Material Changes
ADV Part 2 Material Changes — February 2026
A breakdown of February 2026 material change filings: category distribution, top reasons, and firm-level detail tables.
A breakdown of February 2026 material change filings: category distribution, top reasons, and firm-level detail tables.
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Raw Material Change
This section identifies and discusses material changes to the ADV Brochure since the version of this Brochure dated October 24, 2025. Alternative Investments - Updates were made to reflect the availability of certain Alternative Investments in the Program (See Item 4.A, Alternative Investments). Proxy Voting - Updates were made to reflect changes in how proxies are voted for certain securities in your Account (See Item 6.C Policies and Procedures Relating to Voting Client Securities).
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Raw Material Change
"Below is a summary of the material changes that have been made to this brochure since the annual filing on last filing on May 2, 2025. We are updating the brochure to describe limited instances when the delivery date for an annual Financial Plan may be extended into the next occurring annual period."
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Raw Material Change
This section describes the material changes to Wells Fargo Clearing Services, LLC's ("WFA") Part 2A of Form ADV Appendix 1 ("Wrap Fee Program Brochure" or this "Brochure") for the Personalized Unified Managed Account ("Personalized UMA"), FundSource, Private Advisor Network and Customized Portfolios Programs since the annual version of this Brochure dated March 31, 2025. Changes include: FA Directed Strategy availability in Personalized UMA Program; WFA Solutions remote phone-based service model (0.60% Advisory Fee); new Portfolio Manager partnership feature with Wells Fargo Bank N.A.; Fixed Income Strategy Team Portfolios updates; new Wells Fargo Compass portfolios; closure of ESG Aware Portfolios; FundSource Program changes; Private Advisor Network Program updates; Customized Portfolios Program options additions; Advisory Account Credit maximum reduced from $50M to $25M; and revenue sharing updates including actively managed ETFs and advisory annuities.
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Raw Material Change
Since Vanguard Digital Advisor and Vanguard Personal Advisor's Brochure annual update on March 31, 2025, the following material changes are planned or have occurred: (1) July 2025 - expanded financial planning capabilities providing point-in-time account type recommendations including cash management account recommendations; (2) August 2025 - additional customization available to customize exposure to U.S. and International markets within certain guardrails; (3) September 2025 - required minimum distribution service for IRAs subject to certain limitations; (4) August 29, 2025 - VAI resolved an SEC investigation involving a VAI advisory offer separate from Vanguard Digital Advisor and Vanguard Personal Advisor; (5) Starting March 2026 - ability to add goals other than retirement savings to plans prior to enrollment with enhanced goal planning user experience, methodology, and capabilities.
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Raw Material Change
This section describes material updates and changes made to this ADV disclosure brochure since the last annual amendment dated March 28, 2025. • Item 4 – Advisory Services. This section was amended to describe services provided to Public Clients with multi-asset allocation mandates. • Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. This section was updated to include information on analysis techniques and investment strategy processes for Public Clients with multi-asset allocation mandates. Material risks were also updated to include risks associated with equity strategies.
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Raw Material Change
"The most recent annual update of this Form ADV Part 2A Brochure and Wrap Program Appendix was on March 28, 2025. On June 30, 2025, Betterment amended its advisory brochure on Form ADV Part 2A and Wrap Fee Program Appendix 1 to reflect reductions to Betterment's asset-based fees for Clients on Betterment's Premium plan, such that Betterment will waive the incremental 0.40% fee for Premium Services on the portions of their account balances above $1 million. On July 31, 2025, Betterment amended its advisory brochure on Form ADV Part 2A and Wrap Fee Program Appendix 1 to reflect that beginning on September 1, 2025, Apex will share with Betterment Securities a portion of the payments or rebates that Apex receives on Betterment Securities' orders. On August 19, 2025, Betterment amended its advisory brochure on Form ADV Part 2A and Wrap Fee Program Appendix 1 to reflect that its single-participant 401(k) offering is available to all Retail Clients. On November 4, 2025, Betterment amended its advisory brochure on Form ADV Part 2A and Wrap Fee Program Appendix 1 to reflect the addition of self-directed investing advisory services provided through its wrap fee program. On November 25, 2025, Betterment amended its advisory brochure on Form ADV Part 2A and Wrap Fee Program Appendix 1 to reflect that the monthly fee on digital investing accounts for Retail Clients with balances under $24,000 will increase from $4 to $5 per month effective January 5, 2026. On February 10, 2026, Betterment amended its advisory brochure on Form ADV Part 2A and Wrap Fee Program Appendix 1 to reflect (1) its referral service for Advisors and Retail Clients, the Betterment Advisor Network, and (2) its model marketplace of third-party portfolios through Betterment Advisor Solutions, for which it receives support payments from third-party portfolio managers to provide technology and infrastructure to support certain third-party portfolios on its platform. On February 27, 2026, Betterment amended its advisory brochure on Form ADV Part 2A and Wrap Fee Program Appendix 1 to reflect the addition of Account Recommender, an optional tool for Retail Clients summarized with generative artificial intelligence."
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Raw Material Change
Since the last annual amendment to this Brochure on March 31, 2025, this Brochure has been updated for the following material changes: to update the description of our stable value and Book Value Equalizer Separate Account advisory services, including with respect to Separate Account transfer restrictions, underlying investments, stable value investment contracts and their potential impact on the Separate Account and the Plan Sponsor's Plan, and risks and risk definitions; to update the description of our equity and fixed income investment strategies, including with respect to underlying investments; to update our standard fee schedule for our stable value Separate Account advisory services; and, to disclose conflicts of interest resulting from a new strategic partner program offered by our parent company, MissionSquare Retirement.
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Raw Material Change
Since the last annual amendment to this Brochure on March 31, 2025, we have updated this Brochure for the following material changes: (1) Updated MissionSquare Special Purpose Funds to reflect we no longer exercise investment discretion in the purchase and sales of fixed income securities, and updated the fee structure; (2) Updated the methods of analysis associated with the selection and monitoring process for certain MissionSquare Funds; (3) Updated MissionSquare Low Duration Bond to reflect we no longer exercise investment discretion in the purchase and sales of portfolio securities; (4) Provided updates to reflect potential conflicts of interest related to a partnership program of our parent company, MissionSquare Retirement; (5) Updated brokerage practices to reflect that certain broker-dealers we select may also serve as Authorized Participants to certain ETFs.
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Material changes made on or after the date of the last annual update of FTIML's brochure are summarized below. Item 4: Advisory Business – The description of entities and FTIML's assets under management has been updated. Item 5: Fees and Compensation – The language relating to Co-Investment Vehicle Expenses, Timing and Payment of Advisory fees, and Other Fees and Expenses has been updated. Item 7: Types of Clients – The language pertaining to Private Funds has been updated. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss – The Investment Strategies and Risks disclosures have been updated, including the addition of a new risk disclosure relating to Artificial Intelligence. Item 12: Brokerage Practices – The broker-dealer names have been updated. Item 16: Investment Discretion – The language regarding sweep vehicles has been updated. Item 17: Voting Client Securities – The phone number for the Proxy group has been updated.
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Raw Material Change
This item describes only material changes to this Brochure since our last annual amendment on February 28, 2025: Item 4 (Advisory Business) has been updated to include information regarding the definitive agreement that Diamond Hill Investment Group, Inc. (the parent of Diamond Hill Capital Management, Inc.) and First Eagle Investment Management, LLC have entered into, subject to the satisfaction of customary closing conditions, including approval by Diamond Hill Investment Group, Inc.'s common shareholders, mutual fund shareholder-related approvals, and regulatory approvals. In Item 12 (Brokerage Practices), the Model Delivery and Trade Allocation section has been updated to note that while Diamond Hill Capital Management, Inc. typically provides model change notifications after placing orders for discretionary accounts, some model delivery clients can receive notifications concurrently with those orders.
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Raw Material Change
Since our last annual amendment, dated March 28, 2024, we have made the following material changes to our Disclosure Brochure. Item 4: Added clearing/custody relationship with Fidelity; added Steward Partners - RIA Managed Account Program custodied through Folio Investments, Inc., d/b/a Goldman Sachs Custody Solutions. Item 5: Added program fee and other information regarding Steward Partners - RIA Managed Account Program; enhanced information regarding potential conflicts of interest. Item 10: Elan Wealth Management, Inc. is no longer an affiliated entity. Item 12: Enhanced disclosures regarding custodial choices; added clearing/custody relationships with Schwab, Fidelity Brokerage Services LLC, and Goldman Sachs Custody Solutions; added information regarding mutual fund revenue sharing with RJA; enhanced information regarding clearing and custody relationships available through affiliated broker/dealer. Item 14: Enhanced disclosures regarding growth incentives available to IARs; added disclosure regarding structured product referral arrangement with Navian Capital Securities, LLC.
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Raw Material Change
"Since our last wrap fee brochure dated March 31, 2024, Steward Partners Investment Advisory, LLC ("SPIA") has made the following material changes to our wrap fee program disclosures:" followed by five specific changes: (1) Advisory Program Disclosures expanded to include Steward Partners Personalized Portfolios (Guided and Discretionary), Separate Account Solutions (SMA), and Unified Managed Accounts (UMA); (2) Third-Party Platforms and Models introduced SMArtX Advisory Solutions and added disclosures regarding Life Wealth Optimization (LWO); (3) Custodians now utilize Charles Schwab & Co., Inc., Folio Investments, Inc. (d/b/a Goldman Sachs Custody Solutions), and Fidelity Brokerage Services LLC; (4) Trading Practices added disclosures regarding step-out trades and aggregation of transactions; (5) Use of Margin added disclosure regarding availability of margin and securities-based lending.
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Raw Material Change
"The following are the Material Changes were made to the Brochure since our last annual Brochure disclosure filing of March 29, 2024." Date: March 28, 2025. Items updated: Item 4 (removal of assumed name McShane Partners, use of Pontera technology platform, launch of Waverly Growth Fund II, management of GGM Macro Alignment ETF, professional services disclosure, increased regulatory assets under management), Item 5 (fees/expenses for GGM ETF, advisory fee annual minimum waiver, Pontera platform fees), Item 8 (investment objectives and strategies updates), Item 10 (conflicts relating to GGM ETF), Item 11 (GGM ETF conflicts and employee preclearance requirements), Item 12 (brokerage practices updates including soft-dollar arrangements, best execution, sub-advisory engagements), Item 13 (account review practices including Pontera platform and aggregate account management), Item 14 (referral compensation, soft-dollar benefits, Pontera platform payments).
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Raw Material Change
Since the filing of the previous version of this Brochure as of March 31, 2025, the following material changes occurred: (1) The AuguStar Variable Insurance Products Fund, Inc. introduced a new share class (Class II Shares) for eighteen of its twenty-five portfolios that will charge Rule 12b-1 distribution and shareholder servicing fees, with corresponding updates to Items 5, 10, 12, and 14; (2) Item 4 updated to describe CINV's business functions including management of the AuguStar Variable Insurance Products Fund, Inc., insurance company separate accounts, and CLO private fund investments; (3) Item 8 updated to include additional risk factors relating to CINV's investment advisory functions; (4) Conforming changes throughout the brochure reflect the termination of Federated Investment Management Company as subadviser to two portfolios.
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Raw Material Change
Item 2 Material Changes describes three periods of changes: April 2025 – Fee Updates and Class Action Services (disclosed a $10,000 minimum annual fee for Individually Managed Accounts and added disclosure explaining that Bahl & Gaynor uses Broadridge to manage class action filings, with Broadridge deducting a 12% fee from settlement proceeds); November 2025 – Enhancements to SMA/Wrap Program Disclosures and Pricing of Securities (expanded disclosures regarding wrap fee and dual contract Separately Managed Account programs, added new language regarding valuation methodology for alternative funds); February 2026 – Annual Update, Trading Practices, and Leadership Title Changes (completed annual Form ADV Part 2A update, updated leadership titles, updated Item 12 to provide additional disclosure regarding block trading practices).
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Raw Material Change
"April 2025 – Fee Updates and Class Action Services: Disclosed a $10,000 minimum annual fee for Individually Managed Accounts (high-net-worth and institutional clients). Added disclosure in Item 17 explaining that Bahl & Gaynor uses Broadridge to manage class action filings, and that Broadridge deducts a 12% fee from settlement proceeds recovered for clients. November 2025 – Enhancements to SMA/Wrap Program Disclosures and Pricing of Securities: Expanded disclosures throughout the brochure to provide additional clarity regarding Bahl & Gaynor's role in wrap fee and dual contract Separately Managed Account (SMA) programs, particularly in relation to Platform Partners. Added new language in Item 5 regarding the valuation methodology for alternative funds, including the use of the most recent reported market value, which may be subject to delayed reporting. Made additional minor edits throughout the brochure to improve clarity, readability, and consistency. February 2026 – Annual Update and Leadership Title Changes: Completed the annual update to the Form ADV Part 2A. Updated leadership titles to reflect current roles and responsibilities. No other material changes were made to the brochure."
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Raw Material Change
"In February 2026, Bridgepoint Group consummated a transaction with Apollo Global Management and certain of its affiliates (Apollo), pursuant to which Bridgepoint Group will acquire a team from Newbury, a middle-market secondaries investment firm, and provide advisory services to the Newbury funds. Quantum US Holding LP (Quantum) has been added as a new relying adviser of Bridgepoint, LLC, which will act as an adviser, including as a sub-adviser, to the Newbury funds. This brochure has been updated to reflect the addition of Quantum as a relying adviser and certain details related to Quantum's operations."
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Raw Material Change
Since our last update, we have had the following material changes: (i) Effective January 20, 2026 PNMAC Capital Management, LLC changed its name to Pennymac Capital Management, LLC; and (ii) the Adviser has amended Items 4, 5, 6, 7, 8, 10, 13, 15 and 16 to reflect that the Adviser expects to provide advisory services to institutional clients in addition to PennyMac Mortgage Investment Trust, a publicly traded real estate investment trust.
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Raw Material Change
This is a new, service-specific Form ADV Part 2A prepared to describe IFP's Family Office Services offering for high net worth and ultra-high-net-worth individuals and families. This brochure is derived from IFP's primary Form ADV Part 2A but has been materially revised to (i) limit the scope of services described to Family Office Services, (ii) incorporate advisory services related to complex assets, including direct real estate advisory support, and (iii) tailor disclosures to the needs and risks of sophisticated private clients.
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Since our last annual updating amendment, dated March 21, 2025, the following reflects our most recent material changes: TMG maintains an internal bonus compensation plan whereby employees can qualify to receive bonus compensation based upon various factors, among which factors include prospective new client introductions. This bonus compensation arrangement presents a potential conflict of interest because the employee has an economic incentive to make the prospective new client introduction.
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Raw Material Change
"Item 2 – Material Changes: This section describes the material changes to the Fifth Third Securities, Inc. (FTS or we) Form ADV Part 2A, Appendix 1 (Brochure) since the March 31, 2025 version. Item 4.B.3) - Separately Managed Account Program (SMA Program) – Section updated to provide information related to Index Based Investing, also known as Direct Indexing. Item 4.B.16) - Aspire Strategist Portfolios Program (Aspire Program) – Section was added to disclose a new Passageway program where FIWA has retained Aspire Strategist Portfolios, LLC to recommend investments and models in the Aspire Program. Item 4.B.17) - Cantor Fitzgerald Managed Sponsored Program (Cantor Fitzgerald Program) – Section was added to disclose a new Passageway program where FIWA has retained Cantor Fitzgerald Investment Advisors, L.P. to recommend investments and models in the Cantor Program. Item 4.B.18) - Frontier Asset Model Provider Investment Strategies Program (Frontier Program) – Section was added to disclose a new Passageway program where FIWA has retained Frontier Asset Management, LLC to recommend investments and models in the Frontier Program. Item 4.C.1) FIWA, NFS, and Portfolio Manager Fees – Added details about the fees assessed to FTS for the Aspire Program, Cantor Fitzgerald Program, Frontier Program, and the added US Sector Momentum under the Symmetry Program. Item 4.K. Trade Allocations and Block Trading – Section updated to provide additional information that FTS has no control over a Portfolio Managers allocation policies except when FTS and our IARs act as the Portfolio Manager. Item 4.M. Holding a Client or Instruction – Section has been enhanced to provide additional information regarding when FTS and FTS IARs can choose not to act upon a clients instruction or order if FTS has a belief that the client is subject to financial abuse or is engaged or potentially engaged in a criminal activity. Item 6.C.2) Methods of Analysis, Investment Strategies, and Risk of Loss – Section updated to provide information related to risks associated with Artificial Intelligence (AI), Direct Indexing Risks, and Tracking Error. Item 9.B.2)e) Related Entities – As of February 1, 2026, Comerica Securities, Inc. is an affiliated broker-dealer of FTS. Item 9.C. Additional Conflicts of Interest – Section updated to provide additional information regarding the receipt of compensation or reimbursement from Portfolio Managers, products companies, and service providers. Fee Schedule – Updated the Standard Fee Schedule."
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This February 27, 2026 amendment reflects revisions to services provided to financial planning clients, adoption of model portfolio distribution policies, and the addition of the Halal Growth Equity and Halal Client Aggressive Equity Strategies.
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Raw Material Change
This February 27, 2026 amendment reflects revisions to services provided to financial planning clients, adoption of model portfolio distribution policies, and the addition of the Halal Growth Equity and Halal Client Aggressive Equity Strategies.
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Raw Material Change
Since the last annual update of this Brochure was filed in February 2025, Truston has made the following material changes: Voting Client Securities (Item 17): Truston has updated its proxy voting and stewardship policies to reflect its commitment as a signatory to the Korea Stewardship Code.
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Raw Material Change
Since the time of our last annual updating amendment on March 27, 2025, we have made the following material changes: 1) We offer clients the option of engaging unaffiliated third-party managers to provide portfolio management services via separately managed accounts. 2) We have begun a business arrangement with an affiliated firm under which certain clients of our firm invest a portion of their assets in certain of the affiliated firm's private investment vehicles.
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Set forth below is the Summary of Material Changes for Nicholas Hoffman & Company, LLC ("NHCO") since the last annual update of the Brochure made on March 14, 2025: October 2025 - Various sections of the Brochure were updated to describe that NHCO serves as the Lead Investment Sub-Advisor of the NHCO Lower Middle Market PE, LP (the "Fund"), a private equity fund. The update also included the fees applicable to investments in the Fund, client fee waiver, and a description of conflicts of interest. Item 18 was updated to include the risks of investments in a private "fund of funds" and valuation risks. February 2026 - Item 4 and Item 5 were updated to describe NHCO's Family Office Services and applicable fees. Item 4 was amended to provide information pertaining to NHCO's fiduciary obligations. Item 12 was updated to describe our Allocation Policy for Lower Middle Market Private Equity Funds.
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Raw Material Change
Since our last annual updating amendment dated March 26, 2025, we have amended certain disclosures in this brochure: At Item 4 to update the firm's ownership structure; At Items 4, 10, and 11 to update names of various proprietary mutual funds (HCM Dividend Sector Plus Fund changed to HCM Sector Plus Fund, HCM Income Plus Fund to HCM Multi-Asset Plus Fund, HCM Tactical Growth Fund to HCM Tactical Plus Fund); At Item 5 to revise the manner in which a client's total fee and the amount we pay to a client's primary investment professional are described; At Item 5 to increase and enhance disclosures regarding termination of our services and our related refund practices; At Item 8 to increase and enhance disclosures regarding the use of the HCM-BuyLine® proprietary indicator and the overall risks associated with our investment strategies; At Item 8 to incorporate disclosures regarding the use of HCM Pivot Point® proprietary indicators and the potential use of leveraged funds and derivatives in our mutual funds and ETFs; At Item 12 to incorporate disclosure regarding our mutual fund share class allocation practices and related conflicts and limitations; At Item 13 in connection with a change to the firm's Chief Compliance Officer; At Item 17 to revise disclosure regarding the firm's proxy voting policies for its proprietary funds.
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Raw Material Change
The following material changes have been made to this brochure since the last amendment dated September 15, 2025. Item 1: Added Rockville, Maryland office address. Item 4: Added description of tax, accounting and trustee services as well as modified the description of each of the services offered. Item 5: Added disclosure relating to financial planning and tax preparation services. Updated fee and fee minimum for institutional model portfolio and research subscription services. Item 7: Added individuals as a type of client and added disclosure relating to account minimums for clients of firms acquired by AlphaCore. Item 8: Revised disclosure relating to fundamental analysis utilized by the firm and added disclosure relating to use of legacy managers for clients of firms acquired by AlphaCore. Added disclosure relating to illiquidity; how the firm classifies alternatives into two primary buckets; and cybersecurity risk. Item 11: Added disclosure relating to conflicts in connection with a fund sub-advised by the firm. Item 12: Revised factors the firm takes into account when considering best execution. Added disclosure relating to the firm's relationship with Charles Schwab & Company, Inc. and revised the aggregation and allocation of trades and trade error disclosure. Item 14: Added disclosure relating to conflicts of interest regarding Schwab, AFA LLC and client referral arrangements. Item 15: Added disclosure relating to Schwab accounts and added personal representative and executor as roles subjecting an account to surprise custody. Item 16: Added disclosure stating that the firm does not take any actions on behalf of clients with respect to any legal proceedings and class actions.
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Raw Material Change
The material changes in this brochure from the other than annual amendment of Facet Wealth, Inc. on October 1, 2025 are described below. Material changes relate to Facet Wealth, Inc.'s policies, practices or conflicts of interests. ● A change to the address uses for its business from Maryland to Florida. The address is listed above. Facet remains a fully remote firm. ● An update to the fee range in Item 5 to include the current fee structure for its service tiers. ● An update to include third parties used for estate planning and tax filing services as a part of service tiers or offered a la carte. ● In Items 10 and 14, an overview of partnerships and endorsers, how those arrangements work and any potential conflicts of interest.
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Raw Material Change
Since our last annual amendment to this Brochure on March 31, 2025, we have updated this Brochure for the following material change: We have updated Item 13 to disclose the titles of the investment professionals that conduct client account reviews. On February 6, 2026 we updated this brochure to discuss conflicts of interest related to a partnership program we now offer focused on our retirement plan recordkeeping and administration business.
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Raw Material Change
Material changes were made to Item 4: Advisory Business to include Vident Asset Management as the sub-adviser for Shelton's exchange-traded fund ("ETF"). In addition, Item 5: Fees and Compensation, and Item 8: Methods of Analysis, Investment Strategies and Risk of Loss to add Stringer Risk Managed strategies. Other than the items listed above, there have not been any other material changes since the Brochure dated December 17, 2025.
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"This publication of the Form ADV Part 2A contains highlights of the changes that have been made to this brochure since the last update in March 2025. Some of these items may be deemed material changes from our last filing." Changes include: (1) The firm conducts business under the name Dunham; (2) Updates to Advisory Business and Methods of Analysis sections describing addition of DunhamDC (proprietary algorithmic rebalancing program) and DRIP feature to Standard Asset Allocation Program; (3) Updates to Other Financial Industry Activities and Affiliations and Client Referrals sections clarifying Dunham Trust Company does business as "Dunham Trust" (Nevada) and "Dunham Private Trust" (Wyoming), plus detail about third parties with minority interests; (4) Update to Other Financial Industry Activities and Affiliations about offering access to a third-party mortgage platform.
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This publication of the Wrap Fee Brochure contains highlights of the changes that have been made to this brochure since the last update in March 2025. Some of these items may be deemed material changes from our last filing.
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This Brochure, dated February 20, 2026, was prepared in accordance with the SEC requirements, and contains the following material changes from the prior year's annual amendment (filed on March 31, 2025). Details have been added to Item 4 Advisory Business regarding appointed control persons and scope of services offered. Details have been added to Item 4 Advisory Business and Item 8 Methods of Analysis, Investment Strategies and Risk of Loss regarding the firm's use of Artificial Intelligence to aid operational efficiency.
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Raw Material Change
This section of the Brochure summarizes only those "material changes" that have been incorporated since our last amendment on March 21, 2025. Changes include: Item 4 - new ownership by The Huntington National Bank; Item 5 - new fee schedule for Family Office Services; Item 8 - added call options strategy discussion and expanded Risk Factors; Item 9 - removed disciplinary history of individual no longer associated; Item 10 - added Huntington affiliate activities; Item 11 - added discussion on transactions where LW or Huntington have financial interest; Item 12 - LW does not vote Huntington Bancshares (HBAN), client must vote themselves.
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Since the version of this brochure dated August 26, 2025, there have been the following updates: (1) Updated Business Address: Stash updated its mailing address to 149 E 23rd St, P.O. Box 1106, New York, NY 10010; (2) Item 4- Wrap Program Consolidation: In late 2025, Stash consolidated its previously separate wrap fee program variations into a single unified wrap fee program structure; (3) Item 4- Stash Advisor Connect: Stash added an optional advisory service known as Stash Advisor Connect, which provides eligible Clients access to live investment professionals for personalized guidance for an additional fee; (4) Item 9- Stash Advisor Connect Fees and Conflicts: This brochure has been updated to describe the fee structure and potential conflicts of interest associated with Stash Advisor Connect.
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Since the version of this brochure dated August 26, 2025, there have been the following updates: (1) Updated Business Address to 149 E 23rd St, P.O. Box 1106, New York, NY 10010; (2) Wrap Program Consolidation - removed the offering of multiple wrap fee programs and now offers only one program; (3) Stash Advisor Connect Services - added optional live advisor services made available to some Clients for an additional fee; (4) Stash Advisor Connect Fees - added language regarding fees for the Stash Advisor Connect service.
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Since our last annual updating amendment on March 30, 2025, we have made the following material amendments to this Brochure: Item 4 – CapitalHub Lending Services: We added disclosure regarding our CapitalHub lending services platform, which connects clients with a network of participating lenders through a third-party technology provider. Item 10 – Other Financial Industry Activities and Affiliations: We added disclosure regarding the acquisition of CW Advisors, LLC by our parent company, Osaic Holdings, Inc., and the Firm's resulting affiliation with CW Advisors.
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"Below are the material changes to this brochure since the last annual updating amendment of the brochure filed on March 17, 2025." - Item 4: Updated ownership information to indicate that APIA is a wholly owned subsidiary of Arthur J. Gallagher & Co., a publicly traded company. Updated the amount of assets under our management. - Item 5: Removed disclosure stating that Clients may terminate the advisory agreement within five days of signing without penalty. - Item 10: Removed reference to Justin Callaham as he is no longer affiliated with APIA. Updated disclosure to indicate that APIA is affiliated with other investment adviser firms and broker-dealer firms also under Gallagher's ownership. Updated to disclose that APIA dba Benefits Plus provides third party administrator services and receives separate compensation for those services. - Item 14: Updated to indicate that APIA may pay referral fees to persons who are employees of APIA affiliates.
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Since our last update dated April 11, 2025, we have made the following material changes: Item 4: Amended to reflect ownership change and financial planning and consulting services, as well as updated assets under management. Item 5: Amended to clarify fees and expenses. Item 8: Updated to reflect our current investment strategies. Item 12: Amended to reflect current brokerage practices. Item 14: Updated to reflect that we do not receive any economic benefits from anyone who is not a client.
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Since the last Annual Amendment filing on February 21, 2025, this Disclosure Brochure has been amended in Item 4 to enhance disclosure regarding our advisory services.
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This is the first ADV Part 2A ("Brochure") update since Variant Investments, LLC filed its last Brochure, dated March 1, 2018. In 2018 VAIF LP was converted to a Delaware statutory trust and registered under the Investment Company Act of 1940 as Variant Alternative Income Fund ("VAIF"). Additionally, in 2018 Variant registered with the SEC as an investment adviser under the Investment Advisers Act of 1940. Beginning in January 2026, Variant launched a new fund, Variant Income Opportunities Fund, LP ("VIO"), a private fund exempt from 40 Act registration.
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This is an other than annual updating amendment reflecting the following changes: Item 4 and 5 have been updated to disclose our new Diversified Income SMA Model Strategies. Item 14 has been updated to disclose certain referral fee programs that NEPWA participates in.
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This brochure includes updates to the brochure of GPI published on May 14, 2025. In particular, this Brochure includes revisions related to GPI's business operations and updated disclosures in the following areas: Item 4 – Advisory Business; Item 6 – Performance-Based Fees and Side-by-Side Management; Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss; Item 10 – Other Financial Industry Activities and Affiliations; Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading; Item 14 – Client Referrals and Other Compensation.
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This Brochure replaces the last version of our Brochure dated June 2025. An updated ADV was filed to reflect: a change in Chief Compliance Officer where Joanna Scott is taking on the responsibilities from Peter Butler; the departure of Herbie Lloyd (CIO Private ILS and Head of UK and Bermuda); and to reflect the orderly liquidation of the following Private Funds after returning capital to shareholders: Securis Event Master Fund, Securis Event Fund, Securis Event Fund (US) LP, Securis II Fund – SPC Relating to Segregated Portfolio Three – Life and Non-Life
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Since the annual updating amendment filing on March 31, 2025, the following material changes have been made to this brochure. The addition of the Lighthouse Private Credit Opportunity Fund LLC private fund (Item 4). Clarification of advisory fee billing practices, including valuation timing and treatment of partial billing periods and account terminations (Item 5).
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Since the filing of our last annual updating amendment, dated March 17, 2025 we have made the following material changes to our Form ADV: Since the filing of our annual updating amendment, dated March 22, 2024, and as of 11/14/2025, flexPATH is no longer sub-advising Collective Investment Trusts for which Great Gray Trust Company ("Great Gray") is the trustee, as Great Gray and its affiliates have purchased the assets flexPATH used to conduct that sub-advisory business as well as hired certain flexPATH employees. flexPATH will continue to provide 3(38) services to retirement plans.
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Since our last annual updating amendment dated March 13, 2025, Leo Wealth Solutions, LLC has included additional details regarding the management of ERISA-covered assets as a plan fiduciary under section 3(21) of ERISA, amended the potential range of our financial planning fees, and disclosed additional details regarding costs for transitioning from other custodians.
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Since our last annual updating amendment filed dated March 14, 2025, we have the following material changes to report. Section 15 - Custody - Added language for Trustee Services provided by the Advisor
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Section 2 states: "Elevation Point Wealth Partners, LLC ('EPWP') has made several material updates to our Form ADV Part 2A since our last filing on September 11, 2025... The following material changes have been made:" followed by 8 specific changes including: referral relationship with Woodbridge International, LLC; use of Vestmark platform; relationship with Pinnacle for variable annuities; relationship with TPFG as introducing firm; registered representative relationship with Purshe Kaplan Sterling Investments; updated AUM in Item 4; expanded brokerage practice disclosures; and revenue-sharing agreement with Flourish Financial LLC.
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This summary reflects changes since our last amendment dated October 1, 2025. Gavin Maurer, Zachary Merring, Maxine Shevlin, and Lillia Smith have been added as Investment Advisor Representatives. Henry Cluver and Peyton Vostenak are no longer Investment Advisor Representatives at RTD. RTD now offers an Estate Engagement Service.
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The material changes in this brochure from the last annual updating amendment of Wedmont Private Capital LLC on 01/21/2025, are described below. Material changes relate to Wedmont Private Capital LLC's policies, practices or conflicts of interest. Wedmont Private Capital LLC has updated its disclosure in Item 5 to state "This service may be terminated by either party at any time upon receipt of written notice, at which time Wedmont will process a final pro-rated bill and delink the client's accounts from its master account at Charles Schwab."
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Since our last Annual Updating Amendment on March 31, 2025, we have made changes to the following brochure sections: Item 4 (Services, Fees & Compensation) was updated to reflect flat percentage fee structure instead of prior tiered or blended fee descriptions; Item 6 (Portfolio Manager Selection & Evaluation) was updated to reflect that Digital Asset services clients custody through Fidelity Digital Assets®.
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Since our last Annual Updating Amendment on March 31, 2025, we have made changes to the following brochure sections: Item 4 (Advisory Business) - updated AUM figures to $2,885,624,988, added Digital Asset Management Services updates, new sub-advisory relationship with PeakShares, LLC for the PeakShares RMR Prime Equity ETF; Item 5 (Fees & Compensation) - transitioned from a tiered/blended fee schedule to a single flat-rate advisory fee, described as "a material change to our fee methodology"; Item 7 (Types of Clients) - disclosed provision of advisory services to registered investment companies; Item 8 (Methods of Analysis) - clarified Digital Asset custody arrangements.
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Since our last annual updating amendment on March 19, 2025, we have launched a new investment product: BlackRock UMA Services and Vise Trading Platform. The Firm may now enter into referral or solicitation agreements with third parties and compensate individuals or organizations for client referrals.
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When compared to the Form ADV Part 2 filed January 8, 2025, there are three material changes within the updated ADV Part 2. First, within Item 12, NFC acknowledges that it occasionally employs margin with client direction. Second, within Item 12, NFC acknowledges a Soft Dollar arrangement with The Interstate Group. Third, within Item 17, NFC updated its proxy voting disclosure to reflect that it does not vote client proxies.
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The following information provides a summary of material changes that have been made to this brochure since Sterling Advisers' last Annual Updating Amendment: addition of new relying advisers formed in connection with new investment vehicles sponsored by Sterling Advisers, as well as additional details on the new investment vehicles.
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"We have updated Item 4 Advisory Business with our year end Assets Under Management numbers as of 12/31/2025. We have added language to Item 17 Voting Client Securities, where we disclose the use of an outside Proxy Voting Services vendor and that we subscribe to their proxy voting service."
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This section describes material changes to our Wrap Program since the last filing of our Brochure on December 12, 2025. Changes include: Item 4 - program renamed from 'U.S. Bancorp Investments Managed Portfolios' to 'U.S. Bancorp Advisors Managed Portfolios', added AMG Model Portfolios information, money market funds explanation, revised householding fees, mutual fund share class information; Item 6 - account changes without client signature, additional investment risks, proxy voting process update; Item 9 - February 16, 2026 consolidation of USBA and USBI retail businesses, new margin/lending subsection added to Code of Ethics.
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This brochure replaces Stifel Capital Management, LLC's brochure dated March 26, 2025 and has been updated to reflect the recent acquisition by Stifel Financial Corp. ('Stifel') of certain assets of Spring Mountain Capital, LP ('SMC') effective February 2, 2026. As a result of the Transaction, Stifel Capital Management, LLC ('SCM'), a wholly owned subsidiary of Stifel, assumed the management and investment advisory services of certain separately managed accounts advised by SMC's fixed income business ('SMC FIM'). In connection with the Transaction, all SMC FIM employees have become employees of SCM. Accordingly, SMC no longer advises the above-mentioned accounts.
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The material changes made since filing our last annual amendment update in January 2025 are as follows: (1) The firm has added an additional service to expand our asset management services; (2) We have updated our assets under management
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Since the last annual amendment filed on 03/25/2025, the following changes have been made: As of December 31, 2025, Austin Private Wealth, LLC was acquired by Cerity Partners. Austin Private Wealth no longer provides regulatory advisory services and manages any assets. We will be withdrawing our registration with the U.S. Securities and Exchange Commission in the first quarter of 2026.
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Since the last annual amendment filed on 03/25/2025, the following changes have been made: As of December 31, 2025, Austin Private Wealth, LLC was acquired by Cerity Partners. Austin Private Wealth no longer provides regulatory advisory services and manages any assets. We will be withdrawing our registration with the U.S. Securities and Exchange commission in the first quarter of 2026.
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We have made the following material updates since our last annual update in March 2025: (1) We have updated our billing frequency to monthly in advance from quarterly in advance. We have also clarified that margin debit balances and short market values do not reduce the value of client assets for billing purposes. (2) We have increased our stated maximum annual asset-based advisory fee from 1.07% to 1.35%. (3) We have added information about the use of box trades as a form of synthetic loan.
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"There are material changes in this brochure from the last annual updating amendment of RVW Wealth, LLC on 03/31/2025. Material changes relate to the firm's policies, practices or conflicts of interests. • Exit from Schwab Advisor Network® - RVW previously participated in the Schwab Advisor Network® program for approximately one year. This relationship has now concluded, and related disclosures and conflicts of interest have been removed from this Brochure. • Update to investment management fee billing calculation - RVW updated it's fee billing calculation to disclose quarterly capital flow adjustments."
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The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on March 21, 2025: (1) now serving as investment manager to pooled investment vehicles, (2) now explaining factors used to select custodians/broker-dealers in Item 12, (3) updated fee information and maximums in Item 5, (4) changed method of billing on cash equivalents in Item 5
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"Since our last annual amendment filing, our firm has the following material changes to disclose: • We have updated Item 5 below to disclose the use of 55ip. • We have added risk disclosure language to Item 8 below describing the risks of cryptocurrency products that we recommend in certain client portfolios."
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Here is a list of material changes since last filing: Item 1 has been updated to reflect the Firm's new office address. Items 4 and 5 have been updated to reflect that the Firm offers ERISA plan services as a 3(21) Adviser. Item 5 has been updated to provide more information on hourly fees.
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This brochure dated February 3, 2026 contains two material changes from the Company's prior Annual Amendment dated February 7, 2025. Change 1: The Company previously served as manager and investment advisor to two private investment funds, the AHCO Core Fund, LLC and the AHCO Bond Fund, LLC. The Company concluded to wind up and terminate the funds, and Articles of Termination were filed with the State of Missouri effective December 31, 2025. As a result, sections of this Brochure have been amended to remove references to the two funds. Change 2: The Company has amended portions of its Code of Ethics (Item 11) relating to personal trading policies and procedures applicable to employees.
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Since our last annual updating amendment, dated February 15, 2025 we have made the following material changes to our Form ADV: Added disclosure of the Haven Global Partners ACWI ex-US Fund, L.P.
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The following material changes were made to Evermay Wealth Management, LLC's August 1, 2025, Firm Brochure. Item 4 – Advisory Business: Evermay now offers three advisory service levels, Family Office, Integrated, and Guided. Item 5 – Fees and Compensation: Updated to show the standard advisory fee schedules for the three service levels. Item 7 – Types of Clients: Updated minimum billable asset level information ($2,000,000 for Family Office and Integrated, lower for Guided). Item 10 – Other Financial Industry Activities and Affiliations: Updated to disclose affiliation with Evermay Tax, LLC and related conflicts of interest.
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The material changes in this brochure from the last annual updating amendment of Falcon Wealth Planning, Inc on February 20, 2025, are described below. Material changes relate to Falcon Wealth Planning, Inc.'s policies, practices or conflicts of interests. • The firm has updated its Assets Under Management. • The firm updated Items 4, 5 & 8 to disclose third party financial planning services. • The firm has disclosed assets under advisement. (Item 4)
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Affiance Financial submitted its annual amendment to Form ADV Part 2A ("Brochure") with regard to the following: Item 4 - Advisory Business: The section was updated for listing current owners of the firm and year-end 2025 assets under management; Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss: We updated this section to disclose our current lineup of investment strategies. We also added disclosures for Direct Indexing, Securities Backed Loans, Political Risk, and Artificial Intelligence; Item 12 - Review of Accounts: This section was updated for our current list of reviewers.
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Since our last ADV filing, we have the following material changes to disclose: (1) We have removed all references for transition assistance from Fidelity from Item 12: Brokerage Practices and Item 14: Client Referrals and Other Compensation. (2) Our Firm has appointed a new Chief Compliance Officer as of January 2026, Joseph Fantozzi, as displayed in Item 1: Cover Page.
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Jacobs & Company, LLC's Form ADV Part 2A dated February 2026 contains changes from the prior version dated August 2025 as follows: - Updated description of the Firm's assets under management at Part 2A, Item 4. - Added Sub-Advisor information Part 2A Items 4&5.
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"One Day In July LLC filed an annual updating amendment using the Form ADV Part 2A on January 30, 2026. With this amendment, ODIJ included a clarification regarding the environmental investing service, which focuses on low-carbon investment strategies. An additional clarification was made to explain that inaccurate or insufficient information provided to ODIJ about a client's retirement accounts could lead to incorrect calculations for required minimum distributions. Another material change included in this filing is that supervised persons of ODIJ, in addition to clients and compliance officers, have the authority to terminate an investment advisory contract, provided that the notification is delivered in writing. A fourth material change is that the tranche breakpoint inflation calculations have been changed to round up to certain defined increments. A fifth material change is that supervised persons of ODIJ can receive compensation for client referrals in the form of a monetary bonus or increased commission. ODIJ also added a disclosure about highly leveraged funds and cryptocurrency or digital currency-related assets. This annual updating amendment follows an interim amendment to ODIJ's ADV Part 2A that was filed on September 4, 2025, for the primary purpose of updating the firm's Chief Compliance Officer from Jayne Bills to Daniel Cunningham."
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Our firm has the material changes below since our initial filing dated April 11, 2025. Changes include: Item 4 – Updated Assets Under Management for year ending December 31, 2025; added language around held away assets with Pontera Solutions Inc. and Eaglebrook Advisors, Inc. platforms. Item 5 – Added language around billing and fees for held away assets on Pontera Solutions Inc. and Eaglebrook Advisors, Inc. platforms. Item 8 – Added disclosure language related to cryptocurrency investments. Item 14 – Added disclosure language around use of a Promoter and SmartAsset Advisors, LLC. Item 17 – Clarified that TVPW will not vote proxies unless separately agreed to; added service that monitors client holdings for legal proceedings and assists in recovery efforts.
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"We made the following material changes to our brochure with the annual update, dated June 23, 2025: Item 4 - Advisory Business and Item 5 – Fees and Compensation: • We updated the fees associated with our financial planning services. Item 17 - Voting Client Securities: • We discontinued class action-related monitoring and claim filing services."
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The following material changes to this Disclosure Brochure since the last annual amendment filing on March 4, 2025: • For certain Clients, the Advisor will include tax preparation through a third party as part of its wealth management services. Please see Items 5, and 10 for additional information. • The Advisor has an affiliated tax entity. Please see Item 10 for additional information.
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Since our last annual amendment filed on 03/11/2025, we have the following material change(s) to report: Our firm has established the Santa Barbara Trust Company, which is an affiliated trust company. We may refer clients to the Santa Barbara Trust Company when deemed appropriate. However, our firm's clients are under no obligation to use the Santa Barbara Trust Company for trust services. When the Santa Barbara Trust Company acts as a trustee or equivalent for our firm's clients, our firm is deemed to have custody of those client's assets. The client assets for which our firm has custody must be audited at least once during each calendar year by an independent public accountant at a time that is chosen by the accountant without prior notice to our firm and that is irregular from year to year.
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Since our last annual amendment filed on 03/11/2025, we have the following material change(s) to report: Our firm has established the Santa Barbara Trust Company, which is an affiliated trust company. We may refer clients to the Santa Barbara Trust Company when deemed appropriate. However, our firm's clients are under no obligation to use the Santa Barbara Trust Company for trust services. When the Santa Barbara Trust Company acts as a trustee or equivalent for our firm's clients, our firm is deemed to have custody of those client's assets. The client assets for which our firm has custody must be audited at least once during each calendar year by an independent public accountant.
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"Activest Wealth Management, LLC has made the following material changes since the previous Brochure dated March 12, 2025: Item 4 has been updated to reflect a change in the ownership structure and to include Activest providing portfolio management services to special purpose vehicles; Item 6 has been updated to include the method of calculation performance-based fees from private fund clients; Item 8 has been updated to include the method of analysis and strategies for managing the portfolio of special purpose vehicle clients."
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Since our most recent Form ADV Part 2A annual amendment filing, dated March 20, 2025, the following material changes have been made: Item 15: Custody due to Standing Letter of Authorization; Item 4, Item 5, Item 10: Disclose relationship with subadvisor.
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Since the last annual filing of this Form ADV Part 2A dated February 10, 2025, we have the following material changes to report. We have entered into an agreement with Envestnet Asset Management, Inc. to serve as a model provider for its Third-Party Separately Managed Account Models Program.
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This Brochure has been updated since the previous update filed with the Securities and Exchange Commission dated December 22, 2025, and discloses here the following material changes: • This Brochure has been updated to reflect (i) the removal of Accuidity, LLC as a relying advisor under FGA's umbrella registration; (ii) updates to the terminology used to describe the Firm's fund structures; (iii) clarifications regarding Forge Securities LLC's role as a placement agent; and (iv) modifications throughout the Brochure to reflect the Firm's current business practices.
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Since our last annual amendment filed on 02/24/2025, we have the following material change(s) to report: Our firm may provide cash or non-cash compensation directly or indirectly to unaffiliated persons for client referrals. Please see Item 14 for additional information.
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Since the filing of our last annual updating amendment, dated February 7, 2026, we have made the following material changes: (1) We now offer tax preparation and consulting services to clients of Goldstein Advisors, LLC. Tax-related services are separate and distinct from our Investment Management services and are governed by a separate agreement. Costs for these services are generally based on an hourly rate of $300/hour with minimum charges that vary depending on the type of return (e.g., individual, business, trust, or estate) as well as individual facts and circumstances. We also reserve the right to waive the fee under certain circumstances. You are not obligated to use our tax preparation services and you are always free to seek tax preparation and consulting services from outside service providers. (2) For clients of our Company, we occasionally offer client education and/or appreciation events. In certain instances, a third party financial company may reimburse our firm for a portion, or all, of the expenses incurred for the event.
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Since our firm's last filing on 11/13/2025, the following material changes have been made: The brochure has been amended throughout in connection with the launch of two new private funds sponsored and advised by Ignite Planners, Helion Strategies Horizon Fund and Helion Strategies Meridian Fund.
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"In this update, we elaborated upon fee payment practices and our fee schedule in Item 4. Additionally, we added our practices for alternative investments to the details of our advisory business in Item 6."
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In this update, we elaborated upon fee payment practices and our fee schedule in Item 5. Additionally, we added our practices for alternative investments to the details of our advisory business in Item 4. Additionally, please note that we have updated the Assets Under Management information of Item 4 in accordance with the filing of our Annual Updating Amendment on February 05, 2026.
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Since our last annual amendment filing, we now utilize third party managers for certain client accounts. Please see Items 4 and 5 below for further information. Additionally, we have lowered our maximum advisory fee to 1.25% of assets under management.
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"Since the last annual amendment filed on 03/19/2025, we have the following material changes to disclose: • The fee for our Cash Management services has been revised to 0.22% per annum. • Our Firm no longer offers standalone financial planning and consulting services. • Ms. Sharon Nassir has replaced Mr. Amir Monsefi as Chief Compliance Officer."
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Since our last annual updating amendment filed on March 31, 2025, we have made the following material changes to this brochure: (1) We updated our ownership information in Item 4 to reflect changes in how Emerald Advisors is structured and owned. (2) We updated our description of advisory services in Item 4 to reflect additional estate planning facilitation services delivered through a third-party technology platform. (3) We revised Item 5 (Fees and Compensation) to reflect updated fee arrangements under our current investment management and financial planning agreements, including our Investment Management Fee schedule and separate fixed fees for planning and consulting services. (4) We updated our regulatory assets under management as of December 31, 2025.
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The material changes in this brochure from the last annual updating amendment on March 28, 2025, of Weaver Consulting Group are described below. Material changes relate to Weaver Consulting Group's policies, practices or conflicts of interests. • Weaver Consulting Group may direct clients to third-party investment advisers. • Weaver Consulting Group utilizes PVG Asset Management as a third party money manager (Item 5). • Weaver Consulting Group utilizes Russell Investments as a third party money manager (Item 5).
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"Since the last annual filing of our Form ADV Part 2A, we have the following material changes to report: • Our firm has entered into a promotional relationship with an unaffiliated third party. • Our firm no longer offers portfolio management services through Launch."
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The material changes from the last annual updating amendment on March 10, 2025 are described below. Item 4: Added that the firm may give advice regarding investing in alternative investments such as private placements, and may assist accredited investor clients on IRC 1031 exchanges into DSTs and IRC 721 exchanges into REITs; also added recommendation of third-party estate planning tool from Wealth.com. Item 5: Added that assets under management will include private funds, private placements, DSTs, and REITs in fee calculations; added one-time coordination/set-up fee for Wealth.com service. Item 8: Added disclosures about risks of investing in private placements, private funds, DSTs, and REITs. Item 14: Added disclosure that securities issuers may pay or reimburse the firm for certain costs or sponsorships, creating a conflict of interest.
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"The material changes in this brochure from the last annual updating amendment of Spinnaker Investment Group, LLC on March 10, 2025, are described below." Items changed: Item 4 (added advisory services for alternative investments, private placements, IRC 1031/721 exchanges); Item 5 (added fee calculation methodology including private funds, DSTs, REITs); Item 8 (added risk disclosures for private placements, funds, DSTs, REITs); Item 14 (added disclosure about securities issuers paying costs/sponsorships); Item 15 (added custody disclosure regarding standing letters of authorization).
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The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on March 6, 2025: The Advisor has amended Item 10 to disclose a relationship with an affiliated trust company. The Advisor has amended Item 10 to disclose that in certain instances they may cover fees for services provided by an affiliated entity. The Advisor's primary office address is 358 N Main Street, Suite 100, Wichita, KS 67202. The Advisor offers the selection of other advisors. Please see Items 4, 5, and 14 for additional information. The Advisor's phone number is now (316) 262-6578. The Advisor's facsimile number is now (316) 262-1447.
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Since the last annual amendment dated March 28, 2025, the following material changes have taken place: Promethos Capital has changed the name of the Global Small Cap Gender Forward Strategy to "Global Small Cap Strategy" to better reflect the strategy's investment approach. Effective January 2026, Suzanne Kellogg became CCO of Promethos Capital.
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Since the last annual amendment on March 17, 2025, Item 5 has been materially updated with respect to our managed account fee schedule. Item 4 has been revised to include additional disclosure regarding our advisory business.
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The following material changes have been made to this Disclosure Brochure since its last filing and distribution to clients: (1) The Advisor has established an institutional relationship with Fidelity. Please see Item 12 and 14 for additional information. (2) The Advisor offers a wrap fee program. Please see Item 4 and Appendix 1 for more information.
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We have made some changes since the last annual update of our brochure which was filed on March 26, 2025, that may be considered material, which are: Item 1: • Added the following to websites: o https://www.flirtingwithmodels.com o https://www.returnstackedetfs.com Item 8: • Added risks associated with Return Stacked® U.S. Stocks & Gold/Bitcoin ("RSSX") which was launched in 2025. • Updated the description of Leverage Risk to make clear that return stacking employs leverage. Item 10: • Added information about a new agreement Newfound entered into as a co-promoter of Return Stacked® Global Balanced and Macro ETF ("RGBM") Item 12: • Updated to indicate that Newfound does have trading authority over the portion of the Return Stacked® Balanced Allocation & Systematic Macro Fund that the Firm subadvises.
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The material changes in this brochure from the last annual updating amendment of Oak Root, LLC on 03/19/2025 are described below. Material changes relate to Oak Root, LLC's policies, practices or conflicts of interests only. • Item 7 – Types of Clients – updated to include Individuals.
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As of March 18th, 2025, there have been material changes to Items 4, 5, 10, and 14 to disclose GWAG's insurance relationship with Halo Investing Insurance Services, LLC. Furthermore, as of September 2, 2025 the Garrett Wealth Advisory Group, LLC has transitioned to a fee-only model where the only compensation the Firm and its employees receive is related to the investment management fee charged to its clients; neither the Firm nor its employees receive commissions on any securities or other product sales.
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Stonebrook has amended its Disclosure Brochure to reflect the following changes: Item 4 updated to include information on Stonebrook's wrap fee program. Item 12 updated to reflect the addition of Charles Schwab as a custodial option.
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The Firm has made changes since the last update to its brochure dated September 11, 2025, that may be considered material. They include: Item 4 – Advisory Business: Updated client assets as of December 31, 2025. Item 5: Fees and Compensation: Added GVA Series - Natural Resources Fund's fee schedule. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss: Added GVA Series - Natural Resources Fund. Item 10: Other Financial Industry Activities and Affiliations: Added new related persons. Modified descriptions of related persons. Item 14: Client Referrals and Other Compensation: Added that MAP engages a business consultant to provide endorsements or other business development support. Item 15: Custody: Added related person deemed to have custody of client funds and securities since they are general partners to various private funds.
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The following material change was made to this Brochure since the last annual update issued on March 12, 2025: The firm no longer takes discretion with respect to voting proxies on behalf of clients. Please refer to Item 17 of this Brochure for more information.
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We made the following material change: ● Item 15 - Custody: We accept custody of certain client funds or securities for various client situations.
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Material Changes: We are no longer offering stand alone financial planning. We have removed reference to this service. We have updated Item 5 to reflect that our management fees are not negotiable.
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The following are changes that have been made since the last Annual Amendment filing made on March 18, 2025: The firm's main office location moved to 1331 17th Street, Suite 800 Denver, CO 80202. The Texas office moved to 14101 US-290 Bldg. 1100, Suite 219, Austin, TX 78737. The firm added two new offices in Illinois: 350 S. Northwest Hwy, Suite 300 Park Ridge, IL 60068; 2020 Calamos Court Naperville, IL 60181; 1900 E. Golf Road, Suite 950 Schaumburg, IL 60137. Item 4 was updated to reflect: Maia Wealth does business as Miedema Wealth and no longer does business as Hofkin Capital Management or Cookie Wealth; Maia Wealth provides investment consulting services to certain broker/dealers' customers; Maia Wealth partners with unaffiliated, third-party, estate planning specialists; Maia Wealth partners with unaffiliated, third-party, tax service specialists. Item 5 was updated to reflect consulting fee structure, estate planning coordination service fees, and tax coordination service fees. Item 10 was updated to reflect various disclosures.
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Section 2 lists multiple material changes since the last Annual Amendment filing (March 18, 2025): main office moved to 1331 17th Street, Suite 800 Denver, CO 80202; Texas office moved to 14101 US-290 Bldg. 1100, Suite 219, Austin, TX 78737; three new Illinois offices added in Park Ridge, Naperville, and Schaumburg; Item 4 updated to reflect doing business as Miedema Wealth, new consulting services for broker/dealer customers, and partnerships with estate planning and tax service specialists; Item 5 updated with new fee structure for Brokerage Customers (0.50% to 0.85% basis points), estate planning coordination fees ($500-$2500), and tax coordination fees ($120-$2500); Item 10 updated with disclosures for Financial Institution Consulting Services and third-party specialist partnerships.
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"Material changes since the last annual amendment dated March 24, 2025: Fidelity has been added as a Custodian. In July, ARQ updated item 4 and item 7 to reflect the new AUM minimum of their Wealth Builder Service to now be $250k. In June, ARQ updated its address to 8605 E. Raintree Dr, Suite 240, Scottsdale, AZ 85260."
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Since the last annual update of this brochure was filed in February 2025, we updated Item 4 to clarify and refine the types of investments for which we provide advisory services. In addition, we removed the Part 2B Brochure Supplement for John Klee, as he is no longer with our firm.
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The material changes in this brochure from the last annual updating amendment of PWA on March 8, 2025 are described below. Material changes relate to PWA's policies, practices or conflicts of interests. Changes include: (1) Peterson Wealth Advisors, LLC offers investments in direct indexing (Item 8); (2) Peterson Wealth Advisors, LLC utilizes solicitors for client referrals (Item 14); (3) Peterson Wealth Advisors, LLC has added Fidelity Brokerage Services LLC (CRD#7784) as an additional custodian; (4) Peterson Wealth Advisors, LLC updated its firm ownership (Item 4); (5) Peterson Wealth Advisors, LLC added Cryptocurrency as a recommended instrument (Items 4 and 8); (6) Peterson Wealth Advisors, LLC receives royalties for books authored by Scott Peterson (Item 14).
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BCM Advisors, LLC made the following material changes to Form ADV, Part 2A since its Annual Updating Amendment dated February 18, 2025: 1) Updates to Advisory Services and ERISA Disclosures; 2) Updates and Clarifications to Fee Schedules and Billing Practices; 3) Updates to Referral and Compensation Disclosures; 4) Custody and SLOA Clarifications; 5) Update to Third-Party Administrator Disclosure (BAM to Focus Partners); 6) Change in Chief Compliance Officer (Lenox Brown replaced Hille Domingue); 7) Conforming and Clarifying Edits.
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The following material changes were made: Item 4: Advisory Business - Highline Wealth Partners ("HWP") has entered into a services agreement to provide limited back-office, administrative, technology, and strategic support services to select consultants for a fee; Item 5: Fees and Compensation - HWP recently added Enterprise Support Services' fee structure for those services to this brochure; Item 10: Other Financial Industry Activities and Affiliations - HWP's parent company, Highline Holdings, Inc. ("HHI") has created two companies which represent other financial industry affiliations: (1) Highline Ventures 1, LLC, and (2) Oak Park Real Estate Advisors LLC.
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Since our last annual update, dated April 4, 2025, we made the following material changes hereto: Item 4 is being amended to describe Engaged Capital's co-investment practices, including the use of special purpose vehicles ("SPVs") that, in some cases, may include only Supervised Persons. Item 5 is being amended to incorporate additional fees and compensation considerations in connection with co-investments. Item 6 is being amended to include additional descriptions of allocation and related conflicts arising from the side-by-side management of Funds, Managed Accounts and co-investment vehicles (including SPVs that may include only Supervised Persons). Item 9 is being amended to provide disclosure regarding the issuance of an order by the SEC. Item 11 is being amended to provide additional disclosure regarding co-investment arrangements, including investments by Engaged Capital and its Supervised Persons through affiliated SPVs and related conflicts of interest and allocation practices.
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Since our last annual update, dated April 4, 2025, we made the following material changes hereto: Item 4 is being amended to describe Engaged Capital's co-investment practices, including the use of special purpose vehicles (SPVs); Item 5 is being amended to incorporate additional fees and compensation considerations; Item 6 is being amended to include additional descriptions of allocation and related conflicts; Item 9 is being amended to provide disclosure regarding the issuance of an order by the SEC; Item 11 is being amended to provide additional disclosure regarding co-investment arrangements.
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We made the following changes to this Brochure: Item 8 was amended to reflect the use of interval funds. Item 10 was amended to remove Robert Canterbury as a licensed insurance agent. Historical Change - April 4, 2025 Update: Items 4 and 5 were amended to reflect that Dopkins Wealth can also engage Independent Managers to invest client assets within a diversified equity portfolio structured as a separately managed account (SMA).
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Since the last Annual Amendment filing dated March 4, 2025, the Firm has the following Material Changes to report: This Form was updated to reflect the inclusion of options strategies to our investment approach. Please see Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss).
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Since our last Annual Amendment ADV filing made on February 14, 2025, the following are material changes to our firm disclosure brochure: Item 10 has been amended to remove language and disclosure regarding certain Investment adviser representatives were affiliated with an independent broker dealer. Item 4 and 10 have been updated to reflect language regarding the services provided by Heirloom Tax Solutions and conflict language regarding common ownership between the Firm and Heirloom Tax Solutions. Item 4 and 5 have been amended to disclose information regarding our management of held-away accounts and their related management fees. Information has been updated to reflect our standalone financial planning services and related fees. Item 12 has been updated to reflect the use of Fidelity as one of the recommended Custodians.
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The following material changes have been made to this Disclosure Brochure since the annual amendment filing on March 5th, 2025: • The Advisor has amended its ownership structure. Please see item 4 for additional information. • The Advisor has updated its disclosures and fees associates with Fiduciary Trust Administrative Services. Please see Item 4 – Advisory Services, Item 5 – Fees and Compensation, Item 10 – Other Financial Industry Activities and Affiliations and Item 14 – Client Referrals and Other Compensation for additional information. • The Advisor has implemented a new estate-settlement service and associated fee. Please see Item 4 – Advisory Services, Item 5 – Fees and Compensation, Item 10 – Other Financial Industry Activities and Affiliations and Item 14 – Client Referrals and Other Compensation for additional information.
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This version of the Freedom Wrap Fee Program Brochure ("Brochure") includes material changes since the last annual Brochure filing dated March 31, 2025. On June 6, 2025, an Asset Purchase and Contribution Agreement was made by and among GeoWealth Management LLC, a Delaware limited liability company, GeoWealth, LLC, a Delaware limited liability company (collectively GeoWealth) and Freedom Investment Management, Inc., an Illinois corporation whereby Freedom sold certain assets to GeoWealth. Updated physical and mailing addresses for Freedom. New mailing address: PO Box 1131, South Windsor, CT 06074. New office address: 1635 Ellington Rd., 3rd Floor, South Windsor, CT 06074. Updated Proxy Voting procedures. As noted in prior communications, effective July 2025, Freedom Investment Management is no longer voting proxies on behalf of clients. Freedom no longer charges different platform fees for UMA accounts.
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"This Brochure has been updated to reflect the following changes since the last annual updating amendment on March 31, 2025: (1) Updated Item 4 - Change effective August 1, 2025 - Advisory Business to reflect an Asset Purchase and Contribution Agreement was made by and among GeoWealth Management LLC, GeoWealth, LLC, and Freedom Investment Management, Inc.; (2) Updated physical and mailing addresses for Freedom. Change effective January 1, 2026 - New mailing address: PO Box 1131, South Windsor, CT 06074. New office address: 1635 Ellington Rd., 3rd Floor, South Windsor, CT 06074; (3) Updated Item 17 - effective July 2025, Freedom Investment Management is no longer voting proxies on behalf of clients."
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We amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Securities Backed Lines of Credit (SBLOCs), and Artificial Intelligence ("AI") Risk.
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"Rockport Wealth, LLC, dba 'Rockport Wealth Advisors' has the following material changes to report since its last amendment to this Brochure filed September 10, 2025." The filing documents: address change to 7227 Glenwood Avenue, Youngstown, OH 44512; J Arnold Wealth Management acquisition details including conflict of interest disclosure; private placement policy clarification; Strategic Models service description; new fee schedule ($0-$500K: 1.25%, $500K+: 1.00%); updated account minimum to $250,000; qualified client definition; multiple new risk disclosures; and proxy voting policy update.
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"Since our last annual updating amendment dated March 27, 2025, we have made the following material changes: (1) Modified language in Item 5 to reflect that fees begin accruing on the business day assets are received; (2) Added additional details in Item 8 regarding the functioning of MWM's Investment Committee; (3) In Item 16, added clarifying language that any client directed restrictions or prohibitions in accounts granted discretion must be provided in writing; (4) Added language in Items 4 and 10 regarding the use of sub-advisors as part of our investment management services."
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The following material changes have been made to this Disclosure Brochure since the annual amendment filing on February 24, 2025: (1) The Advisor now requires a minimum relationship size; (2) Certain Advisory Persons are also licensed as independent insurance professionals; (3) The Advisor is now deemed to have custody over certain Client accounts and securities; (4) The Advisor has amended its financial planning fees.
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"Since the last annual update to this brochure, filed in January 2025, the following material changes have been made. Item 4 has been updated to better describe our Discretionary Investment Advisory Account Management services."
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Following is a summary of the material changes to the Brochure since that time: November 20, 2025 - COVER PAGE: Added Suite 2; ITEM 4C Services: Removed the Manager Selection option; ITEM 5A Fees: Revised the asset-based fee option to narrow the fee range and state that fees can be charged monthly or quarterly, Revised the fixed fee option to state that fees can be charged monthly or quarterly, Added the performance-based fee option for qualified clients, Removed the Manager Selection information; ITEM 6 Performance-based Fees: Added disclosures regarding performance-based fees and side-by-side management, including information about associated conflicts of interest.
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We submitted our required annual amendment to regulators on 02/23/2026 for the firm's fiscal year ending 12/31/2025. We updated Item 8 with information regarding political risks and material risks associated with using security backed lines of credit and artificial intelligence.
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Since the last version of this brochure dated March 26, 2024, we made the following material changes to this brochure: Item 4 has been amended to remove language referencing the use of proprietary model portfolios by our firm. Client portfolios are tailored and managed in accordance with our understanding of your unique financial circumstances, investment objectives, needs, and limitations. We do not use model portfolios to manage client accounts.
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Since the last version of this brochure dated March 26, 2024, we made the following material changes to this brochure: Item 4 has been amended to remove language referencing the use of proprietary model portfolios by our firm. Client portfolios are tailored and managed in accordance with our understanding of your unique financial circumstances, investment objectives, needs, and limitations. We do not use model portfolios to manage client accounts.
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"Since the last Annual Updating Amendment, dated February 19, 2025, Hilltop Wealth Advisors has the following material changes to report: • The Firm has updated its services. (Item 4) • The Firm utilizes a blended fee, meaning that different rates are charged on different tranches of assets under management in accordance with the fee schedule. (Item 5) • The Firm has updated its standard fee schedule and service level fees (Item 5)"
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Since the last annual update was filed on February 19, 2025, this Brochure has been materially amended as follows: At Item 5 to disclose the potential for additional fees charged by separate account managers and investment platforms. At Item 8 to specify that the firm does not engage in the use of options trading strategies directly and to incorporate risk disclosures concerning the use of closed-end funds.
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January 2025 – Added Axos Advisor Services due to custodian change. Removed AJ Johnson and added Anne Coe due to personnel changes. June 2025 – Added Shane Kozusko to advisor role.
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Item 5 – Revised pro rata language to clarify calculations for initial billing period. Item 12 – Added Altruist Financial LLC as a recommended broker-dealer.
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Since the Adviser's last Form ADV Part 2A annual amendment was filed in March 2025, the Adviser notes the following material changes: (1) Item 4 (Advisory Business) updated to reflect RAUM as of November 30, 2025; (2) Item 4 updated for additional information about self-directed trading services; (3) Item 4 and Item 12 updated for order handling information; (4) Item 14 updated to include a link to Promoter Disclosure Statement; (5) Item 17 updated to reflect proxy voting responsibilities.
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Since the Adviser's last annual amendment in March 2025, we note the following material changes: The Brochure has been updated to reflect changes made to the Adviser's Form ADV Part 2A Brochure, including additional information about the Adviser's self-directed trading services, a link to the Adviser's Promoter Disclosure Statement and proxy voting responsibilities.
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This brochure replaces the last version dated March 2025 and contains updated information and clarifying disclosures as warranted. In addition, this brochure also includes the following material updates: The East Bridge Capital Select Fund LP and East Bridge Capital Master Fund Ltd. were liquidated in 2025. Liquidation audits were performed and distributed to all underlying investors. All references to these two funds have been removed from the Brochure. Item 7 - The investment minimum range was updated to $1,000,000 to $5,000,000. Previously it was $2,000,000 to $5,000,000. Item 11 - Clarified controls in place to mitigate the conflicts associated with employee personal trading.
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Since the last annual amendment filed on February 11, 2025, we have the following material changes to report: Item 4 and Item 8 were updated to clarify the firm's use of Structured Notes, as an investment option. Item 5 and Item 10 were updated and all mentions of Purshe Kaplan Sterling Investments (PKS) were removed, as our firm is no longer affiliated with PKS.
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The EdgeCo loan which was originated by an Investment Adviser Representative of the Firm as his Outside Business Activity was paid off in its entirety in 2025 with all investors receiving repayment of their principal loan balance as well as all of their scheduled interest payments.
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Since our last annual amendment filed on March 11, 2025 the following material changes were made: Item 4 Advisory Business. Townsend updated its principal owners and its assets under management as of December 31, 2025. Item 10 Other Financial Industry Activities and Affiliations. Added information regarding tax preparation services offered by Townsend.
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This firm brochure reflects the following material changes since the previous version dated March 24, 2025. Changes include: (1) registration transition from SEC to state-level (California/Utah); (2) office relocation to 500 N Street, Suite 30, Sacramento, California 95814; (3) Bradley R. Harsch became sole owner and managing principal; (4) discontinuation of retirement plan consulting services to pension, profit sharing and 401(k) plans; (5) updated fee schedule (annual asset-based fee of 1.00%-2.00%, fixed fee up to $5,000 or hourly fee up to $350/hour for financial planning); (6) new AI-based notetaking disclosure.
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"Since our last annual update to the Brochure dated January 1, 2025, we made the following changes: We have made updates to Item 15 to add disclosure for the use of third-party Standing Letters of Authorizations 'SLOAs'; whereby clients give us authorization to initiate transfers between non-like titled accounts with the clients' custodian(s). We updated our Principal office and place of business address to remove the 'SW' after the Suite number to conform with USPS address updates. No physical change to the office location occurred. The Firm's founder, Jeffrey McClarren, retired at the end of 2025 and Alexis Cunningham obtained a small percentage of ownership in the firm. Updates to Item 5 for fee range; Item 7 to include additional disclosure related to investable assets; Item 11 to update COE to better align with current policies and processes; Item 12 to update disclosures to reflect current operations; Item 16 to provide additional clarity regarding MFA's discretionary and non-discretionary authority; and Item 18 to correct a typographical error."
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Since our last Brochure dated September 25, 2025, the firm has had the following material changes: Removal of wrap fee program option from Item 4; Inclusion of a range for hourly financial planning services (See Item 5); Increase in the fee tiers for accounts managed by a sub-adviser (See Item 5)
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"A material changes since the Firm's last annual amendment includes an update to disclosures regarding the Firm's use of artificial intelligence–enabled tools. The Firm has clarified that any artificial intelligence tools utilized are limited to administrative and operational support functions, such as meeting transcription or summarization. The Firm does not use artificial intelligence tools to make autonomous investment decisions, formulate investment advice, or execute transactions."
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During the firm's last annual updating amendment on February 24, 2026, the following material changes have occurred: Item 4 was amended to remove reference to Securities Based Line of Credit. Item 10 was amended to clarify the ownership structure of The Sum Prep, LLC.
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Item 2 states: "As of 12/31/2025 our firm has transitioned nearly all client relationships to Sequoia Financial Group. We will be withdrawing our registration with the U.S. Securities and Exchange commission in the first quarter of 2026."
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The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on January 29th, 2025: The Advisor now offers Retirement Plan Advisory Services. Please see Items 4 and 5 for additional information.
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On February 23, 2026, we submitted our annual updating amendment filing for fiscal year 2025. We amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Securities Backed Lines of Credit (SBLOCs), Political Risk and Artificial Intelligence ('AI') Risk.
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Since our last annual amendment filed on March 4th, 2025, we have the following material changes to disclose: (1) Pinnacle Peak Private Client Group will be acquired and services will be transferred to a new firm, thus this will be the last annual amendment filing for PPPCG; (2) Pinnacle Peak Private Client Group LLC's affiliate Insight Benefit Counselors, LLC has ceased operations, but the same services that IBC offered will still be available to clients through Pinnacle Peak Private Client Group directly, including fiduciary educational services to federal employees concerning thrift saving plans and various retirement products, and life and disability insurance services.
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The material changes in this brochure from the last annual updating amendment of FSA Advisors on January 24, 2025 are described below. Material changes relate to FSA Advisors' policies, practices or conflicts of interests. FSA Advisors has updated their Assets Under Management (Item 4.E), Description of the Advisory Firm (Item 4.A), Fee Schedule (Item 5.A), Outside compensation for the sale of securities to clients (Item 5.E), Methods of analysis and investment strategies (Item 8.A), Material risks involved (Item 8.B), Registration as a broker dealer or broker dealer representative (Item 10.A), Registration relationship materials to this advisory business and possible conflict of interest (Item 10.C), Investing, personal money in the same securities as clients/trading securities at/around the same time as client securities (Item 11.C), Frequency of nature of period review reviews and who make those reviews (Item 13.A), Compensation to non-advisory personnel for client referrals (Item 14.B).
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Since the last filing of this brochure on February 7, 2024, the following has been updated: Updates made throughout the Brochure (Items 4, 5, and 13) describing the firm's newly offered retirement planning services. Item 10 has been updated describing the tax preparation services provided through the Firm's affiliated tax firm.
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The material changes in this brochure from the last annual updating amendment of MWM on 02/04/2025 are described below. Material changes relate to MWM's policies, practices or conflicts of interests. • MWM has updated its Primary office address. (Cover Page) • MWM has updated their Assets Under Management (Item 4). • MWM has updated other business activities. (Item 10)
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"The following material changes have been made to this Disclosure Brochure since the annual amendment filing on February 4th, 2025: (1) The Advisor has amended its fees and billing methodology for wealth management services. The Advisor has also implemented a minimum annual fee. (2) When deemed to be in the Client's best interest, the Advisor may recommend Clients utilize one or more unaffiliated investment managers or investment platforms. (3) The Advisor has established an institutional relationship with Charles Schwab & Co., Inc. (4) The Advisor may introduce Clients to engage SyntheticFi LLC to manage a portion of a Client's investment portfolio."
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"The material changes in this brochure from the last annual updating amendment of Arcadia Wealth Management, LLC on February 10, 2025, are described below." Plus 11 specific changes: removed Joel Silloway (Item 10.C), updated fees (Item 5.A), updated Held-Away Assets information (Item 4.B), updated Portfolio Management Fees language (Item 5.A), removed Held-Away Assets fees (Item 5.A), updated household minimum (Item 7), updated Methods of Analysis and Investment Strategies (Items 8.A and 8.B), added Custodial Platform Configuration information (Item 12), updated Financial Conditions information (Item 18.B), updated Pension Consulting Services language (Items 4.B and 5.A), updated Client Responsibility for Third-Party Fees language (Item 5.C).
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"The material changes in this brochure from the last annual updating amendment of Arcadia Wealth Management, LLC on February 10, 2025, are described below. Material changes relate to Arcadia Wealth Management, LLC's policies, practices or conflicts of interests." followed by nine specific changes: (1) Removed Joel Silloway, (2) Updated fees, (3) Updated Held-Away Assets information, (4) Updated Portfolio Management Fees language, (5) Removed Held-Away Assets fees, (6) Updated household minimum, (7) Updated Methods of Analysis and Investment Strategies, (8) Added Custodial Platform Configuration information, (9) Updated Financial Conditions disclosure.
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The following material changes have been made to this Disclosure Brochure since the annual amendment filing on February 19, 2025: The Advisor has added Trustee Services as an offering to Clients; The Advisor as a result of offering Trustee Services to Clients will have custody of certain Client accounts. As a result of having custody the firm has amended Item 15 to reflect this update along with the firm being subject to a surprise audit.
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Since the previous annual update (March 2025), there have been material changes to the firm's advisory business or practices. The following are material changes that have occurred. 1) The firm has added investment management as an advisory service. "Item 4 – Advisory Business" and "Item 5 – Fees and Compensation" have been accordingly changed. 2) Item 10 has been updated. The firm's Supervised Persons are no longer broker-dealer registered representatives of J.W. Cole Financial or investment adviser representatives of J.W. Cole Advisors. 3) The firm is registered with the Securities and Exchange Commission.
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"The following changes were made to this Firm Brochure since our annual amendment filing on 03/18/2025: Item 4: Advisory Business was updated to reflect assets under management as of December 31, 2025. Item 7: Types of Clients was updated to include retirement plans."
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Effective January 1, 2026, the Firm made the following material changes to its Form ADV Part 2A: (1) Advisory Fee Reduction - The Firm reduced its maximum annual investment advisory fee from 2.00% to 1.75%; (2) Insurance Services - The Firm no longer offers life insurance and annuity products and does not receive commissions or other compensation in connection with the sale or implementation of life insurance.
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Tealwood added company-sponsored retirement plan consulting services to our service offerings.
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Since our last other than annual amendment filed on March 28, 2025, the following material changes have occurred: Item 4 has been amended regarding ownership; Item 5 has been amended regarding outside business activities; Item 13 has been amended regarding reports offered to clients.
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Since our annual amendment last filed on February 12th, 2025, our firm has the following material changes to disclose: (1) Our firm has appointed Derek Finch as Chief Compliance Officer of Seaside Wealth Management, Inc. (2) Our firm now recommends and utilizes the services of third-party money managers. (3) Our firm has increased our minimum account balance for our asset management service to $1,000,000.
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Since the date of its last annual amendment (January 29, 2026), Briggs Wealth Management, Inc. has made the following material change to this disclosure brochure: Item 4 – Advisory Business: Disclosed the use of third-party money managers. Item 5 – Fees and Compensation: Updated fee schedule (AUM fees: First $1M at 1.25%, Next $2M at 1.00%, Over $3M at 0.75%; Financial Planning fixed fees $5,000-$10,000; Hourly fees $150-$500; Executor services hourly $350-$500 professional, $150-$250 support). Item 7 – Types of Clients: Raised minimum quarterly fee to $3,000 (annual $12,000) for portfolio management services.
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Since the date of its last annual amendment (January 29, 2026), Briggs Wealth Management, Inc. has made the following material change to this disclosure brochure: Item 4 – Advisory Business: Disclosed use of third-party money managers. Item 5 – Fees and Compensation: Updated fee schedule (AUM fees reduced; financial planning fixed fees now $5,000-$10,000; hourly fees $150-$500). Item 7 – Types of Clients: Raised minimum quarterly fee to $3,000 ($12,000 annually).
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"Since the filing of our last annual updating amendment, dated March 7, 2025, we made the following material change to our Form ADV: 1. We no longer have custody for keeping client usernames and passwords. 2. Standing Letter of Authorization - Our firm, or persons associated with our firm, may effect wire transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, as long as the client has provided us with written authorization to do so."
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"The following material changes have been made to the Firm's Brochure since the last annual update amendment on February 28, 2025. • Item 5 - IMPAC and Passport programs through Raymond James & Associates, Inc. will no longer be offered after March 31, 2026. • Throughout this brochure, Karras has further defined the firm's relationship with Raymond James Financial Services, Inc. (RJFS) and Raymond James & Associates, Inc. (RJA) collectively, "Raymond James". RJFS is the registered broker dealer and Member FINRA/SIPC. RJA is the qualified custodian and Member NYSE/SIPC. Investment adviser representatives of Karras are also registered representatives of RJFS."
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This section of the brochure discusses specific material changes that have been made to the brochure since the firm's last annual update in March 2025. Below is a summary of those changes. • Item 12 – Brokerage Practices: Effective October 1, 2025, through March 31, 2026 (or beyond if the program is extended), TradePMR is offering an asset match program to clients of Virginia Wealth Management on new funds and investments transferred into an advisory account managed by Virginia Wealth Management on the TradePMR brokerage platform.
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We have updated our assets under management and made changes in Item 4.
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"Since the filing of the annual update Brochure dated March 27, 2025, we updated detail about our brokerage practices and have made other minor updates but no other material changes were made."
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Since the last amendment on December 12th, 2025, we made the following material changes; Item 5 Fees and Compensation - We modified when we reconcile client accounts to their custodian/brokerage statements
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The firm made the following material change from the last annual update of this Brochure issued in March 2025: As part of its portfolio management services, FORUM may recommend one or more third-party sub-advisers to manage all or a portion of the client's investment portfolio.
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The firm made the following material change from the last annual update of this Brochure issued in March 2025: As part of its portfolio management services, FORUM may recommend one or more third-party sub-advisers to manage all or a portion of the client's investment portfolio.
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The following material changes occurred since the last filing on 2/5/2025: Item 4, added the addition of flat fee investment management for certain accounts; Item 6, added additional investment management risks; Item 9, added information about certain broker dealer licensed individuals who participate in investment banking activities
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"The following material changes occurred since the last filing on 2/5/2025: Item 4 and 5, added information about LeClair Wealth Partners participation in the Zoe digital platform and certain individuals participating in broker dealer transactions; Added language throughout the Brochure about the addition of Charles Schwab & Co., Inc. and Apex (Zoe) as additional custodians; Item 8, added a description of LeClaire's limited use of artificial intelligence and additional risks related to derivatives, hedging and artificial intelligence; Item 10, added information about certain individuals participating in broker dealer transactions through a broker dealer investment banking affiliate; Item 12 and 14, added information about benefits received from custodians."
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Since our last filing on January 30, 2025, there were material changes made to the brochure. • Item 4: Advisory Business • Item 5: Fees and Compensation
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We are required to advise you of any material changes since our last annual update in March 2025. The following material changes have occurred since that update: We have made Flourish Cash, an online cash management solution, available to our clients. In addition to Schwab, Fidelity Brokerage Services LLC is now being used as a qualified custodian for client accounts.
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The material changes in this brochure from the last annual updating amendment of Old Slip Registered Investment Advisors, LLC on 03/13/2025 are described below. Material changes relate to Old Slip Registered Investment Advisors, LLC's policies, practices or conflicts of interests. Old Slip Registered Investment Advisors, LLC updated its investment discretion disclosure (Item 16).
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The following material changes have been made to this Disclosure Brochure since the annual amendment filing on February 19, 2025: • The Advisor now offers sub-advisory services. Please see Item 4 for additional information.
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The following changes were made since our last other annual amendment filing on February 27, 2025: The firm's main office location has moved to 1800 Wazee Street, Suite 300, Street 300 Denver, CO 80202. Item 4 was updated to include: Investment-only service offerings; The DBA name Entrepreneur Align, is no longer being used. Item 5 was updated to reflect new pricing descriptions for Destiny for Entrepreneur Services, investment-only services and new hourly pricing payment options for stand-alone financial planning. Item 5 was also updated to include further descriptions regarding financial institution consulting fees and platform provider fees. Destiny Capital no longer provides investment consulting services to certain broker/dealers' customers (Brokerage Customers). Item 10 was updated to include: One of our associated persons is a licensed insurance agent.
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"The material changes in this brochure from the last annual updating amendment of Greenberg Financial Group on March 21, 2025, are described below." Four changes: (1) Todd Glick is now serving as Chief Compliance Officer of Greenberg Financial Group; (2) Greenberg Financial Group has disclosed insurance activities (Item 10); (3) Greenberg Financial Group has updated its Brokerage Practice disclosures (Item 12); (4) Greenberg Financial Group has updated Client Referrals and Other Compensation (Item 14).
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This brochure contains changes made from our last update of this brochure dated September 2025. The following is a summary of those changes: Item 4 of the brochure, "Advisory Business", was updated to reflect engaging with Orion Portfolio Solutions and Vise AI Advisors, LLC as additional Third-Party Managers available on the platform. Item 5 of the brochure, "Fees and Compensation", was updated to reflect compensation structure of Orion Portfolio Solutions and Vise AI Advisors, LLC. Item 8 of the brochure, "Methods of Analysis, Investment Strategies and Risk of Loss" was updated to include information regarding Alternative Investments and Variable Universal Life and the removal of the Dividend & Income Model. Item 14 of the brochure, "Client Referrals and Other Compensation", was updated to include information regarding the use of third-party promoters to refer clients.
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"We no longer provide proxy voting services to existing Legacy FDM clients."
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The following material changes have been made to this Disclosure Brochure since the initial filing on January 6, 2025: This ADV amendment completes the 120-day SEC filing. Please see Item 4 for updated Assets Under Management. Items 4 and 5 have been amended to reflect that Shrier Wealth Management now makes available to Clients asset management services for donor-advised funds.
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Since our last annual amendment: We have updated Item 12-Brokerage practices and Item 14-Client Referrals and other Compensation to reflect our participation in the TradePMR Custody and Asset Match Program. Additionally, we have updated Item 8- Methods of Analysis, Investment Strategies to reflect the inclusion of ETFs benchmarked to cryptocurrency or digital asset markets, which may involve heightened market and regulatory risks.
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"We performed an overhaul of our ADV 2A Appendix 1 Wrap Fee Brochure with the annual update, dated February 24, 2026, with material and non-material revisions made throughout the brochure. Due to the number of changes that we have deemed material, we are providing a complete copy of the amended brochure to all affected clients."
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We made the following material changes to our brochure with the annual update, dated February 24, 2026: Item 4– Advisory Business, Item 5– Fees and Compensation, Item 6– Performance-Based Fees and Side-By-Side Management, Item 7– Types of Clients, and Item 8– Methods of Analysis, Investment Strategies and Risk of Loss: We added private investments to the types of securities that we may utilize in client accounts.
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We have the following changes to report since our last update dated May 12, 2025: 1) The Firm's Pennsylvania branch office location has been closed and removed from Page 1. 2) The Firm's Assets Under Management in Item 4 has been updated to reflect current figures. 3) Added language in Item 5 regarding Goldman Sachs and the manner in which its fees are deducted. 4) Added language in Item 10 concerning Inception Financial Solar, LLC. 5) Added language in Item 14 describing the Firm's use of advertisements that include interviews of current clients.
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On our last update dated February 18, 2026, we have amended Item 4 and Item 5 to reflect our estate planning service addition.
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"The material changes in this brochure from the last annual updating amendment to this Wrap Fee Program Brochure on 02/07/2024 are described below. Material changes relate to Rede Wealth, LLC's policies, practices or conflicts of interests only." • Item 4 has been updated to reflect the firm's updated fee schedule. • Item 6 has been updated to reflect the firm's practice of not voting proxies on behalf of clients. • Item 9 has been updated to reflect the firm's practice of performing account review annually rather than quarterly. • Item 9 has also been updated to remove a reference to a loan that has been paid in full since the prior amendment of this brochure.
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As of September 2024, the Advisor has amended the Firm's Brochure to disclose the new ownership structure whereby Mr. Paul McIntyre (49%) and Ms. Robin Whitlock (51%). Ms. Whitlock's title was updated to Chairperson. Additionally, information related to soft dollars was revised. Furthermore, the number of accounts and reportable assets under management were revised and updated the Custodians that are currently available for client accounts. Lastly, the firm amended its client agreement by eliminating retroactively, for all firm accounts, the liability clause.
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The following material changes have been made to this Disclosure Brochure since the annual amendment filing on January 30th, 2025: • The Advisor no longer votes proxy on behalf of Clients. Please see item 17 for additional information. • The Advisor has added Independent Managers as part of its service offering, and has updated Items 4
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"There have been the following material changes to the firm brochure: The owners of ADG Wealth Management Group are no longer registered representatives of Osaic Wealth, Inc. As such advisory services and brokerage services previously offered through NFS are no longer available."
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Since our last annual updating amendment dated February 26, 2025, Item 12 has been updated to disclosure our brokerage practices to clarify that client trades may be executed on an aggregated ("block") or non-aggregated basis, depending on client-specific, tax, or operational considerations.
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The last annual update of this brochure was on February 12, 2025. Material changes that have occurred since that update are as follows: (1) We have entered into and are currently a party to a promoter's agreement whereby we receive payment for referring clients to another business or related party. See Item 14. (2) We have entered into an agreement with GeoWealth Management LLC, where GeoWealth will be acting in a sub-advisory capacity solely for trade execution purposes. See Items 4, 5, and 12.
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Since the last filing of this brochure on December 5, 2024, the following material changes have occurred: Item 4 assets under management calculation updated. Item 8 updated to disclose direct indexing. We have changed our custodian to Charles Schwab & Co., Inc.
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Since the last filing on February 26, 2025, the following material changes have occurred: Item 4 has been updated to disclose the most recent calculation for assets under management calculation; Item 5 has been updated to disclose current fees for financial planning; Item 8 has been updated to add disclosures for direct indexing.
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Since the last filing on February 26, 2025, the following material changes have occurred: Item 4 has been updated to disclose the most recent calculation for assets under management calculation. Item 5 has been updated to disclose current fees for financial planning. Item 8 has been updated to add disclosures for direct indexing.
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The following material changes have been made to this Disclosure Brochure since the initial filing on February 25th, 2025: The Advisor now utilizes sub-advisors to manage a portion of Client portfolios.
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Main Disclosure Brochure: "The following material changes have been made to this Disclosure Brochure since the annual amendment filing on February 28, 2025.: • The Advisor has updated Item 14 to reflect that it no longer engages in promoter relationships." Wrap Fee Program Brochure: "The following material changes have been made to this disclosure brochure since the last filing and distribution to Clients: • The Advisor has updated Item 9 to reflect that it no longer engages in promoter relationships."
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We amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Direct Indexing, Securities Backed Lines of Credit (SBLOCs), and Artificial Intelligence ("AI") Risk.
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The material changes in this brochure from the last annual updating amendment of BCO Wealth Management LLC on 02/24/2025 are described below. Material changes relate to BCO Wealth Management LLC's policies, practices or conflicts of interests: (1) BCO Wealth removed references to Assetmark services (Items 5, 12, and 14); (2) Certain supervised persons receive discretionary bonuses that may be based, in part, on new client relationships or assets they bring to BCO Wealth and client retention. This arrangement creates a conflict of interest, which BCO Wealth seeks to mitigate (Item 14); (3) BCO Wealth has authority to transfer money from client account(s), which constitutes a standing letter of authorization. Accordingly, BCO Wealth will follow the safeguards specified by the SEC rather than undergo an annual custody audit (Item 15).
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The material changes in his brochure from the last annual updating amendment of Eltekon Advisors, LLC on February 13, 2025, are described below. Eltekon Advisors, LLC has removed the following service offerings: discontinued its third-party advertising agreement with SoraFinance, Inc.; no longer utilizes Anchorage Digital Bank National Association as a qualified custodian for clients' cryptocurrency and digital asset holdings; now a marketer for SkyView1 bank accounts; has added Charles Schwab & Co. as its primary custodian due to its acquisition of TD Ameritrade; has updated custody over the funds and securities of trust accounts; has retired its wrap fee program; has updated its Fee Schedule; has updated its Assets Under Management.
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Since our last annual amendment filing filed on March 6th, 2025, we have the following material changes to report: (1) Our firm has changed our DBA name to Solano Wealth Advisors. (2) Our firm now maintains Standing Letters of Authorization granting third-party money movement authority. (3) Our firm has amended Item 8 of this brochure to expand on the different types of securities we may recommend in client accounts.
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Since our last annual amendment filing filed on March 6th, 2025, we have the following material changes to report: (1) Our firm has changed our DBA name to Solano Wealth Advisors. (2) Our firm has amended Item 6 of this brochure to expand on the different types of securities we may recommend in client accounts.
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Item 2. Material Changes\nThis section discusses only the material changes that have occurred since TFS's last annual update dated March 19, 2025\n\n• TFS has disclosed its insurance activities. (Item 5 and 10)\n• TFS has disclosed Capital Group/American Funds as the custodian for 401K assets. (Item 12)
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Since our last annual amendment filing on February 26, 2025, we have the following material changes to report: Our firm's maximum advisory fee for Wrap Comprehensive Portfolio Management services has been increased to 2.25%. In certain instances, our Firm will recommend the sub-advisory services of Third Party Money Managers.
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Since our last annual amendment filing on February 26, 2025, we have the following material changes to report: (1) Our Firm's maximum advisory fee for Wrap Comprehensive Portfolio Management services has been increased to 2.25%. (2) In certain instances, our Firm will recommend the sub-advisory services of Third Party Money Managers.
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Since our last annual updating amendment dated March 13, 2025, we have the following material change to report: In July, we included the risks of alternative investments in Item 8 Methods of Analysis, Investment Strategies and Risk of Loss. Paradigm also disclosed the use of artificial intelligence (AI) with certain third-party technologies aimed at driving operational efficiency by automating meeting preparation, taking and recapping meeting notes, creating tasks and other client service-related function.
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Since our last annual updating amendment dated March 13, 2025, we have the following material change to report: In July, we included the risks of alternative investments in Item 8 Methods of Analysis, Investment Strategies and Risk of Loss. Paradigm can recommend to clients, who meet the suitability requirements outline in the product's offering memorandum, investment in alternative investments. These investments generally have no secondary market and are considered illiquid and long-term. These products are considered risky, and the client is urged to review the subscription documents for specific risks applicable to the alternative investments recommended by Paradigm. Paradigm also disclosed the use of artificial intelligence (AI) with certain third-party technologies aimed at driving operational efficiency by automating meeting preparation, taking and recapping meeting notes, creating tasks and other client service-related function.
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On February 10, 2026, we filed our annual updating amendment for fiscal year end 2025. We have updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management of approximately $370,905,975, and non-discretionary assets under management of approximately $25,800,717. We also amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Direct Indexing, Political Risk and Artificial Intelligence ("AI") Risk.
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Since its last update to this Brochure filed on July 31st, 2025, Cache Advisors LLC (Cache) has made the following changes. The changes on Form ADV Part 2 include the following update: Cache has updated Item 4 to reflect that addition of a discretionary investment advisory services through separately managed accounts via the Cache Advisors Long Short Program ("Long Short Program") offered mainly to high-net worth individuals and trusts.
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"Since our last ADV amendment on October 8, 2025, Heritage Oak Wealth Advisors has made material changes to the brochure. Item 4: Advisory Business. Item 10: Other Financial Activities and Affiliations."
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"Item 2: Material Changes. These are the following material changes in this brochure from the last annual amendment filing of Signify Wealth LLC on March 19, 2025. Material changes relate to Signify Wealth LLC's policies, practices or conflicts of interests. Items 4, 5, 6, and 8: Updated to describe features, fees, and risks of new business line — Special Purpose Vehicles."
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Since the posting of our most recent required annual amendment to this Disclosure Brochure Form ADV Part 2A in January 2025 the following material changes have been made: The firm has updated its outside business activities. The firm is no longer the General Partner of 5T Wealth Partners, LP. The firm no longer refers clients to third party money managers. The firm no longer recommends Charles Schwab as a custodian.
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This Brochure is West Horizon's update to its 120-day registration with the SEC as well as its Annual Amendment. West Horizon has begun to manage regulatory assets and those assets have been added to the brochure.
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Private Wealth Group, LLC has made the following changes to its ADV Part 2A Disclosure Brochure since its last annual update on February 26, 2025: (1) As Firm no longer recommends subadvisors, references to this service have been removed throughout this ADV Part 2A. (2) Item 5(A) – Firm has updated its disclosures regarding conflicts of interest. In addition, Firm has revised this ADV Part 2A to disclose its practice of consolidating Management Fee components into a single fee for clarity and administrative simplicity for newer clients. This change does not impact existing clients' Management Fee arrangements, which are set forth in their respective investment advisory agreements. (3) The principal owners of the Firm are Michael M. Anderson and the Estate of Stephen F. Segundo.
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The firm's most recent Annual Updating Amendment is dated March 25, 2025. Since that date, the following material changes have occurred: 1) The firm added Financial Planning and Consulting for Businesses as a new service. "Item 4 – Advisory Business" and "Item 5 – Fees and Compensation" were updated to discuss the new service. 2) "Item 10 – Other Financial Industry Activities and Affiliations" has been updated to reflect that Stableford Tax LLC is no longer an active affiliate of Stableford Capital, and that certain Supervised Persons have changed the broker dealer with whom registration is maintained.
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The following material changes have been made to this Disclosure Brochure since the annual amendment filing on January 29, 2025: (1) The Advisor has added insurance consulting services as a component of its Aspen Private Wealth Services. (2) The Advisor has updated its fees for standalone financial planning.
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"As required, the Firm must discuss material changes since the last annual update. The following material changes have been made to this Brochure: Advisory Business (Item 4): Updated to more accurately describe the Adviser's services as discretionary investment advisory services provided through Separately Managed Accounts (SMAs). Fees and Compensation (Item 6): Updated to clarify that the Adviser does not charge performance-based fees. Investment Strategies and Risks (Item 8): Updated to align with the Adviser's 'long-only' approach, removing references to short selling, leverage, and derivatives as standard practices. Cybersecurity (Item 8): Added specific disclosures regarding cybersecurity risks and the Adviser's policies for protecting customer information under the amended Regulation S-P. Brokerage Practices (Item 12): Updated to clarify that the Adviser does not participate in soft dollar arrangements, wrap fee programs, or receive soft dollar benefits. Voting Client Securities (Item 17): Updated to clarify that the Adviser does not vote proxies on behalf of Clients. Clients retain the responsibility for receiving and voting proxies for securities held in their accounts."
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Our Foundational Consulting Service has transitioned from a 3-year program with a fixed monthly fee (increasing in years 2 and 3) to a service with no set time period. The new service has a fixed consulting fee of $2,400 the first year, transitioning to an hourly fee, until client reaches $400,000 in assets under management at any quarter-end.
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There have been material changes to the Brochure since the last dated filing of February 12, 2025. Specific changes include: Item 1 (Cover Page – change of address), Item 4 (Advisory Business), Item 5 (Fees and Compensation), Item 9 (Disciplinary Information), Item 12 (Brokerage Practices).
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Material Changes since the Last Update: Changed Custody information; Added to include officers and staff of Security First Financial; Changes to policy on ESRPs; Added succession plan information
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"Since that date, the following material changes have occurred: 1) An affiliated company, Holland Trustees, Inc., was created through which David Holland, CPA, conducts outside business activities involving estate planning, trust administration and trustee services. Holland Trustees, Inc. was incorporated on March 21, 2025. 2) Holland Business Management, Inc. was incorporated January 1, 2026, in order to provide compliance, technology, marketing, and human resources services to its affiliated companies. 3) Inclusion of exchange traded products that hold Digital Assets into our asset allocation models."
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Since the last update, the following material changes have occurred: (1) Keith Browning replaced Steve Larsen as President of CAP; (2) CAP has begun offering two additional affiliated private funds to CAP Clients – the Sound Income Cap Fund and the Hartley Income Fund; (3) CAP has begun permitting certain of its investment adviser representatives to also serve as registered representatives of CAP's affiliated broker-dealer, Columbia Private Markets, LLC.
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We have updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management of approximately $286,876,797, and non-discretionary assets under management of approximately $0. In addition, we amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Political Risk and Artificial Intelligence ("AI") Risk.
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Effective 1/1/2026, David Hornberger and Christopher Wilde each will own 50% of the firm, buying out Stephen Wilde. David Hornberger's ownership is held indirectly via sole ownership of 1810 Ventures LLC. This assignment of ownership has been timely communicated to clients and the ADV will be updated during the annual amendment to reflect this ownership change. Stephen Wilde will remain at Glass Wealth Management as an employee in a portfolio management/advisory role. There are no other changes. This impacts Item 4: Advisory Business. Effective 1/1/2026, We no longer have proxy voting rights on behalf of our clients. We instruct our custodians to deliver all proxy voting materials directly to the client. Clients who wish to discuss their proxy votes with us may contact us. This impacts Item 17: Voting Client Securities.
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"The following material changes have occurred since the last annual filing on February 28, 2025: • Item 4 – Advisory Business – Describes the use of wealth.com (no involvement, added service to our overall relationship, no billing) • Item 4 – Advisory Business - Describes the addition of donor-advised funds and private funds as part of the investment advisory services offered by the firm • Item 5 – Fees and Compensation – Included fees associated with the offering of donor-advised funds and private funds"
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There have been material changes since the March 19, 2024, Form ADV filed on the IARD system as follows: Trademark has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). (Item 15) We believe that this transition to Charles Schwab & Co., Inc. will benefit our clients by providing enhanced technology and improved operational support. As a result of the transition, we have updated Items 5, 12, and 14 of these brochures.
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Since the last filing of our Form ADV Part 2 in the IARD system, Des Moines Investments has had the following material change: David Harkin became a licensed Iowa insurance agent in January 2025.
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The following material changes have been made to the Form ADV Part 2A since the initial filing of the form: On February 20, 2026, the following sections were amended to remove disclosures related to Estate Planning services and conflicts of interest that exists between Sanchez Gaunt Capital Management and Estate Planning Advisors Of America, LLC (EPAOA). EPAOA has been dissolved and estate planning services are no longer provided by SGGM through this related entity. Additionally, the following item was amended to disclose an additional outside business activity, Specialized Trusts & Estate Plans, LLC., related to Jon Sanchez.
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Since the filing of our last annual updating amendment, dated February 27, 2025, we have the following material changes to report: The firm has added Charles Schwab & Co., Inc. as a recommended custodian.
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Since the last filing the following material changes have occurred: PIP now engages in proxy voting. Please see Item 17 for additional information.
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Since the filing of our Annual Amendment dated February 26, 2025, we have the following material changes to report: Portfolio Management - We consider financial planning an integral aspect of the portfolio management process designed to assist our clients in reaching their financial and retirement goals and will provide clients with access to a cloud-based software.
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Since the last annual amendment of its Brochure was filed on March 14, 2025, Invera Wealth Advisors has been the following changes to its Brochure: July 1, 2025 Item 4 has been updated to reflect the current appointment of Invera Wealth's Chief Compliance Officer and the controlling members of the firm. October 9, 2025 The descriptions of Invera Wealth's advisory services have been updated in Items 4 and 5. February 23, 2026 The amount of RAUM has been updated in Item 4.
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"We now utilize separately managed accounts in certain instances to assist in managing certain client accounts. Please see Items 4 and 5 of this brochure for more information."
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"There are material changes in this brochure from the last updating amendment of Innova Wealth Partners, LLC on January 23, 2025. Material changes relate to Innova Wealth Partners, LLC's policies, practices or conflicts of interests." The specific changes include: Item 4 amended to reflect Pontera services removed and Financial Planning/Consultancy services added; Items 4 and 5 amended to disclose sub-advisory relationships and fees; Item 5 updated with Educational Courses/Seminars fees; Item 8 updated to disclose additional investment risks; Item 10 amended for sub-advisor engagement disclosure.
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Material changes have been made to this Form ADV Part 2A since the filing dated January 31, 2025 are: Item 4 (Advisory Business): Comprehensive Financial Planning Services renamed to Journey Financial Planning Services; Navigator Financial Planning Services added; Business Planning removed; Cash Flow and Debt Management renamed to Cash Flow Planning. Item 5 (Fees and Compensation): Comprehensive Financial Planning Services renamed to Journey Financial Planning Services; Navigator Financial Planning Services added.
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Since the last filing on February 6, 2025, the following material changes have occurred: Item 4 to update the assets under management for the firm. We are no longer offering Outsourced Chief Investment Officer Services.
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Since our last annual filing we have made the following material changes: Item 4 (Advisory Business) – Changes were made to reflect our ownership change. The principal owners of our firm are Jeffrey Gordon and Barclay Douglas. Item 5 (Fees and Compensation) – Updated language to further clarify how the Firm charges for its portfolio management services and the process for billing on assets withdrawn during the quarter. Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss) – Added additional risk to describe risk associated with the type of investments utilized, including risk associated with investing in equities, ETFs, mutual funds, fixed income, and real estate. Item 15 (Custody) - Updated the custody section to reflect that SGCo is deemed to have custody as a result of employees acting as trustee on client accounts. SGCo is subject to the surprise examination requirement. Additional changes were made throughout for language consistency and clarification.
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Since our last annual updating amendment, dated March 26, 2025, we have the following material changes to report: (1) Private fund lineup: Broyhill Partners, LP was liquidated on June 18, 2025; Broyhill Vitruvian Value, LP was launched on July 1, 2025; (2) Updates to disclosure items including Item 5 (indemnification summary), Item 6 (performance allocations for new fund), Item 7 (Section 3(c)(1) exemption), Item 12 (trade errors, timing/allocation, directed brokerage), Item 13 (review roles), Item 17 (proxy voting provider changed from ProxyEdge to Egan-Jones).
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Since the firm's last Form ADV updating amendment filing in July 2025, the following material change has occurred. Item 14 (Client Referrals and Other Compensation): The Firm added disclosure regarding a program under which it may pay the cost of certain clients' tax-preparation services for qualifying clients, including related conflicts of interest and limitations of the program.
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Since our last annual amendment filing on February 4, 2025, the following changes have been made: (1) Our firm now utilizes the services of Third-Party Money Managers in client accounts; (2) Victoria Hooker has been appointed Chief Compliance Officer of Pacific Capital Associates, Inc.; (3) Our firm has amended Item 14 of this brochure to disclose that our firm provides cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements.
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"Convoy's asset under management is changed from $218 million as of 12/31/2024 to approximately $261 million as of 12/31/2025. Convoy is currently retaining a subject matter expert consultant, currently Dr. Leonidas Tam, to support our AI strategy."
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The following are the material changes since Registrant's last annual update dated March 13, 2025: (1) Registrant revised Item 4, as well as corresponding sections of Items 5 and 10, to reflect that it no longer recommends third-party managers to manage client assets; (2) Registrant revised Item 13 to reflect that periodic reviews are conducted by the Registrant's IARs rather than its Principal; (3) Registrant revised Item 14 to indicate that its supervised persons who are also licensed insurance agents receive a bonus based on insurance product sales; (4) Registrant revised Item 14 to explain details of its new "Promoter" relationship.
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The material changes in this brochure from the last annual updating amendment of Carolina Financial Advisors, Inc. on 03/05/2025, are described below. Material changes relate to Carolina Financial Advisors, Inc.'s policies, practices or conflicts of interest. • Carolina Financial Advisors, Inc. has updated its Biblically Responsible Portfolios to Values Based Investing. (Items 4 and 5) • Carolina Financial Advisors, Inc. has updated its Brokerage Practices (Item 12) • Carolina Financial Advisors, Inc. no longer uses Pontera (Item 4 and 5) • Carolina Financial Advisors, Inc. has updated its assets under management. (Item 4) • Carolina Financial Advisors, Inc. has updated its Other Financial Industry Activities and Affiliations. (Item 10)
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The material changes in this brochure from the last annual updating amendment of Carolina Financial Advisors, Inc. on 03/05/2025, are described below. Material changes relate to Carolina Financial Advisors, Inc.'s policies, practices or conflicts of interest. • Carolina Financial Advisors, Inc. has updated its Biblically Responsible Portfolios to Values Based Investing. (Items 4 and 5) • Carolina Financial Advisors, Inc. has updated its Brokerage Practices (Item 12) • Carolina Financial Advisors, Inc. no longer uses Pontera (Item 4 and 5) • Carolina Financial Advisors, Inc. has updated its assets under management. (Item 4)
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Since the last update on October 16, 2025 the following material changes have been made: We have added information regarding a new advisory program, in Item 4.
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"We have the following material changes to report since the last annual filing of this Firm Brochure on 02/05/2025: Item 1: We have moved from the Independent Contractor Division to the RIA and Custody Services Division of Raymond James Financial Services. As a result, we have updated the information on the Raymond James Ambassador Program, as well as our email addresses. Item 4 and 5: We have added ERISA Retirement Plan Services to our service offerings. Item 5: Our hourly fee has been updated to $500. Item 15: We have disclosed that for certain accounts, the Firm has authority to transfer client funds to third parties pursuant to standing letters of authorization."
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The material changes in this brochure from the last annual updating amendment of ADC Wealth Management, LLC on 01/22/2025 are described below. Material changes relate to ADC Wealth Management, LLC's policies, practices or conflicts of interests. ADC Wealth Management, LLC has updated its assets under management. (Item 4.E). ADC Wealth Management LLC no longer receives soft dollar benefits. (Item 12.A).
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The following lists material changes since the Firm's previous Annual Amendment filing, dated February 13, 2025: Our firm now utilizes the services of DPL Financial Partners, LLC, for variable annuity insurance products. Please refer to Item 9 of this brochure for more information.
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Our firm now utilizes the services of DPL Financial Partners, LLC, for variable annuity insurance products. Please refer to Items 4, 5, 10, and 14 of this brochure for more information.
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We have made the following updates since our last annual updating amendment, dated March 6, 2025: Item 12 and Item 14 have been updated to remove any references to the use of Fidelity as a custodian; Item 15 has been updated to reflect that the Adviser has custody due to Standing Letters of Authorization (SLOA's).
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Global Trust Wealth Management, LLC has the following material changes to report. Material changes relate to Global Trust Wealth Management, LLC's policies, practices or conflicts of interests. • Updated Item 4 and 5 to reflect use of the Pontera platform to manage held away assets. • Updated Item 10 to include disclosure of IAR insurance license with unaffiliated firm. • Updated Item 12 to update soft dollar policy.
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Our current Brochure contains the following changes: Since our last annual updating amendment, we have updated this brochure to (i) revise the description of our ownership structure in Item 4, (ii) remove references to employee benefit retirement-plan services and qualified retirement-plan clients in Items 5, 7 and 13, and (iii) make related conforming changes to reflect that we no longer provide those services.
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Since the last annual amendment filing of this brochure on February 18, 2025, the following changes have been made: Item 4, 5 and 10 have been updated to reflect that the Firm is utilizing a turnkey asset management program to provide operational and trading support, and the potential conflicts associated with this service. Item 5 has been updated to reflect the new fee levels for Asset Management. Item 7 has been updated to add an account minimum for new relationships.
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The following material changes have been made since our last Annual ADV Amendment filing made on January 24, 2025: (1) Item 4 has been updated to include arrangement with Wealth.com for estate planning services, (2) Item 5 has been updated to include fees for estate planning services, (3) Item 8 has been updated to include risks associated with structured products.
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On February 10, 2026, we submitted our annual updating amendment filing for fiscal year 2025. In addition, we amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Political Risk.
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The date of the last annual update was February 26, 2025. Item 5 was amended to update the firm's hourly billable rates and the general range of annual fees for Planning by the Year services. Item 12 was amended to note the Firm longer recommends Vanguard.
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The following material changes have been made to this Disclosure Brochure since the last filing and distribution to Clients on October 2, 2025: The Advisor has added insurance consulting services as a component of its comprehensive wealth management services.
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The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on March 12, 2025: • Effective September 1, 2025, Melanne Acker is the Advisor's Chief Compliance Officer. • The Advisor has amended Item 5.A to update the range of financial planning services.
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The following are changes that were made since the last Annual Amendment filing made on February 6, 2025: Effective August 1, 2025, our Firm's new address is 5755 Mark Dabling Blvd Ste 220 Colorado Springs, CO 80919. Item 4 has been updated to remove reference to the Firm's recommendation of Betterment Institutional Platform. Item 10 has been updated to reflect Brian Colvert's minority interest in SETA CPA, LLC. Item 14 has been updated to reflect the receipt of compensation for any supervised person of Bonfire Financial that refers clients to SETA CPA, LLC.
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Since Westview Investment Advisors' most recent Annual Amendment filing on March 4, 2025, this Disclosure Brochure has been amended as follows: • At Item 4 to update the firm's ownership details • At Item 8 to discuss the use of interval funds and related risks and limitations • At Item 15 to describe third-party standing letters of authorization and related custody implications
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Since the last amendment filed on March 3, 2025, material changes have been made to the brochure. • Item 4: Services, Fees, and Compensation - correction • Item 9: Additional Information
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"There are material changes in this brochure from the last annual updating amendment on May 12, 2025, of Sand Creek Capital, LLC dba Cordingley & Parkinson Wealth Management... The following changes were noted: • C&PWM does not have any solicitors; • C&PWM offers discretionary and non-discretionary advice; our AUM was broken down to reflect the differences; • C&PWM no longer receives Transition Assistance payments from LPL Financial; • The ownership structure was updated to reflect current ownership. Robert Parkinson and Tracey Parkinson each own 50% of C&PWM; and • C&PWM has added Charles Schwab & Co., Inc. as a custodian."
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The firm has updated its Proxy Voting language. (Item 17)
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Since our last amendment, GSI Capital has made the following changes: 1) Item 4 was amended to reflect our assets under management as of December 31, 2025. 2) We closed and liquidated GSREF, LP, the sole private fund that we advised, in October of 2025.
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Material Changes: We have rewritten some of the sections for more clarity. We encourage you to review this Brochure in its entirety. We have added details related to investments in unaffiliated third-party private fund offerings or other pooled investment vehicles. Please see Items 4, 5, and 6. We have implemented a new minimum fee for new clients with under $200,000 in assets. Please see Item 5 and Item 7 for more details.
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Since the last update on September 4, 2025, there have been the following changes: We have added Parametric Portfolio Associates as a third-party money manager.
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Since the last update on September 4, 2025, there have been the following changes: Item 4 has been updated to disclose the most recent calculation for client assets under management; Item 5 updated to include a new portfolio fee schedule for Gradient Investments & remove information about alternative investments; Item 5 amended to remove the co-advisor relationship with Flexible Plan Investments since the firm is no longer working with them; Brochure amended to remove assets held away services.
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"CovingtonAlsina, LLC has the following material changes to report since its last annual updating amendment on 03/11/2025. Material changes relate to CovingtonAlsina, LLC's policies, practices or conflicts of interests. • The firm has updated the Primary office address phone number (Cover Page) • The firm has reorganized the company to Florida. • The firm has updated its financial planning services to include two new service packages that are available to clients who have engaged the firm for portfolio management services – the Core and Choice Program Service packages. The fixed rate for Core Program Services is up to $1,250 annually. The fixed rate for Choice Program Services is up to $5,250 annually. (Items 4 & 5) • CovingtonAlsina offers tax preparation and related tax services. These services are offered through an in-house CPA and are provided at the client's election and are not required as a condition of receiving investment advisory services. (Items 4 & 10)"
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The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on January 31, 2025: (1) Inman Jager Wealth does not offer fixed fee arrangements. (2) The Advisor has added the following facsimile number: (601) 602-3867.
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Since our last filing on February 20, 2025, we have increased our hourly rate to $350. Donald Monsen and Martin Konsor each own 5% of the company stock according to a new succession plan put in place that provides for continuation of the firm in the event of the death or disability of the company's founder James Dobbs. Woodfield Financial Advisors, Inc. formed a new DBA Woodfield Inheritance Advisors focused on serving people that have inherited $1,000,000 or more.
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Item 9. The Firm has added Charles Schwab as an additional qualified custodian for client assets. Item 17. The Firm updated its proxy voting practices to reflect changes in proxy voting authority, including reliance on Independent Managers to exercise proxy voting authority for assets they manage.
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"Since the filing of our last annual updating amendment, dated February 4, 2025, the following material changes to report: • Victoria F. Jones is now serving as Chief Compliance Officer of the firm. • We may use a third-party platform, Pontera, to facilitate management of held away assets such as 401k accounts, with discretion."
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The material changes to report since the most recent update filing dated March 10, 2025 are as follows: 1. Removed language for the termination of the sub-advisory relationship, Foundations Investment Advisory. 2. Named a new president, CEO and chief compliance officer, Christopher B. Radford. 3. Provides an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies. 4. Item 8 has been amended to reflect the use of Signal Call Providers.
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On February 17, 2026, we submitted our annual updating amendment filing for fiscal year 2025. We have updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management of approximately $219,485,362, and non-discretionary assets under management of approximately $694,638. In addition, we amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Political Risk and Artificial Intelligence ("AI") Risk.
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Material change: -We are updating Item 4, Page 4 - Advisory Business
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Since the filing of our last annual updating amendment dated March 5, 2025, Thompson Capital Management has the following material changes: Item 4: Advisory Business. We added a section describing how we may also service employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary as part of our portfolio management services.
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Since the last filing of this brochure on April 10, 2025, we have amended the following: Item 4 has been amended to reflect an updated asset under management calculation. Items 4 and 5 have been updated to clarify services offered and the corresponding fees. Item 15 has been updated to disclose third party standing letters of authorization. The entire brochure has been updated for compliance reasons.
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The only material change in this Brochure since the last annual update is that CenterNode Group, LLC ("CenterNode") has been added as a relying adviser under FRAM's SEC registration and this Brochure has been updated to reflect FRAM's advisory business on an umbrella basis.
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The material changes in this brochure from the last annual updating amendment of Signet Private Wealth LLC (Formerly known as Twende Asset Management LLC) on March 12, 2025, are described below. Material changes relate to Signet Private Wealth LLC's policies, practices, or conflicts of interest. • Signet added in information regarding Financial Consulting. • Signet offers newsletters as a service. (Item 4) • Signet added additional touch points for financial planning services. • Signet has updated Other Financial Industry Activities and Affiliations. (Item 10)
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Since our last annual updating amendment on January 14, 2025, we have the following material changes to report: Item 4, 5 and 8: We revised our investment advisory services to disclose that we are no longer recommending alternative investments. Item 5: The breakpoint on our fee schedule has been lowered and we updated the minimum account size required for our fees to be negotiable.
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Since our last annual update on March 1st, 2025, we have made the following changes: Item 4 and Item 7: Added disclosure regarding limited consulting services provided to certain employer-sponsored retirement plans. Item 4 and Item 8: Updated disclosures regarding investment strategies to reflect that portfolio recommendations may include alternative investments for certain clients where appropriate. Item 10: Other Financial Industry Activities and Affiliations: Removed a disclosure stating that Ravi Davis was a partner in Hippocratic Tax and Accounting, LLC. Ravi Davis does not maintain that affiliation, and the related paragraph has been deleted. Item 15: Custody: Updated to reflect that the Firm will engage the services of an independent certified public accounting (CPA) firm to conduct annual surprise examinations of the accounts over which the Firm is deemed to have custody.
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In April 2025, Payne Capital LLC first filed for registration as an investment advisor. Since then, several material changes have occurred, requiring an update to this disclosure document. Changes include: (1) Swiftwater Capital is an assumed business name for Payne Capital LLC registered with Oregon; (2) Fred Payne is no longer affiliated with Northwest Capital Management, Inc. nor Carson Wealth; (3) Swiftwater Capital is now registered with the SEC as of December 2025 after AUM exceeded $110M; (4) Mailing address changed to PO Box 959, Lake Oswego, OR 97034; (5) Services expanded to include attorney/CPA advisory services, estate planning audit support, internet-based estate planning resources, tax return analysis, and ERISA consulting for qualified retirement plans.
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Since the date of our last filing of our initial registration request, dated January 8, 2025, we have made the following material changes to our brochure: Item 10 has been updated to reflect that OxenFree Accounting & Tax Service is now under common ownership with OxenFree Capital LLC dba OxenFree Financial through James Phillips, and to update related affiliated business disclosures. Item 4 has been updated to reflect the correct address of our headquarters office. Item 12 has been updated to disclose the addition of Altruist as a custodian utilized by our firm. Items 4 and 5 have been updated to describe services and related fees for facilitating estate planning services. Items 4, 5, 10, and 14 have been updated to include disclosures regarding facilitation of advanced tax strategy services provided through third-party partners, including related compensation, relationships, and conflicts of interest.
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Since the last filing of this brochure on January 29, 2025, the Firm has the following material changes to report: Item 4 has been updated to disclose that we are now utilizing a third-party alternative investment platform (CAIS) to expand our investment offerings. Item 8 has been updated to disclose the risks associated with alternative investments.
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"Corrales & Company LLC has the following material changes to report. Material changes relate to Corrales & Company LLC’s policies, practices or conflicts of interest. • The firm has updated its primary office address and phone number. (Cover Page) • The firm has updated its Assets under Management. (Item 4.E) • The firm has updated its Financial Industry Affiliations (Item 10.C) • The firm has added Subscription Services to its services. (Item 4.B) • The firm has added Educational Seminars/Workshops to its services. (Item 4.B)"
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NinePointTwo Capital LLC has made the following material updates to the Form ADV Part 2A since the last annual update on February 10, 2025: (1) Item 4 and Item 8 - added tax-aware long/short equity strategy for separately managed accounts; (2) Item 5 and Item 6 - updated fee structure for NPT Neutron Fund I, LP; (3) Item 14 - new marketing arrangement with unaffiliated third-party marketer for NPT Neutron Fund I, LP.
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"The material changes in this brochure from the last annual updating amendment of Specialized Retirement Consultants LLC on 03/10/2025 are described below. Material changes relate to Specialized Retirement Consultants LLC's policies, practices or conflicts of interests." - Specialized Retirement Consultants LLC has updated its Asset-Based Fees for Pension Consulting (Item 5). - Specialized Retirement Consultants LLC has removed Selection of Other Advisors (Items 4 and 5).
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This Brochure dated February 23, 2026, includes the following material changes since our last annual updating amendment dated January 31, 2025: In Item 12, we updated references to recommended custodians. SouthCol currently recommends that clients open and maintain accounts with Schwab & Co., Inc., only.
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The material changes in this brochure from the last annual updating amendment of Kastel Capital Advisors, LLC on February 14, 2025 are described below. February 20, 2025 update: Deleted Insurance Consultancy. November 4, 2025 update: The Advisor now offers Estate Planning Services. Please see Items 4 and 5 for more information. February 25, 2026 update: The Advisor now offers Tax Planning Serivces. Please see Item 10 for more information. The Advisor has updated its Fee Schedule. Please see Item 5A for more informaiton.
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Since the filing of our last annual updating amendment, dated February 27, 2025 we have the following material changes to report: (1) Financial plans and/or planning services are included in the Ambassador Program; (2) The agreement can be terminated upon either parties notice to the other with pro rata charging and refunding of pre-paid fees; (3) Our fees are negotiable and in most cases range between .70% to 1.75%
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Since the firm's last annual updating amendment filed on March 17, 2025, we have the following material changes to report: Effective Date March 31, 2025 - Item 5: We have updated our fees; Throughout: We have removed sub-advisory services through the use of 55ip; Item 12: We have added Fidelity Brokerage Services LLC as a custodian
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Since then, SilverPeak Wealth Advisors, LLC submitted its annual updating amendment on February 25, 2026, for the firm's fiscal year ending December 31, 2025, with the following material changes: (1) We updated Item 4 of our Brochure to reflect that, as of December 31, 2025, we managed approximately $177,373,121 in client assets on a discretionary basis. We do not manage assets on a non-discretionary basis. (2) We also updated Item 8 of our Brochure regarding direct indexing, securities backed lines of credit, and political risks.
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Since the last amendment filing on July 21, 2025, there have been material changes made: Item 4: Advisory Business – We no longer use Pontera for Held Away Accounts; Item 5: Fees and Compensation – We have removed fee information related to Pontera; Item 12: Brokerage Practices – We have removed Altruist as a custodian; Item 15: Custody – We have removed Altruist as a custodian; Item 16: Investment Discretion – We no longer have access to Held Away Accounts through Pontera
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The following material change has been made to this Disclosure Brochure since the annual amendment filing on February 21, 2025: The Advisor has added Estate Planning services through Encore Estate. Please see Items 4, 5, and 10 for additional details.
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"The material changes in this brochure from the last annual updating amendment on 03/03/2025 of Durante & Waters are described below. Material changes relate to Durante & Waters' policies, practices or conflicts of interests." • Updated assets under management (Item 4). • Updated how it handles the termination date of fees for management during partial quarters of service (Item 5). • Removed all references of the utilization of independent managers as this practice is not a part of our business.
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February 13, 2026: Changed to Version 2026.02; Updated Copyright notice; Item 10.4: Updated information on IAG Management Persons' affiliations; Corrected various grammatical errors. March 20, 2025: Changed to Version 2025.3; Updated Copyright notice; Item 4.2: Added clarity to Management Persons' licensing; Item 4.3: Removed all references to non-discretionary management; Added clarity to OPA accounts; Item 5.1: Added clarity to fee refund process; Removed reference to Pacific Premier Trust; Item 5.2: Added information on new conflict of interest with IAG Management Persons due to new ownership interests; Item 5.3: Added information on new conflicts of interest with IAG staff due to new affiliations; Item 8.4: Added Cybersecurity Risk; Item 10: Added information on IAG Management Persons' new affiliations.
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"Since that date, we have made the following material changes to this Brochure: Item 15 was amended to disclose that SMB has the ability to disburse or transfer certain funds pursuant to ongoing Standing Letters of Authorization executed by clients."
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"The material changes in this brochure from the last annual updating amendment to this Wrap Fee Program Brochure of Hoffman Capital Advisors LLC on 03/22/2025 are described below. Material changes relate to Hoffman Capital Advisors LLC's policies, practices or conflicts of interest. • The firm has updated its primary address & phone number. (Cover page) • The firm has updated its outside business activities. (Item 9.A)"
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The material changes in this brochure from the last annual updating amendment of Hoffman Advisors LLC on 03/22/2025 are described below. Material changes relate to Hoffman Advisors LLC policies, practices or conflicts of interest. • The firm has updated its primary address & phone number. (Cover page) • The firm has updated its outside business activities. (Item 10.C)
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The material changes in this brochure from the last annual updating amendment of Networth Advisors, LLC on 02-17-2026 are described below. Material changes relate to Networth Advisors, LLC's policies, practices or conflicts of interests. • Networth Advisors, LLC has updated their Asset Under Management (Item 4E). • With the increased popularity of digital assets, Item 8C adds the requirement for a client to acknowledge risks if they specifically request to be invested in an alternative investment, such as cryptocurrency or private offerings.
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"Robinhood Strategies has made the following material changes to its Form ADV Part 2A brochure since its registration became effective on January 14, 2025: On February 27, 2026: Item 4 — Advisory Business: Introduced the Robinhood Advisor Network business line; Item 7 — Types of Clients: Introduced custodial managed accounts for minor beneficiaries. On November 7, 2025: Item 4 — Advisory Business: Introduced generative-AI Digests feature and tax loss harvesting services; Item 5 — Fees and Compensation: Updated fees/compensation disclosures; Item 8 — Methods/Strategies/Risk of Loss: Expanded risk disclosures; Item 10 — Other Financial Industry Activities and Affiliations: Added Robinhood Ventures as an affiliated investment adviser. On May 9, 2025: Item 4 — Advisory Business: Expanded description of program operations and client account mechanics; Item 10 — Other Financial Industry Activities and Affiliations: Added TradePMR Inc. as an affiliated entity; Item 11 — Code of Ethics: Enhanced disclosures of internal controls; Item 14 — Client Referrals and Other Compensation: Enhanced disclosures regarding advertising and promotional campaigns and related conflicts of interest; Item 16 — Investment Discretion: Expanded disclosure on limitations on asset transfer limitations and investing timelines."
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In connection with this Annual Updating Amendment, the Firm enhanced its disclosures to Items 4 and 5. These enhancements more clearly describe ancillary accounts managed as an extension of existing Wealth Management Services ("WMS") relationships and the associated fee and billing arrangements. The Firm's Privacy Policy, previously provided as a standalone document, has been incorporated into this Disclosure Brochure following "Item 18 – Financial Information."
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Since last updating amendment filing dated July 22, 2025, we have made the following material changes. • Item 4: Advisory Business – Add Sub-Advisors • Item 5: Fees and Compensation – Add Sub-Advisors Fees
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Since our last annual update dated February 03, 2025, we have the following material changes to report: (1) The firm has added disclosures for Standing Letter of Authorization. Please see Item 15 for additional information. (2) The firm has added additional disclosures for custody due to being the trustee of a client account. Please see Item 15 for additional information.
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Our current Brochure includes the following material changes: (1) Added language to disclose the use of AQR as an Independent Manager in Item 4 and Item 5, (2) TDA was removed as a custodian from Item 12 and Item 14, (3) Ryan Mahoney has taken on the position of Chief Compliance Officer. In addition, we updated the Assets Under Management information of Item 4 in accordance with the filing of our Annual Updating Amendment on February 26, 2026.
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The following material changes have been made since our Disclosure Brochure filing: 1. We revised Items 4 and 5 to include details regarding our sub-advisory services. 2. We revised Items 4 and 5 to include information about our Yield Enhancement Strategy (Y.E.S.) which is primarily the use of structured notes, issued by third-party financial institutions. 3. We revised Item 8 to include risk information associated with structured notes. These risks include the risk of loss. 4. We revised Item 14 to update that we have entered into a SMA Structured Product Wholesale Agreement with Barnabas Capital, LLC.
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On February 27, 2026, we submitted our annual updating amendment filing for fiscal year 2025. We have updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management of $150,560,827, and non-discretionary assets under management of $0. We also disclosed that we provide various investment advisory services over an additional $154,107,708 in client assets. We also amended Items 4, 5, 10 and 14 of our Form ADV Part 2A Brochure to remove references to the sale of insurance and referrals to third party investment advisers as we no longer offer these services. In addition, we amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Artificial Intelligence (AI) Risk.
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Since our annual amendment filed in January 2025, we have made the following material changes to this brochure: Item 4 - Farris Capital Management adjustment to assets under management; Item 4 and Item 12 - The addition of Farris Capital Management's partnership with Betterment Securities
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The material changes in this brochure from the last annual updating amendment of Taylor Securities Services, Inc. on September 16, 2025 are described below. In this Wrap Fee Program Brochure, Taylor Securities Services, Inc. ("TSSI") has made material changes since the last filing on September 16, 2025 and reorganized its disclosures to more clearly describe the firm's wrap fee program services, portfolio manager selection and monitoring practices, and client contact with portfolio managers. The brochure has also been revised to enhance disclosure regarding conflicts of interest associated with the firm's affiliated insurance agency, Taylor Retirement Services, Inc. ("TRS"), including commission-based compensation and related non-cash benefits, and to clarify required disclosures concerning the firm's Code of Ethics, economic benefits received from custodial relationships, and financial information. TSSI has engaged Broadridge Financial Solutions as an independent third-party proxy voting service provider to assist with the administration, research, and execution of proxy votes for client accounts where TSSI has voting authority.
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Wisdom Wealth Strategies, LLC amended its Form ADV Part 2 brochure from the previous version dated January 30, 2025 as part of its annual updating amendment. Services to retirement plan sponsors has been removed from Items 4 and 5, and additional product-specific risks have been added in section 8.
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Since our last annual updating amendment dated February 13, 2025, we have the following material changes to report: Added Artificial Intelligence under Item 8 Methods of Analysis, Investment Strategies and Risk of Loss; Updated Item 15 to reflect SEI Investments Company as custodian.
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This Brochure contains material changes from the last firm brochure dated as of February 19, 2025 including, but not limited to: • LCRWM updated Item 8 to disclose derivatives. • LCRWM updated its fee schedule.
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"Beacon Capital Advisory Group has the following material changes to report. Material changes relate to Beacon Capital Advisory Group's policies, practices or conflicts of interest. • Removed Standing Letters of Authorization (SLOAs) from Custody. • Amended Item 4 to omit IPS form and replaced with Suitability form. • Updated Item 5 to include more details on refunds. • Added Educational Workshops/Seminars to services. • Added alternative investment language to Items 4, 5, 8, 10 and 11. • Updated Item 12 to include Allianz and John Hancock/Goldman Sachs as recommended custodians."
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Since our last ADV Annual Amendment was filed in January 2025 the following material changes have been made to this disclosure brochure: (1) In July 2025 the firm amended the description of our advisory services. (2) In September 2025 the firm added a discretionary trading option to our Asset management Services.
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Since our last ADV Annual Amendment was filed in January 2025, the material changes made to our documents are: In July 2025 the firm amended the description of our advisory services. In September 2025 the firm added a discretionary trading option to our Asset management Services.
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On February 17, 2026, we submitted our annual updating amendment for fiscal year 2025. We amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Securities Backed Lines of Credit (SBLOCs), Political Risk and Artificial Intelligence ('AI') Risk.
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Since the last Annual Amendment on March 18, 2025, we have the following material change to report: This Form has been updated to disclose that we do not sponsor, manage, or participate in a Wrap Fee Program.
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RS Petrell & Associates has two material changes to report since the Amendment filed January 8, 2026. First change: RS Petrell & Associates has entered into a material relationship with Mayflower Financial Advisors LLC as of January 09, 2026. Mayflower will provide Third Party Asset Management Services to a portion of RS Petrell & Associates clients. Second change: Kestra Financial is no longer holding themselves out to Advisors as a Third-Party Asset Manager.
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"Van Diest Capital has the following material changes to report. Material changes relate to Van Diest Capital's policies, practices or conflicts of interests." Lists 8 specific changes: (1) Transitioning to SEC registration from state-level registration; (2) Added Charles Schwab & Co Inc. as a custodian; (3) Updated Item 8.C to disclose hedge funds, private equity funds, venture capital funds and private placements; (4) Updated fee calculation for portfolio management fees (paid in advance); (5) Updated contact email address and phone number; (6) Updated Outside Business Activities; (7) Updated ownership information; (8) Added Socially Responsible Investing and ESG considerations.
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February 5, 2025 – Item 15 was amended to disclose procedures concerning Standing Letters of Authorization.
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Item 2 explicitly lists five specific material changes: Item 4 – Advisory Business – Updated to include language regarding SAM's services performed on behalf of a private fund; Item 5 – Fees and Compensation – Updated to provide information regarding SAM's fees associated with its private fund investment management services and its removal of hourly financial planning fees from its services; Item 6 – Performance-Based-Fees and Side-By-Side Management – Updated to information regarding SAM's performance fees associated with its private fund investment management services, and conflicts associated with side-by-side management; Item 10 – Other Financial Activities and Affiliations – Updated to include disclosures and conflicts of interest related to SAM's private fund investment management services; Item 14 – Client Referrals & Other Compensation – Updated to reflect the cancellation of its arrangement for paying for client referrals.
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The following material changes have been made to this brochure since our last filing in January, 2025: Item 4 was updated to include digital assets as the type of investment we advise on. Item 8 was updated to disclose risks pertaining to blockchain, digital assets & virtual currency investments.
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The following changes have been made since our last annual amendment filing on March 17, 2025: Mateusz Sudol became the CCO. Item 4: Services, Fees & Compensation - updates to advisory services including non-discretionary account management, private placement tax equity strategies, DST investments through Inland Securities Corporation, and Financial Institution Consulting Services. Item 9: Additional Information - The firm added disclosure language regarding the use of cryptocurrency used in model portfolios.
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"The following changes have been made since our last annual amendment filing on March 17, 2025: Mateusz Sudol became the firm's CCO. Item 4: Advisory Business - new services for non-discretionary advisory, private placement tax equity strategies, DST investments, and Financial Institution Consulting Services. Item 5: Fees and Compensation - new flat fees ($3,000-$5,000) for coordination services. Item 8: Methods of Analysis - added cryptocurrency disclosure language."
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"The following changes have been made since our last annual amendment filing on March 17, 2025: Mateusz Sudol became the CCO. Item 4: Services, Fees & Compensation - Price Financial manages advisory accounts on a discretionary and non-discretionary basis... private placement tax equity strategies with charitable donation option... DST investments through Inland Securities Corporation... Financial Institution Consulting Services. Item 9: Additional Information - The firm added disclosure language regarding the use of cryptocurrency used in model portfolios."
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"The following changes have been made since our last annual amendment filing on March 17, 2025" - Changes detailed in Item 4 (Advisory Business: discretionary/non-discretionary authority, private placement tax equity strategies with charitable donation option, DST investments, Financial Institution Consulting Services), Item 5 (Fees and Compensation: flat fees $3,000-$5,000 for coordination services, fixed fees for DST investments, consulting fees from Mutual Securities), and Item 8 (added cryptocurrency disclosure language for model portfolios).
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The following changes have been made since our last annual amendment filing on March 17, 2025: Item 4 - Services, Fees & Compensation changes include non-discretionary authority details, private placement tax equity strategies with charitable donation options, DST investments through Inland Securities Corporation, and Financial Institution Consulting Services through Mutual Securities; Item 9 - Added disclosure language regarding cryptocurrency use in model portfolios.
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Item 4 has been updated to reflect the firm's current investment strategies and assets under management.
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Since the last filing of this brochure on January 14, 2025 the following changes have been made: Item 4 has been amended to reflect an updated asset under management calculation. Item 5 updated to reflect increased investment management minimums for consulting services to be included without an additional fee and updated minimum fee for financial planning and consulting services. Item 10 and the supplemental brochure for Robert Roy have been updated to reflect a new other business activity.
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TradeWinds Wealth Management has made the following material changes since its last annual amendment: Item 4 was updated on February 20, 2026, to explain any sub-advisor relationships that we have with Clients. Item 5 was updated on February 20, 2026, to include revised information regarding our fee schedule. We have added information related to how fees are charged on incoming and outgoing cash flows. In addition, we have revised Item 5 to explain any sub-advisor relationships that we have with Clients and the separate fee charged for this. Item 14, Client Referrals and Other Compensation was updated on February 20, 2026, to reflect our arrangements with various entities that assist with promoting our firm and the compensation we provide to them.
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The material changes in this brochure from the last annual updating amendment of Liberty Asset Management, LLC on February 18, 2025, are described below. Material changes relate to Firm name policies, practices or conflicts of interests only. • Liberty Asset Management, LLC has transitioned to registration with the United States Securities and Exchange Commission from its prior registration at the state level. • Liberty Asset Management, LLC, does not offer WRAP fee services. (Item 4)
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Since filing the annual amendment to this brochure in February 2025, McDonnell Capital Management transitioned from being a state-registered adviser firm to federal registration with the U.S. Securities and Exchange Commission. Item 19 has been removed from this brochure because that section is only for state-registered firms. We also updated Item 4 to better describe the services provided through our Employee Retirement and Benefit Plan Consulting services. Item 5 was updated to include our current standard fee schedule for Investment Management Services. The previous fee schedule showed 0.75% for the Next portion up to $5,000,000 and 0.50% Above $5,000,000. The new fee schedule shows 0.85% for the Next portion up to $5,000,000 and 0.75% Above $5,000,000. We also updated the Limited Negotiability of Advisory Fees & Account Minimums to include additional language about discretion to negotiate account minimums and alternative fees.
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The material changes in this brochure from the last annual updating amendment of Wealth Ease Wealth Management on 01/13/2026 are described below. Material changes relate to Wealth Ease Wealth Management's policies, practices or conflicts of interests. • The firm has updated its email address. (Cover Page) • The firm updated its Portfolio Management services and fees. (Items 4 and 5) • The firm is transitioning to registration with the United States Securities and Exchange Commission from its prior registration at the state level.
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Since our last annual amendment was filed in March 2025, the following material change has been made to this disclosure brochure: (1) In April 2025 and January 2026, the firm adjusted our Asset Management fee schedule. (2) The firm also clarified our Financial Planning service program. (3) The firm is transitioning to registration with the United States Securities and Exchange Commission from its current registration at the state level.
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Since the filing of our last annual updating amendment dated February 11, 2025, we have the following material changes to report: Item 4 – Advisory Business: registration change from state to SEC (September 30, 2025), conflict of interest for rollovers, updated AUM; Item 5 – Fees and Compensation: updated billing date, refund policy for terminated accounts, conflict of interest for insurance commissions; Item 8: added cybersecurity risks information; Item 10: conflict of interest for insurance commissions; Item 11: added Code of Ethics information; Item 12: updates to brokerage practices including mutual fund share class selection, soft dollar arrangements, aggregated trading, trade error correction; Item 15: noted custody of client assets; Item 19: eliminated state-registered adviser information.
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Since the last filing of this brochure on September 19, 2025 the following has been updated: Item 4 has been updated to disclose the most recent calculation for client assets under management. We are no longer offering financial planning services.
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Since its last filing on March 28, 2025, there have been the following material changes to this Form ADV Part 2A. Item 4 – Advisory Business has been updated to reflect Sage Barfield as the Chief Compliance Officer, Items 4 and 5 have been updated to disclose sub-advisor relationship, Item 10 C has been updated, Schedule A – Ownership has been updated.
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Since the last filing on July 22, 2025, the following changes have been made: Item 4 has been updated to reflect the firm's most recent assets under management calculation. Items 4, 5 and 10 have been updated to remove third party manager services.
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Since the last update filed on March 13, 2025, the following has been updated: Item 4 to update the assets under management for the firm; The fee schedule has been updated in Item 5; Ongoing financial planning services have been added.
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Huffman & Ross Wealth Management has the following material changes to report. Material changes relate to Huffman & Ross Wealth Management's policies, practices or conflicts of interests. The firm has updated their E-Mail. (Cover Page). The firm has updated its assets under management. (Item 4.E). The firm has updated its outside business activities. (Item 10.C). The firm has added a website. (Cover Page).
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Since our last annual update filing dated January 30, 2025, we have made the following material changes: • We have added hourly financial planning as a service offering.
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Since our last annual update filing dated January 30, 2025, we have made the following material changes: We have added hourly financial planning as a service offering.
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Since our last annual update filing dated January 30, 2025, we have made the following material changes: We have added hourly financial planning as a service offering.
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On February 11, 2026, we submitted our annual updating amendment filing and made the following amendments to our Brochure: Item 4: The amount of discretionary assets under management was amended to $165,776,178. Legacy references regarding the use of independent managers were removed. Item 5: Legacy references regarding the use of independent managers were removed. Item 8: Additional risk disclosures were made. Item 15: Our custody disclosures were updated.
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Since our initial filing on July 18, 2025, the following material changes have been made: (1) We are filing our initial registration as an investment adviser with the Securities and Exchange Commission (SEC), managing greater than $100,000,000 in assets; our previous registration was with the State of Arizona. (2) We have updated our disclosure document to reflect a change in address of our primary business location. (3) We have updated our disclosure document to reflect that we are no longer affiliated with Tarbox Family Office, Inc. (4) We have updated our disclosure document to reflect the addition of Sub-adviser relationships.
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The material changes in this brochure from the last annual updating amendment of Trinity Investment Management, LLC on 03/26/2025, are described below. Material changes relate to Trinity Investment Management, LLC's policies, practices or conflicts of interest. • Trinity Investment Management, LLC has retired its use of a Wrap Fee Program. (Item 4)
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As of December 1, 2025, Wellington-Altus USA, Inc. ('WA (USA)') amalgamated (combined) with Wickham Investment Counsel Inc. ('Wickham'). Prior to the combination, Wickham was a registered Portfolio Manager in Canada. As such, WA (USA) is now a registered Portfolio Manager.
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As of December 1, 2025, Wellington-Altus USA, Inc. ("WA (USA)") amalgamated (combined) with Wickham Investment Counsel Inc. ("Wickham"). Prior to the combination, Wickham was a registered Portfolio Manager in Canada. As such, WA (USA) is now a registered Portfolio Manager.
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Since our annual updating amendment in February 2025, we have made the following material interim changes: (1) We have provided additional information about our standalone financial planning services. See Item 4 and Item 5 for more information; (2) We have included information about a new broker-dealer affiliate in Item 10.
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Since that date, there have been the following material changes to Oak Street Advisors' advisory business: 1) Oak Street Advisors has applied for registration as an investment advisor with the SEC; 2) Item 4 has been updated to include additional information about our advisory business; 3) Item 5 has been updated with additional details regarding our investment management and financial planning fees.
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Since the last ADV update dated April 21, 2025, when the Firm is transitioned from state registration to registration with the Securities and Exchange Commission, the following material changes have been made: Firm address changed on the cover page. Disclosure of SLOAs added to Item 15.
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Since the most recent Annual Amendment filing on March 19, 2025, this Disclosure Brochure has been amended as follows: removal of referral compensation disclosures at Items 4 and 10; fee calculation example added and hourly rate updated to $325 at Item 5; cryptocurrency-linked securities risk disclosure added at Item 8; removal of Item 19 related to SEC registration transition.
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Since our most recent annual update to this Brochure, the following material changes have been made: (1) KW updated the service offering and fees for Investment Management Services. See Item 4 and 5 for further information. (2) KW updated the description of advisory fees charged to retirement plans to reflect that some plans will pay fees in advance of each quarter while others will pay fees in arrears for the previous quarter, depending on the platform. Additionally, the advisory fee may be calculated based on either (i) the Average Daily Balance of the plan assets for the billing period or (ii) the value of the Client's account(s) as of the last day of the billing period.
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Since the firm's most recent annual update, Ideal Retirement Solutions, LLC has made the following material changes to its policies, practices, or conflicts of interest: (1) Clarified the scope of tax-related considerations provided in connection with investment advisory services; (2) Added disclosure regarding an affiliated tax services firm under common ownership.
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This Form ADV Part 2A firm brochure has been revised pursuant to Zuckerman Capital Management, LLC's registration as an investment adviser with the SEC, superseding previous versions. Updates include our advisory services and reportable assets under management (Item 4), fee processing (Item 5), revised risk statements (Item 8), an updated to management participation in the financial industry (Items 5 and 10), and how we serve client accounts (Items 15), among others.
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"Material changes have been made to the policies, procedures, or management of the Firm since the August 2025 version." Lists specific changes: Item 4 (Advisory Business - updated to SEC registration), Item 5 (Fees and Compensation – updates), Item 10 (Other Financial Activities and Affiliations – updates to broker-dealers), Item 12 (Brokerage Practices – updated for custodian information), Item 13 (Review of Accounts - updated), Item 15 (Custody - updated for custodian information), Item 19 (Requirements for State Registered Advisers - removed), Brochure Supplements - removed.
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Since filing our last annual amendment to our Wrap Brochure on February 1, 2025, there has been one material change to report: Item 9: We have added Altruist Financial LLC as a custodian.
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Since our last annual updating amendment, dated 02/20/2025, we have made the following material changes to our Form ADV: 1. We have updated our language under brokerage practices. (item 12) 2. We have updated our language under custody (item 15) and soft dollars (item 12). 3. We have updated our language under Disciplinary Information (Item 9). 4. We have updated our hourly fee (Item 5).
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Since our last annual updating amendment, dated April 28, 2025 we have the following changes to report: Item 4 Advisory Business: We updated the Financial Planning section to reflect that we offer standalone financial planning services in which case we will charge a negotiated fee based on individual client circumstances. Item 5 Fees and Compensation: We updated the billing terms for standalone Financial Planning services from a fixed one-time fee to a negotiated fee, billed quarterly.
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This Brochure has been updated to reflect the following material changes since the Firm's last annual update: 1) Increase in Assets Under Management - The Firm has experienced an increase in assets under management due to organic growth and the addition of new client relationships; 2) SEC Registration - The Firm is now registered with the U.S. Securities and Exchange Commission ("SEC"). Previously, the Firm was registered with one or more state securities authorities; 3) Elimination of Soft Dollar Benefits - The Firm has discontinued participation in soft dollar arrangements.
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Since our Previous annual ADV Update in 2025 we have made the following material changes: Item 15: Updated description of advisory firm to indicate that PFM no longer takes custody of client assets.
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The following material changes have occurred since our initial SEC application filing on June 17, 2025: (1) In November 2025, the Firm's main office location moved to: 3120 Sabre Drive, Suite 160 Southlake, TX 76092; (2) The firm offers a wrap fee program for all accounts under management; (3) Item 4 was updated to include description of our firm's affiliated entity, PWM Tax Group, LLC; (4) Item 5 was updated to include a new payment option for financial planning fees; (5) Item 10 was updated to reflect certain IARs of our firm are no longer dually registered with the unaffiliated, SEC registered investment advisor, Osaic Wealth, Inc.; (6) Item 10 was updated to include disclosures regarding the affiliated tax services entity, PWM Tax Group, LLC
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Since our firm's last annual updating amendment dated January 22, 2025, we have made the following material changes to this Brochure: (1) January 22, 2025 - amended to disclose that our firm offers discretionary management services to certain retirement accounts, such as a 401(k) account, through an unaffiliated web-based platform; (2) January 24, 2025 - amended as part of a registration application with the SEC; (3) April 28, 2025 - amended to disclose an increase in our maximum annual fee for portfolio management services; (4) August 22, 2025 - amended to disclose that our portfolio management services are billed monthly in arrears, and are typically based on the average daily balance of the portfolio over the billing month, and that we may aggregate orders.
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Since our most recent Annual Amendment filing, dated March 7, 2025, the following changes have been made to this Disclosure Brochure: • At Items 1 and 4 to remove reference to a former Oklahoma branch office. • At Item 4 to revise the firm's Cash Positions disclosure, in connection with the cessation of asset-based fee billing. • At Item 5 to update the minimum fee for Stage 1 Financial Planning services to $3,350 and to incorporate additional explanatory details regarding initial fee billings for certain managed accounts.
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Elemental has made the following material changes to this disclosure brochure since its last annual amendment filing on January 3, 2025: Item 4 – Advisory Services: Elemental now provides portfolio management services outside of the Ascend Portfolio Strategy.
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"On February 25, 2026, we submitted our annual updating amendment filing for fiscal year 2025. We have updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management of approximately $285,025,351, and non-discretionary assets under management of approximately $0. In addition, we amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Direct Indexing, Securities Backed Lines of Credit (SBLOCs), Political Risk and Artificial Intelligence (AI) Risk. On November 18, 2025, we amended Items 4 and 5 of our Form ADV Part 2A Brochure to describe our services and relationship with the co-adviser with more accuracy, and to provide additional disclosures regarding the sale of insurance products. We also amended Item 14 to provide additional disclosures about the receipt of benefits from our custodian and vendors. Additionally, Joseph Griffin is no longer employed by our firm. As such, we amended several sections of our Form ADV 2 Brochure to identify Gregory D. Black as our CCO. On June 25, 2025, we amended Item 4 of our Form ADV Part 2A Brochure to disclose Retirement Plan Consulting as one of the advisory services offered by our firm. We also amended Item 5 to provide disclosures about related fees and payment arrangements."
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Moffatt Financial Strategies has initiated transition to registration with the United States Securities and Exchange Commission from its current registration at the state level. Moffatt Financial Strategies does not participate in a Wrap Fee Program. (Item 4) Moffatt Financial Strategies has updated its Assets Under Management. (Item 4.E) Moffatt Financial Strategies has disclosed its use of third-party advisers and applicable fees. (Items 4, 5, and 10) Moffatt Financial Strategies has added Fidelity Brokerage Services as a custodian. (Item 12)
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Wurz Financial Services, LLC has the following material changes to report. Material changes relate to Wurz Financial Services, LLC's policies, practices or conflicts of interests. • Wurz Financial Services does not offer pension consulting services and all sections related to that activity has been removed from the brochure. • Wurz Financial Services has added a new service. (Items 4 and 5) • Wurz Financial Services, LLC has successfully transitioned to formal registration with the Securities and Exchange Commission from its previous registration at the state level. • Wurz Financial Services has updated Fixed Fees. (Item 5)
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"The following material changes have occurred since our initial registration filing:" - Lists specific changes including: Firm's transition from state registered to SEC registered investment adviser (February-March 2026), changes to Advisory Business in Item 4 (financial consulting/planning services, tax services through affiliated entity NIM Tax Solutions, Inc.), changes to Fees and Compensation in Item 5 (fee structures, financial consulting fees ranging $20,000-$100,000), and added disclosures about insurance recommendations in Item 10.
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The following material changes have occurred since our initial registration filing: (1) The Firm requested SEC registration in February 2026, transitioning from state-registered to SEC-registered investment adviser in March 2026; (2) As an SEC registered investment adviser: no monthly invoice requirement, no prepayment of more than $1,200 in fees six months in advance, removed state registration references; (3) Item 4 - Advisory Business: added financial consulting and planning services, tax services through affiliated entity NIM Tax Solutions, Inc.; (4) Item 5 - Fees and Compensation: annual fees up to 2.00% of assets under management, stand-alone financial consulting fees range from $20,000 to $100,000; (5) Item 10 - Other Financial Industry Activities: added disclosures regarding insurance recommendations.
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The Firm requested SEC registration in February 2026. The Firm anticipates transitioning from a state registered investment adviser to an SEC registered investment adviser in March 2026. As an SEC registered investment adviser: The Firm will not send a monthly invoice to you itemizing the service fee, 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 do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. The Firm has removed references to requirements for state registered investment advisers. Item 4: Financial consulting and planning services are included as part of our investment advisory services for no additional fee. For clients engaged in investment advisory or stand-alone financial consulting and planning, tax consulting and planning and services are included through our affiliated tax services entity, NIM Tax Solutions, Inc. NIM's annual fees are based upon a percentage of assets under management not to exceed 2.00%.
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The Firm requested SEC registration in February 2026. The Firm anticipates transitioning from a state registered investment adviser to an SEC registered investment adviser in March 2026. Multiple changes stemming from SEC registration: no monthly invoice for service fees, no prepayment requirement over $1,200, removed references to state registration requirements. Item 4 updates: financial consulting/planning now included with investment advisory services, tax consulting through affiliated entity, fee structure changes including stand-alone planning fees ($20,000-$100,000). Item 9: "The firm has added disclosures regarding insurance recommendations"
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The material changes in this brochure from the last annual updating amendment of Align Wealth Management, LLC on 02/19/2025 are described below. Material changes relate to Align Wealth Management, LLC's policies, practices or conflicts of interests. • The firm has added Fidelity Brokerage Services LLC as a custodian to Item 12. • The firm is transitioning to registration with the United States Securities and Exchange Commission from its prior registration at the state level (Entire Document). • The firm removes AssetMark Trust Company as a custodian (Item 12). • The firm added Fidelity Institutional Wealth Adviser, LLC (Item 4 and Item 14).
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"The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on February 6, 2025: • The Advisor has added Securities Backed Lending/Lines of Credit as part of its service offering. Please see Item 4 and Item 8 regarding these changes. • The Advisor has established institutional relationships with Altruist Financial. For more information, please see Item 12 and Item 14."
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The following material changes have been made since our last Brochure dated June 27, 2025: 1. We revised Item 4 to include that LFA may recommend the selection of third-party advisers, co-advisers, or sub-advisers in connection with managing client portfolios. Please see Item 4 for more information. 2. We revised Item 5 to include information regarding the fees and compensation when third-party money managers are recommended. Any fee due to a third-party manager is paid out of the Advisory Fee paid to LFA. This third-party manager fee is disclosed in a separate disclosure delivered to the client by LFA or the third-party manager at or before the time the assets are designated to be managed by the third-party. Please see Item 5 for more information. 3. We revised Item 8 to include factors taken into consideration when LFA recommends the services of a third-party money manager. Please see Item 8 for more information. 4. We updated Item 10 to reflect that Drew Holland is now a registered insurance agent. From time to time, Drew will offer clients advice or products from those activities. Clients should be aware that the placement of insurance products and related services pay customary commissions. Please see Item 10 for more information. 5. We updated Items 10 and 12 to add details regarding LFA's participation in Schwab's Institutional customer program. LFA may recommend that clients use Schwab for custody and brokerage services. There is no direct link between LFA's participation in the program and the investment advice it gives to its clients. Under this program, Schwab makes certain research and brokerage services available at no additional cost to our Firm. Please see Items 10 and 12 for more information. 6. We updated Items 10 and 14 to include details regarding the potential referral relationship that may exist when LFA recommends the services of a third-party money manager. If a client is introduced to a third-party manager by LFA, LFA may receive a solicitor fee in accordance with the requirements of state and/or federal securities law, as applicable. Please see Items 10 and 14 for more information.
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Since our SEC registration filing dated September 23, 2025, we have the following material changes to report: (1) Item 13 updated to reflect the addition of the Account Manager to perform account appraisals; (2) Item 17 updated to reflect that Pasnau Investment Management, Inc. does not have proxy voting authority.
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This is our annual amendment filing in which we have the following changes: Item 4 has been updated with our regulatory assets under management and to disclose our new professional tax services.
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Since the last filing of this brochure on January 27, 2025, the following has changed: The firm has transitioned to registration with the United States Securities and Exchange Commission from its prior registration at the state level. The firm added a conflict of interest. (Item 10) The firm has updated its assets under management. (Item 4) The firm has removed Financial Planning. (Items 4 and 5) The firm has removed ERIA Plan services. (Items 4 and 5) The firm has removed seminars and workshops. (Items 4 and 5) The firm has removed recommendations of other investment advisors. (Item 10) The firm has updated the frequency of the reviewing of accounts. (Item 13)
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Since the last filing of this brochure on January 27, 2025, the following has changed: • The firm has transitioned to registration with the United States Securities and Exchange Commission from its prior registration at the state level. • The firm added a conflict of interest. (Item 10) • The firm has updated its assets under management. (Item 4) • The firm has removed Financial Planning. (Items 4 and 5) • The firm has removed ERIA Plan services. (Items 4 and 5) • The firm has removed seminars and workshops. (Items 4 and 5) • The firm has removed recommendations of other investment advisors. (Item 10)
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The material changes to DRCM are as follows: Item 1 was updated to reflect a new suite number for the principal place of business. Item 13 was updated to reflect the firm's practice of performing account review on a quarterly rather than a bi-weekly basis.
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Since our last annual updating amendment, dated 03/28/2025, we have made the following material changes to our Brochure: Item 5 was updated with Soft Dollar information; The firm has transitioned to registration with the United States Securities and Exchange Commission from its prior registration at the state level; Item 5 has been updated to reflect new fees.
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Since our last brochure filed on July 23, 2025, the firm's disclosure brochure has had the following material changes: Item 4 Updated language to remove participation in wrap programs; Item 5 Updated language for Treatment of Mutal Fund Share Classes; Item 10 We have changed our name from Legato CPAs and Advisors PLLC to LFG Tax Partners, LLC; Item 15 Updated language for our Custody section.
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Since our Brochure dated March 31, 2025, Hinsdale has updated the overall formatting of this Brochure. In addition, Hinsdale has incorporated new disclosures or clarifying language to the following sections of this Brochure: Enhanced disclosures in Item 10 (Other Financial Industry Activities and Affiliations) relating to the licensing of Hinsdale employees for the sale of insurance products; Clarified language in Item 11 (Code of Ethics); Clarified language in Item 12 (Brokerage Practices); Enhanced disclosures in Item 14 (Client Referrals and Other Compensation); Enhanced disclosures in Item 15 (Custody); Clarified language in Item 17 (Proxy Voting).
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Since that date, there have been the following material changes to Fairlight Advisors, LLC's advisory business. 1) Fairlight Advisors, LLC has applied for registration as an investment advisor with the SEC. 2) Item 5 has been updated with information regarding the firm's fee and compensation arrangements. 3) Item 15 has been updated with additional information regarding the firm's custodial arrangements.
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The following material changes have occurred since our previous annual amendment filing, dated February 15, 2025: Firm converted from State Registered Investment Advisor (RIA) to SEC RIA in December 2025; Item 4 changes regarding investment advisory services, portfolio allocations, and standalone financial planning services; Item 5 changes to Financial Planning fees (fixed, $1,500 to $5,000) and prepayment limitations; Item 8 changes adding risk disclosures including market risks, cybersecurity risks, artificial intelligence, and alternative investments; Item 14 changes regarding custody and standing letter of instruction (SLOA) procedures with SEC's seven conditions.
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Since filing its last annual updating amendment on February 11, 2025, SSF has implemented the following changes: (1) SSF is now registered with the Securities Exchange Commission; (2) SSF has added Misty Cherniss as an IAR; (3) SSF has updated services in Items 4 to disclose Canopy by SeedSafe; (4) SSF has updated its fees in Item 5 to disclose fees for Canopy by SeedSafe, and update fees for Financial Planning Services.
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Since the firm's last annual updating amendment filed on March 6, 2025, we have the following material changes to report: Item 12 Brokerage Practices was updated to add Fidelity as a recommended custodial broker-dealer. Item 5 Fees and Compensation was updated to reflect that asset-based fees are calculated based on average daily market value during the applicable billing period.
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Since our previous filing on February 24, 2025 there have been the following material changes: We have updated our minimum account size to $250,000. We are registering with the SEC. We have updated Global Compounding Quality to Global Compounding Quality.
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Since the last filing of this brochure on September 09, 2025, the following changes have occurred: Items 4, 5, 8, and 10 to add information on a sub-advisor relationship.
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Since our last annual update to this brochure was filed in February 2025, we have transitioned from being a state-registered adviser firm to federal registration with the U.S. Securities and Exchange Commission. Subsequently, Item 19 has been removed from this brochure because that section is only for state-registered firms. The Form ADV Part 2B Brochure Supplements previously contained within this document have also been removed as SEC-registered firms are not required to file Brochure Supplements on the IARD system. Updates were made to explain that advisory fees associated with Asset Management Services are billed and collected on a monthly basis. We also updated our fee schedule for Asset Management Services. Additional disclosures were added for our fee billing arrangements and termination procedures. We also updated Item 5 and Item 16 to explain we have the authority to hire/fire at our discretion the institutional investment managers, also referred to as Sub-Advisers, who provide discretionary management of individual portfolios through the CAAP program. The financial planning service descriptions have been changed because we have gone to an annual meeting rather than a semi-annual meeting.
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The following material changes have occurred since the firm's initial registration filing, February 24, 2025: The Firm requested SEC registration in January 2026, transitioning from a state registered investment adviser to an SEC registered investment adviser in February 2026; the Firm no longer sends monthly invoices itemizing fees; the Firm removed references to state registered investment adviser requirements; Item 4 and Item 5 updated to include description of services and coordination fees associated with Wealth.com estate planning solution; Item 10 updated to include disclosures regarding Russell Strickler's outside activity as managing member of SoLiv, LLC.
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Since our last annual amendment dated March 29, 2025, we have made the following material changes: With our Wealth Management Services, when appropriate for your financial circumstances, we may engage the services of a third-party investment management program offered by AE Wealth Management LLC ("AEWM") to manage all or a portion of your assets. Information regarding the third-party investment management program offered by AEWM has been added to Item 4, and information regarding the associated fees is included in Item 5.
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"During the calendar year of 2025, the Firm made a series of significant changes including: Changed its legal structure from a sole proprietorship; Registered with United States Securities and Exchange Commission; Registered John 'Garrett' Rowe as an Investment Adviser Representative; Added two additional versions of its MAP investment strategy (MAP+ and MAP Balanced); Added a more passive investment strategy called IPA for Index Program Account. The firm altered its fee structure for all new program accounts to better align its fee schedule with the range of services it will offer to its clients. Further, the Firm has added an hourly consulting fee rate strictly applicable to current clients and the executors of estates of deceased clients. Finally, the Firm has added an incentive, performance based fee for those investors who are eligible. The Firm will be engaging in marketing efforts via various social media networks."
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As of the last update on August 28, 2025, below are VIP's material changes: Item 4 – Advisory Business was amended to provide additional information to retirement investors; Item 5 – Fees and Compensation was amended to provide additional information regarding underlying investment expenses and other custodial costs and expenses associated with VIP's portfolio management services, as well as VIP's practices with respect to share class recommendations for mutual funds; Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss was amended to provide additional information describing operational and third-party risks, the risks associated with cryptocurrency and/or digital assets, and risks associated with international investments; Item 10 – Other Financial Industry Activities and Affiliations was amended to provide additional information regarding conflicts of interest and how VIP mitigates such conflicts of interest; We removed the included Privacy Notice which will be a standalone document going forward.
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Since our last annual brochure filed on February 24, 2025, the firm's disclosure brochure has had the following material changes: Item 4: Updated Assets Under Management figures as of December 31, 2025. Item 10: Added new Financial Industry Affiliation, M50 Tax Pros, LLC which is a tax preparation service affiliated with Martinsen Wealth Management. Items 4, 5, and 10: Updated Advisory Business, Fees, and Financial Industry Activities to disclose new line of business, Estate Planning which Martinsen Wealth Management offers for a fee. Items 4, 5, and 10: Updated Advisory Business, Fees, and Financial Industry Activities to disclose new line of business, Credit and Identity Theft Monitoring which Martinsen Wealth Management offers for a fee.
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Since our last annual brochure filed on February 24, 2025, the firm's disclosure brochure has had the following material changes: Item 5: Updated to reflect Assets Under Management as of December 31, 2025; Item 9: Added new Financial Industry Affiliation, M50 Tax Pros, LLC; Item 9: Added new Financial Industry Activity, Estate Planning; Item 9: Added new Financial Industry Activity, Credit and Identity Theft Monitoring.
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Since our last annual update filing dated July 8, 2025, Align has made the following material changes to this document: Item 4 (Advisory Business) - merger with Agile Retirement Management (ARM), bringing ARM accounts into Align, and allowing legacy ARM accounts to continue under their previously agreed to services and fee structures; Item 10 (Other Financial Industry Activities) - details about Roger Whitney's ownership of RP Whitney, LLC and educational content activities via "The Retirement Answer Man" podcast and "The Rock Retirement Club".
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"The following material changes have been made to this Disclosure Brochure since the annual amendment filing on 3/07/2025: ● The Advisor has amended Item 4 and Item 5 to reflect an educational book sold by CPW. Please see Item 4 and Item 5 for more details. ● The Advisor has started using online lead generation services. Please see Item 14 for more information."
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Since the last annual amendment filed on 02/14/2025, we have made the following material changes: (1) Items 4 and 5 have been updated to disclose that the Firm is now offering discretionary management of digital assets; (2) Item 5 has been updated to disclose that the maximum fee for retirement consulting services is 1.5%; (3) Item 8 has been updated to disclose the risks related to the purchase and sale of Digital Assets; (4) Item 12 has been updated to disclose the addition of BitGo as a Custodian; (5) Item 17 has been updated to disclose that the Firm does not vote proxies on behalf of clients.
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"The following material changes have been made to this Disclosure Brochure since the annual amendment filing on January 27th, 2025: • The Advisor no longer utilizes LPL Financial LLC as a custodian."
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Since the last filing on January 23, 2026, the following has changed: • Item 5 has been updated to disclose the use of sub-advisors.
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Since the last update of this brochure on April 7, 2025, the following material changes were made: Item 4, 5, and 8: Advisor updated to disclose the use of third-party portfolio managers (Outside Managers) to manage client portfolios. Item 5: Fees and Compensation - Advisor updated the maximum allowable onboarding fee to $1200.
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In February 2026, the Investment Committee increased the upper weighting limit for funds that offer clear hedging against the stock market, such as inverse ETFs and zero-coupon bond funds, to 20% for each position. The reason for the change is that under extraordinary market conditions, LCM needs to have greater flexibility to take extraordinary action to protect our clients' portfolios.
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The following material changes have been made to this Disclosure Brochure since the last annual filing on 2/27/2025: ● The Advisor offers financial planning services on an ongoing basis only. Please see Item 5 for additional information. ● The Advisor has updated its max financial planning fee. Please see item 5 for additional information.
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Since our last annual amendment on January 24, 2025, we have made the following material changes: Item 4, Advisory Business, has been updated to remove insurance as an area of analysis for Ongoing Financial Planning services; Item 10, Other Financial Industry Activities and Affiliations, has been updated to remove Steve Witter as a licensed insurance agent; Item 12, Brokerage Practices, has been updated to reflect that we recommend the custodial and brokerage services of Charles Schwab & Co., Inc. and to include that there are circumstances where we recommend other custodians for certain types of accounts, such as 529s or retirement accounts; We have amended Item 15, Custody, to reflect that BW has custody of client funds and securities in some circumstances, and to describe the practice we use to safeguard client assets when we have custody.
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Since our last annual updating amendment dated February 28, 2025, we have the following material change to report: Item 4, Advisory Business and Item 8 Methods of Analysis, Investment Strategies and Risk of Loss - clarification about equities; Item 5, Fees and Compensation - Cadaret Grant acquired by LPL Financial LLC; Item 14, Client Referrals and Other Compensation - clarification on no compensation for client referrals.
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The Firm has updated certain disclosures about: its manner of charging management fees, its management of client portfolios on either a discretionary or non-discretionary basis, its manner of analysis, and Item 17 for decline of proxy voting.
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The material changes in this brochure from the last annual updating amendment of Seaside Advisory Services, Inc. on 2/20/2025 are described below. Material changes relate to Seaside Advisory Services, Inc. policies, practices, or conflicts of interests only. Seaside Advisory Services, Inc. is in the process of transitioning from registration with The Securities and Exchange Commission to registration with the States of California, Connecticut, New York, and Washington. Seaside Advisory Services, Inc. updated its assets under management. Seaside Advisory Services, Inc. updated its asset management services to include financial planning. Seaside Advisory Services, Inc. removed Investment Management Services. Seaside Advisory Services, Inc. updated its fee disclosures. Seaside Advisory Services, Inc. updated Shawn Orser's other business activities. Seaside Advisory Services, Inc. updated its directed brokerage disclosure. Seaside Advisory Services, Inc. updated Item 19 to reflect Shawn Orser's relationship with issuers of securities. Seaside Advisory Services, Inc. no longer offers a wrap fee program.
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The following changes were made since the last filing on February 14, 2025: Item 4 – to update the assets under management for the firm. Item 15 – to add Third Party Standing Letters of Authorization.
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Since the last filing of this ADV Part 2 on 05/12/2025, the following material changes have been made: (1) We have updated Ownership and DBA in Items 1 and 4; (2) Sound Advisory dba Gannett Wealth Advisors was acquired by Gannett Trust Company, LLC, enabling potential recommendations for affiliated trust and custody services; (3) We have added the Firms Website in Item 1; (4) We have made additional disclosures in Item 8; (5) We have disclosed Non Discretionary authority in Item 16.
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The following material changes have been made to this Disclosure Brochure since the last filing on and distribution of this Disclosure Brochure to Clients: Item 1 has been revised to indicate a new principal office address. Item 4 has been revised to include additional information regarding our advisory services.
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"The material changes in this brochure from the last annual updating amendment of WPM Wealth Advisors LLC on 02/28/2025 are described below. Material changes relate to WPM Wealth Advisors LLC's policies, practices or conflicts of interests. • WPM Wealth Advisors added language to incorporate their use of inverse and leveraged ETFs in Item 6. • Removed Item 10: Requirements for State Registered Advisers since WPM Wealth Advisors maintains SEC Registration. • Added Leveraged Mutual Funds to Item 6. • Updated Item 5: Types of Clients. • WPM Wealth Advisors added financial planning in Item 4."
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"The material changes in this brochure from the last annual updating amendment of R. Seeger Wealth Management, LTD on 02/05/2025 are described below. Material changes relate to R. Seeger Wealth Management, LTD's policies, practices or conflicts of interests. • The firm has updated its phone number. (Cover page) • We will require clients to use a specific broker-dealer to execute transactions. (Item 12)"
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As of the date of this brochure. February 6, 2026, GST has the following material changes to communicate to investors: (1) Item 4 – Advisory Business: GST has amended its list of model portfolios to reflect changes in advisory strategies offered to its investors. (2) Item 4 – Advisory Business: GST has updated its regulatory assets under management to reflect data as of February 4, 2026.
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We have updated Item 15 to describe changes to our forms of Custody. Otherwise, we have not made material amendments to this Disclosure Brochure since our last annual filing on February 24, 2025.
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We have the following material changes to report since the last annual update of the brochure dated December 31, 2024 filed on March 18, 2025: (1) As our assets under management are less than $90 million, we are transitioning from registration as an investment adviser with the U.S. Securities and Exchange Commission to the State of New Hampshire. (2) As of January 1, 2026, we do not have custody of any client funds and/or securities.
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The Adviser established agreements with Charles Schwab & Co., Inc. ("Schwab") for Schwab to provide custodial and brokerage services for the Adviser's clients that have established separately managed accounts ("SMA"). These SMA client relationships will typically include a limited power of attorney and the discretion for the Adviser to trade for clients.
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"There have been the following material changes to Inverlochy Capital, Inc since our last Brochure dated March 21, 2025. • Item 5 - Inverlochy Capital, Inc. includes financial planning services at no extra charge for all clients with assets managed by Inverlochy Capital, Inc."
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The following material changes have been made to this Form ADV Part 2A since the filing dated August 1, 2025: Item 7: updated the minimum investable asset requirements. Item 14: removal of the Community Membership as a paid service.
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Since our last filing in March 2025, we have made the following material changes: • Updated principal office address to New York, NY • Clarified fee structure and billing methodology for alternative investment monitoring services • Enhanced disclosure regarding the nature of assets under management • Clarified that advisory services are limited to monitoring and administrative oversight of client-held private placements • Replaced our CCO
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The following material changes have been made since the prior version of this document: • Updated list of services provided by Albert Corp. • The names, but not the content, of the portfolios managed by Albert Investments have been changed to: Conservative Strategy, Balanced Strategy, Growth Strategy
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The following changes may be considered material: Recalculation of assets under management in Item 4 E 3 after rule change required all clients to be served through online platform exclusively.
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This brochure includes material updates since the firm's last annual amendment dated February 5, 2025. February 26, 2026 Updates: Item 12 (Brokerage Practices): Updated brokerage disclosures to reflect Alpaca Securities LLC as the firm's primary custodian; Item 5 (Fees and Compensation): Revised advisory fee billing practices to reflect direct deduction from client brokerage accounts; Item 8 (Methods of Analysis, Investment Strategies, and Risk of Loss): Expanded investment risk disclosures, including risks associated with leveraged ETFs, short selling, margin, digital asset-related securities, and quantitative investment models; Item 7 (Types of Clients): Clarified minimum account requirements and strategy-specific minimums; Item 4 (Advisory Business): Updated descriptions of the firm's investment practices and discretionary authority, and updated ownership disclosure to reflect the firm's parent company structure. December 4, 2025: Item 5 (Fees and Compensation): revised to reflect changes to the firm's fee structure.
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Under direction of recent regulatory notice, this is Form ADV Part 2 for Bryan Advisory Services LLC in a new narrative format. In addition, we have made some changes to our fee structure to allow, along with fee adjustments, our ability to provide services with commissions providing an offset to regular fee charges.
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In addition, we have made some changes to our fee structure to allow, along with fee adjustments, our ability to provide services with commissions providing an offset to regular fee charges.
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Since the most recent annual update to Form ADV Part 2A dated March 18, 2025, the following material changes have been made to this brochure: Item 4.B Addition - Truvius now offers discretionary portfolio management services through its Platform within taxable accounts and IRAs, all containing Digital Asset portfolios known as Products; Item 4.C Amendment - Clients may impose reasonable investment restrictions, including exclusion of specific Digital Assets from their portfolios; Item 7 update - Firm now services certain retirement accounts in addition to taxable accounts
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Since our last annual amendment filing dated July 20, 2025, we have made the following material changes to this brochure: (1) Illuminate has introduced Solutions Funds as a new investment option available to clients alongside Guided Investing. Solutions Funds are equity-only thematic portfolios composed of individual stocks focused on sustainable investing themes. (2) Illuminate has discontinued its Custom Portfolio offering, which previously allowed clients to self-direct investments in individual stocks and ETFs. All investment advisory services are now provided through Guided Investing and Solutions Funds.
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The following material changes have been made since Zacks Intelligence's last other than annual update dated November 17, 2025. Zacks Intelligence has begun offering a new program to clients. Conforming changes have been made to Items 4, 5, 7, 8, 10, 12, 13, 15, 16, and 17.
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"The following material changes to this Brochure have occurred since its last amendment on October 17, 2025: Advisory Business. Since our last update, the firm has established a relationship with a qualified custodian, Altruist Corp. ("Altruist"), and has updated its business practices to permit the acceptance of client assets under management ("AUM")."
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Since the filing of our last annual updating amendment, dated March 27, 2025, we have the following material changes to report: Services, Fees and Compensation - We are also offering private funds for Indian nationals to invest in US pre-IPO private shares through Reg D 506(c) offerings as well as US Nationals to invest in Indian listed equities and Pre-IPO shares through Reg D 506(c) and Reg S offerings; Client Investment Process - Private Fund Services - We may enter co-advisory relationships with other advisors to source pre-IPO shares for Indian Nationals; Program Fee - Fees charged for Private Funds are based upon each individual offering's subscription fees and expense charges.
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The following material changes have been made to this Disclosure Brochure since the initial filing on November 21, 2025: The Advisor will assist interested Clients with establishing a digital currency account through Fidelity Digital Asset Services, LLC ("FDAS").
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A3 Capital Advisors has the following material changes to report. Material changes relate to A3 Capital Advisors' policies, practices or conflicts of interest. • A3 Capital Advisors has added Performance-Based fees. (Items 5 and 6) • A3 Capital Advisors has updated its Assets Under Management. (Item 4) • A3 Capital Advisors has updated its primary address. (Cover Page) • A3 Capital Advisors has added Consulting services and fees. (Items 4 and 5) • A3 Capital Advisors has updated its Fee Schedule and minimum account size. (Items 5 and 7) • A3 Capital Advisors has disclosed custody due to Standing Letters of Authorization. (Item 15) • A3 Capital Advisors has updated Voting Client Securities (Proxy Voting). (Item 17)
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We have updated Item 4 to reflect that the firm's interactive website is now operational.
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This Brochure is dated January 20, 2026, and represents the first annual updating amendment to our initial Brochure dated October 23, 2025. The following material changes have been made to this Brochure since our initial filing: (1) Assets Under Management (Item 4.E): Now managing approximately $171,559 in discretionary client assets, up from $0 at initial filing; (2) Advisory Services Expansion (Item 4.B): Expanded to include comprehensive Financial Planning and Wealth Advisory Services; (3) Geographic Restrictions (Items 4.B and 7): Clarified that services are NOT provided to residents, citizens, or legal entities of the EU, UK, or EEA; (4) Fees and Compensation (Item 5): Increased minimum onboarding fee, added Financial Planning fee structures, restructured subscription pricing, and disclosed cash in billing base; (5) Code of Ethics and Proprietary Trading (Item 11): Enhanced disclosure to identify firm's proprietary trading account and four specific conflicts of interest; (6) Brokerage Practices (Item 12): Identified Interactive Brokers LLC as primary recommended custodian with Charles Schwab as alternative, added trade aggregation procedures.
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Instead of using Alpaca, we are now using Interactive Brokers LLC for brokerage services.
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Section 2 lists material changes including: ITEM 5 - added discussion regarding nominal referral fees that may be paid to affiliates and associates for client referrals; ITEM 10 - clarified that GCPW provides insurance agency services through licensed affiliated insurance agencies, and may make referrals to affiliated insurance agencies; ITEM 18 - added statement confirming GCPW is not aware of any financial condition that impairs contractual commitments, and confirmed no bankruptcy petition in previous ten years.
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"In this Item, Enrich Finance is required to discuss any material changes that have been made to the brochure since its last filing. Enrich has made the following changes: • Item 4 has been amended to update the description of services provided by Enrich Finance. • Item 5 has been amended to reflect revisions to a description of fees charged when clients use Apple Pay."
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Since the firm filed its last annual amendment in February 2025, LDN Wealth has had the following material changes made this this brochure: (1) Item 4 – Under "Ongoing Financial Planning Services", removed language that would suggest LDN Wealth's investment adviser representatives would sell, solicit or negotiate variable annuity products; (2) Item 4 – LDN Wealth filed its initial application to become registered as an investment adviser with the U.S. Securities and Exchange Commission in November 2025; (3) Item 5 – LDN Wealth uses an hourly fee of $350 to calculate a client's fixed fee for advisory services.
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In 2026, we plan to provide subscription based on line investment tools to individual investors. Item 5 in the following is updated from our 2015 brochure to reflect this change.
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Since filing its initial Brochure in August 2025, the Adviser has updated its mailing and office address. Additionally, the Adviser has updated Item 4.B (Types of Advisory Services) and Item 16 (Investment Discretion) to reflect the Firm's advisory practices and the different levels of authority granted by Clients.