability company founded in March of 2022. Wright Wealth LLC became registered in 2022. Jeff Wright, Tim Benbow, and Stephen Wade are the principal owners. As used in this brochure, the words “WW”, "We", "Firm", “Advisor” and "Us" refer to Wright Wealth LLC and the words "you", "your" and "Client" refer to you as either a client or prospective client of our firm. Types of Advisory Services WW is a fee-only firm, meaning the only compensation we receive is from our Clients for our services. We offer investment management and financial planning services. From time to time, WW recommends third-party professionals such as attorneys, accountants, tax advisors, insurance agents, or other financial professionals. Clients are never obligated to utilize any third-party professional we recommend. WW is not affiliated with nor does WW receive any compensation from third-party professionals we may recommend. Investment Management Services Our Firm provides continuous advice to a Client regarding the investment of Client funds based on the individual needs of the Client. Through personal discussions in which goals and objectives based on a Client's particular circumstances are established, we develop a Client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation targets. We will also review and discuss a Client’s prior investment history, as well as family composition and background. Account supervision is guided by the stated objectives of the Client (e.g., maximum capital appreciation, growth, income, or growth, and income), as well as risk tolerance and tax considerations. We primarily advise our Clients regarding investments in stocks, bonds, mutual funds, ETFs, U.S. government and municipal securities, and cash and cash equivalents. We may also provide advice regarding investments held in Client’s portfolio at the inception of our advisory relationship and/or other investment types not listed above, at the Client’s request. When we provide investment management services, Clients grant us limited authority to buy and sell securities on a discretionary basis. More information on our trading authority is explained in Item 16 of this Brochure. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. When appropriate, we utilize the services of third-party investment advisers (“Outside Managers”) to assist with the management of Client accounts. We assist Clients in selecting an appropriate allocation model, completing the Outside Manager’s investor profile questionnaire, interacting with the Outside Manager and reviewing the Outside Manager. Our review process and analysis of Outside Managers is further discussed in Item 8 of this Brochure. Additionally, we will meet with the Client on a periodic basis to discuss changes in their personal or financial situation, suitability, and any new or revised restrictions to be applied to the account. 4  Financial Planning Services Financial planning involves an evaluation of a Client's current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they affect and are affected by the entire financial and life situation of the Client. In general, the financial plan will address some or all of the following areas of concern. The Client and WW will work together to select specific areas to cover. These areas may include, but are not limited to, the following: ● Business Planning: We provide consulting services for Clients who currently operate their own business, are considering starting a business, or are planning for an exit from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. ● Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. ● College Savings: Includes projecting the amount that will be needed to achieve college or other post- secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if appropriate). ● Employee Benefits Optimization: We will provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals ● Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. ● Financial Goals: We will help Clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. ● Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile. ● Investment Analysis: This may involve developing an asset allocation strategy to meet Clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee 5  stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. Retirement Planning: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. Risk Management: A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self-insuring”). ● Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with the consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. Financial Planning Services are offered via an ongoing engagement. This ongoing engagement involves working one-on-one with a financial planner (“planner”) over an extended period of time. By paying an ongoing fixed fee, Clients are expected to collaborate with the planner to develop and implement their financial plan (the “plan”). The planner will monitor the plan, recommend any changes and ensure the plan is up-to-date. Upon engaging the firm for financial planning, a Client will be taken through establishing their goals and values around money. Clients will be required to provide pertinent information to help complete the following areas of analysis: net worth, cash flow, insurance, credit scores/reports, employee benefits, retirement planning, insurance, investments, college planning, and estate planning. Once the Client's information is reviewed, their plan will be built and analyzed, and then the findings, analysis and potential changes to their current situation will be reviewed with the Client. If a follow-up meeting is required, we will meet at the Client's convenience. The plan and the Client's financial situation and goals will be monitored throughout the year and follow-up phone calls and emails will be made to the Client to confirm that any agreed-upon actionable steps have been carried out. On an annual basis, there will be a full review of this plan to ensure its accuracy and ongoing appropriateness. Any needed updates will be implemented at that time. Wright Wealth Money Membership Clients may elect to enroll in WW’s Money Membership Group. Money Membership Clients receive access to the Elements® financial app and one initial client on-boarding where Money Membership Clients will provide WW 6  with details about their financial situations and goals. Additionally, Money Membership Clients will have access to newsletters provided by WW and email access to a licensed investment adviser representative provided by and through WW. Outside of the initial client on-boarding, Money Membership Clients may engage WW for additional consulting at an hourly rate. The value and usefulness of the Money Membership Group depends on the accuracy and completeness of the information provided by the Client and upon Client’s active participation in the relationship with WW. Tax Preparation Assistance Upon WW and Client’s agreement, we may provide tax preparation assistance to our Clients as part of the investment advisory services. In performing these services, WW will recommend an unaffiliated accountant for the Clients to use for tax preparation services. WW will help interface with the accountant and assist as necessary. Eligible Clients may enroll in tax preparation services by executing the Tax Preparation Addendum to the Investment Advisory Contract. It is essential that a Client provide the information and documentation we request regarding income, investments, taxes, estate plan, etc. Additionally, Clients may be required to enter into a separate agreement with the recommended unaffiliated accountant. Retirement Plan Consulting Our firm provides retirement plan services to employer plan sponsors on an ongoing basis. Generally, such services consist of assisting employer plan sponsors or plan fiduciaries in establishing, monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure, and participant education. In providing retirement plan services, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly-traded REITs), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). Certain plans and/or clients that we may provide services to are regulated under the Employee Retirement Income Securities Act of 1974 (“ERISA”). We will provide employee benefit plan services to the plan sponsor and/or fiduciaries as described above for the fees set forth in Item 5 of this brochure. The services we provide are advisory in nature. We are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we are acting as a fiduciary of the plan as defined in Section 3(21) under ERISA. Educational Seminars/Speaking Engagements We may provide seminars for groups seeking general advice on investments and other areas of personal finance. These seminars are purely educational in nature and do not involve the sale of any investment products. Information presented will not be based on any individual’s need, nor does WW provide individualized investment advice to attendees during these seminars. Client Tailored Services and Client Imposed Restrictions We tailor the delivery of our services to meet the individual needs of our Clients. We consult with Clients initially and on an ongoing basis, through the duration of their engagement with us, to determine risk tolerance, time horizon and other factors that may impact the Clients’ investment and/or planning needs. Clients are able to specify, within reason, any restrictions they would like to place as it pertains to individual securities and/or sectors that will be traded in their account. All such requests must be provided to WW in writing. WW will notify Clients if they are unable to accommodate any requests. 7  Retirement Account Advice When we provide investment advice to Clients regarding their retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Individual Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with our Clients’ interests, so we operate under a special rule that requires us to act in our Client’s best interest and not put our interest ahead of our clients. A Client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If we are asked by a Client or prospective client to make a recommendation from among these choices, we have a conflict of interest in that we have an incentive to recommend that a client roll over their retirement plan assets into an account to be managed by WW in order to earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the Client. No Client is under any obligation to roll over retirement plan assets to an account managed by WW. Wrap Fee Programs A “wrap fee program” is an investment management structure whereby the client pays a single fee for investment management and the execution of transactions in the Client’s account. We do not participate in wrap fee programs. Assets Under Management As of December 31, 2025, WW has $ 169,961,118 in Discretionary and $ 18,501,092 in Non-Discretionary assets under management. 8  Item 5: Fees and Compensation Please note, unless a Client has received this brochure at least 48 hours prior to signing an Advisory Contract, the Advisory Contract may be terminated by the Client within five (5) business days of signing the Advisory Contract without penalty. How we are paid depends on the type of advisory services we perform. Below is a brief description of our fees, however, you should review your executed Advisory Contract for more detailed information regarding the exact fees you will be paying. No increase to the agreed-upon advisory fees outlined in the Advisory Contract shall occur without prior Client consent. Please note, lower fees for comparable services may be available from other sources. Investment Management Services The Advisory Fee is based on a percentage of assets under management, but may be replaced by a negotiated fixed rate. The specific fees charged by WW for its advisory services will be outlined in each Client’s Investment Advisory Contract. The annualized fees for investment management services are based on the following fee schedule: Assets Under Management Annual Advisory Fee $0 - $2,000,000 1.00% $2,000,001- $4,000,000 0.80% $4,000,001- $6,000,000 0.60% $6,000,001- $8,000,000 0.40% $8,000,001- $10,000,000 0.25% $10,000,001+ Negotiable The annual advisory fee is based on the average daily balance of the Client’s account(s). The advisory fee is a blended tier. For example, for assets under management of $3,000,000, a Client would pay 1.00% on the first $2,000,000 and 0.80% on the remaining balance. The Advisory Fee may be paid monthly or quarterly in arrears or monthly or quarterly in advance. In determining the advisory fee, we may allow accounts of members of the same household to be aggregated. WW relies on the valuation as provided by Client’s custodian in determining assets under management. Our advisory fee is prorated for any partial billing periods occurring during the engagement, including the initial and terminating billing periods. WW reserves the right to prorate advisory fees for Client contributions and withdrawals during the billing period. If WW utilizes an Outside Manager, the above fee schedule does not include the Outside Manager’s fee. The Outside Manager’s advisory fees, billing schedule, and payment procedures are set forth in their separate written disclosure documents, advisory agreements, and/or the account opening documents of your account Custodian. At no point will the combined fee charged to the Client exceed 2% of assets under management. Financial Planning Fees We charge an ongoing fixed fee for financial planning services. Fees are paid monthly in advance or arrears, ranging from $250 to $1,500 per month. The fee range is dependent upon variables including the specific needs of the Client, complexity, estimated time, research, and resources required to provide services to you, among other factors we deem relevant. We also charge an hourly fee of $250/hour for any work that falls outside of the original scope of 9  the plan, including call time. Fees are negotiable and the final agreed upon fee will be outlined in your Financial Planning Contract. WW may collect an initial fee, no greater than $2,000. The initial fee covers the initial construction of the comprehensive financial plan. This work will commence immediately after the fee is paid, and the length of time required to complete and present the plan is dependent on several factors including the needs of the Client, the Client’s ability to provide any necessary information and documentation, as well as the complexity of their financial situation. Advisor may reduce or waive the initial fee at the Advisor’s discretion. At no time do we require prepayment of $500 or more six months or more in advance of rendering the services. Tax Preparation & Tax Planning Fees WW may provide tax preparation services to advisory Clients. The fee for tax preparation services will initially be paid by WW and then WW will invoice the Client for the tax preparation services. At WW’s discretion, WW may elect to discount or markup the fee changed by the unaffiliated accountant for the tax preparation services. At no time will any markup exceed 10%. The expected cost of tax preparation services, as well as our expected involvement in the process, will be reviewed and agreed to by the Client before engaging in the service. The fees for this service are not negotiable and are due at the end of the engagement and paid either by check or ACH. The exact terms of the relationship, including the Client’s responsibility for the fee, will be contained in the Tax Preparation Addendum to the Investment Advisory Agreement. Clients are not required to utilize any third-party products or services that we may recommend and they can receive similar services from other third party professionals at a similar or lower cost. Wright Wealth Money Membership WW may provide clients with financial health checks through its Money Membership program. The fee for such membership is $79 per month, payable monthly until terminated by WW or the membership client. Educational Seminars/Speaking Engagements Seminars and speaking engagements are offered to organizations and the public on a variety of financial topics. Fees range up to $5,000 per seminar. The fee range is based on the content, amount of research conducted, the number of hours of preparation needed, and the number of attendees. WW collects 50% of the fee to be collected in advance with the remaining half due at the conclusion of the Seminar. WW offers its services in a virtual or in- person setting. Should the event require travel arrangements, both parties must agree to the terms of travel (i.e. cost, distance, hotel arrangements) at the start of the engagement. Strategies discussed during the seminars are always offered on an impersonal basis and do not focus on the individual needs of attendees. Fee Deduction For Investment Management services, we deduct our advisory fee from one or more account(s) held at an unaffiliated third-party custodian, as directed by the Client. Please refer to Item 15 of this Brochure regarding our policy on direct fee deduction. When an Outside Manager is used, the Outside Manager will debit the Client’s account for both the Outside Manager’s fee, and WW’s advisory fee. Fees for our financial planning service may be paid by electronic funds transfer or check. For fees paid by electronic funds transfer, debit card or credit card, we use an independent third party payment processor in which the client can securely input their banking information and pay their fee. We do not have access to the client’s banking information at any time. The client will be provided with their own secure portal in order to make payments. Retirement Plan Consulting 10  The fee is based on a percentage of assets under management and is negotiable. The annualized fees for retirement plan investment consulting services are based on the following fee schedule: Assets under Management Annual Advisory Fee $0 - $1,000,000 0.50% $1,000,001 and Above 0.40% The annual advisory fee is paid monthly in arrears based on the average daily balance of the Client’s account(s). The advisory fee is a straight tier. For example, for assets under management of $2,000,000, a Client would pay 0.40%. The monthly fee is determined by the following calculation: (($2,000,000 x 0.40%)) ÷ 12 = $666.67. This does not include fees to other parties, such as record keepers, custodians, or third-party administrators. WW relies on the valuation as provided by Client’s custodian in determining assets under management. Our advisory fee is prorated for any partial billing periods occurring during the engagement, including the initial and terminating billing periods. Other Types of Fees and Expenses Clients will incur transaction charges for trades executed in their accounts. These transaction fees are separate from our Firm’s advisory fees and will be disclosed by the chosen custodian. Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as fund management fees, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, custodial fees, initial or deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange-traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. WW does not receive a portion of these fees. For more information regarding brokerage practices, see Item 12. The Client may incur fees from third-parties for third-party services that may relate to a Client’s financial plan (i.e., legal and tax fees for estate planning or tax preparation). Such fees are separate and in addition to the WW’s fees. At WW’s discretion, WW may choose to absorb these fees on a case-by-case basis. Clients may incur fees from third-party professionals such as accountants and attorneys that WW may recommend, upon Client request. Such fees are separate and distinct from WW’s advisory fees. Terminations and Refunds For Investment Management services, the Investment Advisory Contract may be terminated with written notice at least 30 calendar days in advance. Upon receipt of notice of termination, WW will commence the process of liquidating or transfer of such account. Upon completion, any prepaid, unearned fees will be promptly refunded, less any actual costs the Firm incurs upon termination, and any earned, unpaid fees will be due and payable upon termination. For Financial Planning services, the Financial Planning Contract may be terminated with written notice at least 30 calendar days in advance. Any prepaid, unearned fees will be promptly refunded, less any actual costs the Firm incurs upon termination, and any earned, unpaid fees will be due and payable upon termination. 11  Sale of Securities or Other Investment Products We do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. General Disclosures Lower fees for comparable services may be available from other sources. Material conflicts of interest disclosed to the Client in writing via this Form ADV, Part 2 could cause WW or its representatives to render bias or non- objective advice. To address these conflicts, we take into consideration the best interests of Clients. WW does not maintain custody of Client funds or securities except as described in Item 15. Clients are advised that the investment recommendations and advice offered by WW are not legal or accounting recommendations or advice. Clients should discuss the impact of financial advice with their attorney and/or accountant. Clients are advised that it is necessary to inform WW promptly with respect to any changes in the Client’s financial situation and investment goals and objectives. Failure to notify WW of any such changes could result in investment recommendations being made that are based upon inaccurate information, and thus will not meet the needs of the Client. As noted above, advisory fees are negotiable. Therefore, Clients receiving similar services may pay higher or lower fees than another Client. WW reserves the right, at WW’s discretion, to discount fees for Clients who engage WW to provide multiple advisory services. 12  Item 6: Performance-Based Fees and Side-By-Side Management Performance-Based fees are based on a share of capital gains on or capital appreciation of the Client’s assets. Side- by-side management occurs when advisers manage both accounts that are charged a performance-based fee and accounts that are charged another type of fee, such as an hourly or flat fee or an asset-based fee. We do not accept performance-based fees, nor do we engage in side-by-side management. 13  Item 7: Types of Clients We provide financial planning and investment management services to individuals, high net-worth individuals, pension and profit sharing plans, charitable organizations, and corporations or other businesses. We do not have a minimum account size requirement. 14  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Each Client’s portfolio is evaluated on a periodic basis. Below is a brief description of our methods of analysis and primary investment strategies. Methods of Analysis Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience, and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The risk of fundamental analysis is that the information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick sectors that may outperform market indices. However, there is no assurance of accurate forecasts or that trends will develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods will presumably occur in the future. Even where major trends develop, outside factors like government intervention could potentially shorten them. Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method may underperform other trading methods when fundamental factors dominate price moves within a given market. Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based upon business cycles. Economic/business cycles may not be predictable and may have many fluctuations between long-term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Charting analysis involves the gathering and processing of price and volume information for a particular security. This price and volume information is analyzed using mathematical equations. The resulting data is then applied to graphing charts, which is used to predict future price movements based on price patterns and trends. Charts may not accurately predict future price movements. Current prices of securities may not reflect all information about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Tactical analysis is an active management portfolio strategy that shifts the percentage of assets held in various categories to take advantage of market pricing anomalies or strong market sectors. This strategy allows portfolio managers to create extra value by taking advantage of certain situations in the marketplace. It is a moderately active strategy since managers return to the portfolio’s original strategic asset mix once reaching the desired short-term profits. Modern Portfolio Theory (MPT) The underlying principles of MPT are: 15  ● Investors are risk averse. The only acceptable risk is that which is adequately compensated by an expected return. Risk and investment return are related and an increase in risk requires an increased expected return. ● Markets are efficient. The same market information is available to all investors at the same time. The market prices every security fairly based upon this equal availability of information. ● ● ● The design of the portfolio as a whole is more important than the selection of any particular security. The appropriate allocation of capital among asset classes will have far more influence on long-term portfolio performance than the selection of individual securities. Investing for the long-term (preferably longer than ten years) becomes critical to investment success because it allows the long-term characteristics of the asset classes to surface. Increasing diversification of the portfolio with lower correlated asset class positions can decrease portfolio risk. Correlation is the statistical term for the extent to which two asset classes move in tandem or opposition to one another. Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in other funds in the Client’s portfolio. In addition, we monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the fund or ETF less suitable for the Client’s portfolio. Use of Outside Managers: We may refer Clients to Third Party Investment Advisers or advisory programs (“Outside Managers”). Our analysis of Outside Managers involves the examination of the experience, expertise, investment philosophies, and past performance of the Outside Managers in an attempt to determine if that Outside Manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the Outside Manager's underlying holdings, strategies, concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as part of our due diligence process, we survey the Outside Manager's compliance and business enterprise risks. A risk of investing with an Outside Manager who has been successful in the past is that they may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in an Outside Manager's portfolio. There is also a risk that an Outside Manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our Clients. Moreover, as we do not control the Outside Manager's daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. 16  Investment Strategies Asset Allocation In implementing our Clients’ investment strategy, we begin by attempting to identify an appropriate ratio of equities, fixed income, and cash (i.e. “asset allocation”) suitable to the Client’s investment goals and risk tolerance. A risk of asset allocation is that the Client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of equities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the Client’s goals. We attempt to closely monitor our asset allocation models and make changes periodically to keep in line with the target risk tolerance model. Passive and Active Investment Management We may choose investment vehicles that are considered passive, active, or a combination of both styles. Passive investing involves building portfolios that are composed of various distinct asset classes. The asset classes are weighted in a manner to achieve a desired relationship between correlation, risk and return. Funds that passively capture the returns of the desired asset classes are placed in the portfolio. Active investing involves a single manager or managers who employ some method, strategy or technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a designated benchmark. Actively managed funds are also designed to reduce volatility and risk. We may engage in both passive and active investing in your portfolio. However, we strive to construct portfolios of funds and individual securities that we believe will have the greatest probability for achieving our Clients’ personal financial goals with the least amount of volatility and risk rather than attempt to outperform an arbitrary index or benchmark. Specific investment selections are based on a number of factors that we evaluate in order to select, what we believe to be, the highest quality funds or individual securities for our Clients. These factors include but are not limited to underlying holdings of funds, percentage weighting of holdings within funds, liquidity, tax efficiency, bid/ask spreads, and other smart/strategic beta factors. These factors may or may not result in the lowest cost ETFs and mutual funds available when utilizing funds in a Client’s portfolio, but we strive to keep internal fund expenses as low as possible. Material Risks Involved All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other investment or security. It is impossible to describe all possible types of risks which may affect investments. Among the risks are the following: Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. 17  Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your investments remains the same. This is also referred to as purchasing power risk. Concentration Risk: To the extent a portfolio is concentrated in assets related to a particular industry or geographic region. The portfolio will be subject to additional volatility risks associated with such industry or region. In addition, concentrating in a single industry or group of industries may be more susceptible to any single economic, market, political or regulatory occurrence affecting that industry or group of industries. Currency Risks: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Credit Risk: If debt obligations held by an account are downgraded by ratings agencies or go into default, or if management action, legislation or other government action reduces the ability of issuers to pay principal and interest when due, the value of those obligations may decline, and an account’s value may be reduced. Because the ability of an issuer of a lower-rated or unrated obligation (including particularly “junk” or “high yield” bonds) to pay principal and interest when due is typically less certain than for an issuer of a higher rated obligation, lower rated and unrated obligations are generally more vulnerable than higher-rated obligations to default, to ratings downgrades, and to liquidity risk. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. For example, Treasury Bills are highly liquid, while real estate properties are not. Some securities are highly liquid while others are highly illiquid. Illiquid investments carry more risk because it can be difficult to sell them. Political Risk: Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world. Regulatory Risk: Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. Risk Related to Investment Term: If the Client requires a liquidation of their portfolio during a period in which the price of the security is low, the Client will not realize as much value as they would have had the investment had the opportunity to regain its value, as investments frequently do, or had it been able to be reinvested in another security. Business Risk: Many investments contain interests in operating businesses. Business risks are risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Financial Risk: Many investments contain interests in operating businesses. Excessive borrowing to finance a business’ operations decreases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Default Risk: This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk. 18  Disaster Risk: The value of a Client’s portfolio may be adversely affected by political, economic, social and religious instability including natural disasters, corruption and military activity. Risks Associated with Securities Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer may default. Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks. Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations. Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are delisted from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the Clients invest. Mutual Funds When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). 19  Due to the volatile nature and risks involved when investing in certain types of strategies and/or securities, Clients should be aware that the actual return and value of their account(s) may fluctuate and at any point in time be worth more or less than the amount originally invested. We do not represent, guarantee or imply that the services or methods of analysis employed by WW can or will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses due to market corrections or declines. 20  Item 9: Disciplinary Information WW is required to disclose the facts of any legal or disciplinary events that are material to a Client’s evaluation of our advisory business or the integrity of our management. We do not have any required disclosures to report in response to this Item. 21  Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation Neither WW or its management persons is registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Other Affiliations Neither WW or its management persons is registered, or have an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor. Insurance company or agency Related Persons WW does not have a related person that is: • A banking or thrift institution • Accountant or accounting firm • A lawyer or law firm • • A pension consultant • A real estate broker or dealer • A sponsor or syndicator of limited partnerships Recommendations or Selections of Other Investment Advisers As referenced in Item 4 of this brochure, WW may recommend Clients to Outside Managers to manage their accounts. In the event that we recommend an Outside Manager, we do not share in their advisory fee. Our fee is separate and in addition to their compensation (as noted in Item 5 of this brochure). In addition, you will be provided a copy of the Outside Manager’s Form ADV 2A, Firm Brochure, which also describes the Outside Manager’s fee. You are not obligated, contractually or otherwise, to use the services of any Outside Manager we recommend. Moreover, WW will only recommend an Outside Manager who is properly licensed or registered as an investment adviser. Recommendation of Other Types of Professionals In connection with tax preparation services, WW will recommend an unaffiliated accountant for Client to use for tax preparation services. WW is not compensated, directly or indirectly, by the professional for referring any Clients and no reciprocal referral arrangement exists between WW and any accountants. Tax preparation services are provided under the Code of Ethics and requires WW and its adviser representatives to exercise its fiduciary duty to Clients to act in the best interest of the Client and always place the Client’s interests first and foremost. Licensed Insurance Agents Some representatives of WW are licensed insurance agents in their individual capacities. Clients should be aware that as insurance agents they will earn typical and customary commissions for the sale of insurance products. Acting in dual capacities (insurance agent and financial advisor) and receiving compensation as such creates a conflict of interest in that representatives of WW may recommend purchasing insurance products based on compensation received rather than on the needs of the clients. We manage this conflict of interest by ensuring our representatives review suitability profiles and that insurance recommendations are in the best interest of advisory clients prior to making such recommendations. We also fully disclose to a client when a particular transaction will result in the receipt of commissions or other associated fees. Insurance products may be available through other channels and as a client you are not obligated to purchase insurance products recommended by our representatives. 22  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our Firm has a duty of utmost good faith to act solely in the best interests of each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board of Standards Inc. and accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to uphold the principles of integrity, objectivity, competence, fairness and confidentiality. Additionally, WW requires adherence to its Insider Trading Policy, and the CFA Institute's Asset Manager Code of Professional Conduct and Code of Ethics and Standards of Professional Conduct. Code of Ethics Description This Code of Ethics does not attempt to identify all possible conflicts of interest, and compliance with each of its specific provisions will not shield our Firm or its access persons from liability for misconduct that violates a fiduciary duty to our Clients. A summary of the Code of Ethics' principles is outlined below. ● Integrity - Access persons shall offer and provide professional services with integrity. ● Objectivity - Access persons shall be objective in providing professional services to Clients. ● Competence - Access persons shall provide services to Clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. ● Fairness - Access persons shall perform professional services in a manner that is fair and reasonable to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. ● Confidentiality - Access persons shall not disclose confidential Client information without the specific consent of the Client unless in response to proper legal process, or as required by law. ● Professionalism - Access persons conduct in all matters shall reflect the credit of the profession. ● Diligence - Access persons shall act diligently in providing professional services. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all Firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our Firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest Neither our Firm, its access persons, or any related person is authorized to recommend to a Client or effect a transaction for a Client, involving any security in which our Firm or a related person has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, principal transaction, among others. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our Firm, its access persons, and its related persons may buy or sell securities similar to, or different from, those we recommend to Clients for their accounts. In an effort to reduce or eliminate certain conflicts of interest, our Code of Ethics may require that we restrict or prohibit access persons’ transactions in specific reportable securities. Any exceptions or trading pre-clearance must be approved by WW’s Chief Compliance Officer in advance of the transaction in an account. WW maintains a copy of access persons’ personal securities transactions as required. Trading Securities At/Around the Same Time as Client’s Securities From time to time our Firm, its access persons, or its related persons may buy or sell securities for themselves at or around the same time as they buy or sell securities for Clients’ account(s). To address this conflict, it is our policy that neither our firm or access persons shall have priority over Clients’ accounts in the purchase or sale of securities. 23  Item 12: Brokerage Practices Selection and Recommendation WW does not have any affiliation with Broker-Dealers. Specific custodian recommendations are made to the Client based on their need for such services. We recommend custodians based on the reputation and services provided by the Firm. In recommending broker-dealers, we have an obligation to seek the “best execution” of transactions in Client accounts. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the broker-dealer’s services. The factors we consider when evaluating a broker-dealer for best execution include, without limitation, the broker-dealer’s: fee for custody); ● Combination of transaction execution services and asset custody services (generally without a separate ● ● Capability to execute, clear, and settle trades (buy and sell securities for your account); ● Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill ● payment, etc.); ● Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.); ● Availability of investment research and tools that assist us in making investment decisions ● Quality of services; ● Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; ● Reputation, financial strength, security and stability; ● Prior service to us and our clients. With this in consideration, our firm recommends either Charles Schwab (“Schwab”) or Altruist Financial LLC (“Altruist”)(“Altruist” and “Schwab” each a “Custodian” and together, the “Custodians”), independent and unaffiliated SEC registered broker-dealer firms and members of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Although Clients may request us to use a broker-dealer of their choosing, we generally recommend that Clients open brokerage accounts with Schwab or Altruist. We are not affiliated with the Custodians. The Client will ultimately make the final decision of the Custodian to be used to hold the Client’s investments by signing the selected broker-dealer’s account opening documentation. Research and Other Soft-Dollar Benefits We do not have any soft-dollar arrangements with broker-dealers whereby soft-dollar credits, used to purchase products and services, are earned directly in proportion to the amount of commissions paid by a Client. However, as a result of being on their institutional platform, Custodians may provide us with certain services that may benefit us. Custodian -- Charles Schwab Your brokerage and custody costs For our Clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. 24  Products and services available to us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide our Clients and us with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our Clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. The benefits received by Advisor or its personnel do not depend on the number of brokerage transactions directed to Schwab. As part of its fiduciary duties to Clients, Advisor at all times must put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits by Advisor or its related persons in and of itself creates a potential conflict of interest and may indirectly influence the Advisor’s choice of Schwab for custody and brokerage services. Following is a more detailed description of Schwab’s support services: Services that benefit you Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that may not directly benefit you Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our Clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: facilitate trade execution and allocate aggregated trade orders for multiple Client accounts facilitate payment of our fees from our Clients’ accounts ● provide access to Client account data (such as duplicate trade confirmations and account statements) ● ● provide pricing and other market data ● ● assist with back-office functions, recordkeeping, and Client reporting Services that generally benefit only us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: ● Educational conferences and events ● Consulting on technology, compliance, legal, and business needs ● Publications and conferences on practice management and business succession Schwab Securities Lending Program allows eligible Clients to lend out their fully-paid securities to Schwab, potentially earning monthly income through interest payments. This program enables Clients to put their holdings to work, generating additional revenue without needing to sell their assets. Clients enroll in the program and allow Schwab to borrow the eligible securities when there is demand, often from short sellers. In return, Clients receive interest payments based on the demand for their loaned securities. The program is fee to enroll, and there are no hidden fees. This program provides a way to generate passive income from assets held in the Client’s portfolio. Clients can sell or recall their loaned securities at any time. Key Features: • Eligibility: The Schwab program has eligibility requirements, including a minimum of $100,000 is assets held in Schwab accounts. 25  • Collateralization: Schwab provides cash collateral equal to the full market value of the borrowed securities, which is returned to the Client in the event of Schwab’s failure. • Supplemental Lending Account: A separate account is created to track loaned securities and collateral. • Dividends and Interest: While securities are on loan, the lender may receive substitute payments in lieu of dividends or interest. • Voting Rights: Lenders waive their voting rights on loaned securities. • SIPC Protection: Loaned securities may not be covered by SIPC protection. Custodian – Altruist Financial Your brokerage and custody costs For our Clients’ accounts that Altruist maintains, Altruist 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 Altruist account. Certain trades (for example, ETFs) may not incur Altruist commissions or transaction fees. Products and services available to us from Altruist Altruist serves independent investment advisory firms like us. They provide our Clients and us with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Altruist retail customers. Altruist 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. Altruist’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. The benefits received by Advisor or its personnel do not depend on the number of brokerage transactions directed to Altruist. As part of its fiduciary duties to Clients, Advisor at all times must put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits by Advisor or its related persons in and of itself creates a potential conflict of interest and may indirectly influence the Advisor’s choice of Custodian. Following is a more detailed description of Altruist’s support services: Services that benefit you Altruist’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 Altruist include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Altruist’s services described in this paragraph generally benefit you and your account. Services that may not directly benefit you Altruist also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Altruist’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 Altruist. In addition to investment research, Altruist also makes available software and other technology that: facilitate trade execution and allocate aggregated trade orders for multiple Client accounts facilitate payment of our fees from our Clients’ accounts ● provide access to Client account data (such as duplicate trade confirmations and account statements) ● ● provide pricing and other market data ● ● assist with back-office functions, recordkeeping, and Client reporting Services that generally benefit only us Altruist 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 26  Altruist Fully Paid Securities Lending Program Altruist offers eligible customers the ability to lend out certain of their fully paid and excess margin securities to Altruits, which Altruist may then lend out to other Altruist customers or to other market participants who wish to use these shares for short selling or other purposes. In the Altruist program, you permit Altruist to borrow from you and Fully-Paid Securities in your portfolio and loan these securities out in the securities lending market. Altruist will have the discretion to initiate loans of your securities. You will not be asked to approve each loan before it is initiated, but you can sell your shares at any time or terminate your participation in the program. Altruist will pay you a loan for the shares that it borrow from you. Ordinarily, in cases where borrowers are willing to pay a rebate for the use of your Fully Paid Securities. Altruist will pay you a percentage of the rebate earned by Altruist for lending your securities. Altruist’s net rebate amount used to calculate your Lending interest may be less than the gross rebate amount received by Altruist for relending your securities because certain deductions and charges. In cases where borrowers are willing to take a rebate for the use of your Fully Paid Securities, Altruist will pay you a percentage of the value of the collateral Altruist is holding for you to secure the amount of the loan. For all transactions in which you are lending your Fully Paid Shares, Altruist will be the borrower and Altruist will be the party providing the collateral for you on the securities loan and paying your lending interest or collateral interest, as applicable, to you. Brokerage for Client Referrals We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Directed Brokerage We do recommend a specific custodian for Clients to use, however, Clients may custody their assets at a custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By allowing Clients to choose a specific custodian, we may be unable to achieve the most favorable execution of Client transactions and this may cost Clients money over using a lower-cost custodian. 27  Aggregating (Block) Trading for Multiple Client Accounts Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or access persons may participate in block trading with your accounts; however, they will not be given preferential treatment. Outside Managers used by WW may block Client trades at their discretion. Their specific practices are further discussed in their ADV Part 2A, Item 12. 28  Item 13: Review of Accounts Periodic Reviews Jeff Wright, Stephen Wade, Richard O Maurice, John Allan Duncan or Timothy S. Benbow, will work with Clients to obtain current information regarding their assets and investment holdings and will review this information as part of our financial planning services. WW does not provide specific reports to Clients. Clients who engage us for investment management services will have their account(s) reviewed on a regular basis by Jeff Wright, Stephen Wade, Richard O Maurice, John Allan Duncan or Timothy S. Benbow. The account(s) are reviewed with regards to the Client’s investment policies and risk tolerance levels. Triggers of Reviews Market and Client events may trigger a special review. Client’s may, and are encouraged to, request a review by contacting WW. Review Reports Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. 29  Item 14: Client Referrals and Other Compensation Compensation Received by Wright Wealth LLC WW is a fee-only firm that is compensated solely by its Clients. WW does not receive commissions or other sales- related compensation. Except as mentioned in Item 12 above, we do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our Clients. Client Referrals from Promoters The Advisor engages independent promoters to provide Client referrals. If a Client is referred to us by a promoter, this practice is disclosed to the Client in writing by the promoter and WW pays the promoter out of its own funds— specifically, WW generally pays the promoter a portion of the advisory fees earned for managing the capital of the Client or investor that was referred. The use of promoters is strictly regulated under applicable federal and state law. The Advisor’s policy is to fully comply with the requirements of Rule 206(4)-1, under the Investment Advisers Act of 1940, as amended, and similar state rules, as applicable. WW may receive client referrals from Wealthramp Inc, Inc through its participation in the Wealthramp Referral Platform. Wealthramp Inc is independent of and unaffiliated with WW and there is no employee relationship between them. Wealthramp Inc established the Referral Platform as a means of referring individuals and other investors seeking fiduciary personal investment management services or financial planning services to independent investment advisors. Wealthramp Inc does not supervise WW and has no responsibility for WW’s management of Client portfolios or WW’s other advice or services. WW pays Wealthramp Inc an on-going fee for each successful Client referral. This fee is usually a percentage of the advisory fee that the Client pays to WW (“Promoter Fee”). WW will not charge Clients referred from Wealthramp any fees or costs higher than its standard fee schedule offered to its Clients. For information regarding additional or other fees paid directly or indirectly to Wealthramp Inc, please refer to the Wealthramp Inc Disclosure provided at the time of the referral. 30  Item 15: Custody WW does not hold, directly or indirectly, Client funds or securities, or have any authority to obtain possession of them. All Client assets are held at a qualified custodian. If WW deducts its advisory fee from Client’s account(s), the following safeguards will be applied: i. ii. The Client will provide written authorization to WW, permitting them to be paid directly from their accounts held by the custodian. The custodian will send at least quarterly statements to the Client showing all disbursements from the accounts, including the amount of the advisory fee. In jurisdictions where required, WW will send an itemized invoice to the Client at the same time it instructs the custodian to debit the advisory fee. Itemization includes the formula used to calculate the fee, the amount of assets under management the fee is based on, and the time period covered by the fee. We urge you to carefully review custodial statements and compare them to the account invoices or reports that we may provide to you and notify us of any discrepancies. Clients are responsible for verifying the accuracy of these fees as listed on the custodian’s brokerage statement as the custodian does not assume this responsibility. Our invoices or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 31  Item 16: Investment Discretion For those Client accounts where we provide Investment Management Services, WW has discretionary authority and limited power of attorney to determine the securities and the amount of securities to be bought or sold for a Client’s account without having to obtain prior Client approval for each transaction. Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm discretion over the account(s). Additionally, the discretionary relationship will be outlined in the Investment Management Contract and signed by the Client. Clients may limit our discretion by requesting certain restrictions on investments. However, approval of such requests are at the Firm’s sole discretion. If WW has engaged an Outside Manager to assist with the management of Client’s portfolio, WW has the discretion to direct the Outside Manager to buy or sell securities for Client’s portfolio without obtaining prior Client approval for each transaction. 32  Item 17: Voting Client Securities We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the Client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our Firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies. 33  Item 18: Financial Information We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to our Clients, nor have we been the subject of any bankruptcy proceeding. We do not have custody of Client funds or securities, except as disclosed in Item 15 above, or require or solicit prepayment of more than $500 in fees six months or more in advance. 34  35