Williams & Novak Wealth Management, LLC

Williams & Novak Wealth Management, LLC ("W&N") is a registered investment adviser primarily based in Westlake Village, CA. We are organized as a limited liability company ("LLC") under the laws of the State of Nevada. We have been providing investment advisory services since 07/6/2023. We are owned by Jacob Williams and Daniel Christopher Novak. The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Williams & Novak Wealth Management, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. PORTFOLIO MANAGEMENT SERVICES Discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to manage your account. Discretionary authority is typically granted by the Investment Management Agreement you sign with our firm, a power of attorney, or trading authorization forms. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without obtaining your approval prior to each transaction. We will also have discretion over the broker or dealer to be used for securities transactions in your account. You may limit our discretionary authority for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. Non-discretionary portfolio management services. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account through a signed Non-Discretionary Investment Management Agreement. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. If your Financial advisor does not have authority to execute trades in your account(s), you are responsible for the implementation, trading and execution of any recommendations provided by your Financial Advisor. Sub-adviser(s) Utilization. Financial advisors may employ sub-advisors provide investment allocation and securities selection and may execute securities transactions in your accounts pursuant to an agreement with W&N and your IMA. Sub Advisors use a variety of assets in client portfolios, including equities, bonds, ETFs and/or mutual funds, options or other derivatives. In some cases, the selection of these investments creates a conflict of interest for the sub-advisor. These sub-advisors disclose conflicts of interests, including their selection of such investments, in their Form ADV Part 2. Financial Advisors advise you in establishing investment objectives, and work with the sub-advisors to ensure an appropriate investment strategy for you. You are provided with the sub-advisor's Form ADV Part 2 (or a brochure such as this). Unaffiliated Third Party Money Managers. This involves entering into an IMA with W&N and a separate agreement with a third-party manager. Financial Advisors advise you in establishing investment objectives for the account, the selection of the third-party manager, and defining any restrictions on the account. Financial Advisors continue to provide management oversight of your account and ongoing monitoring of the activities of the third-party manager. Sub Advisors use a variety of assets in client portfolios, including equities, bonds, ETFs and/or mutual funds, options or other

derivatives. In some cases, the selection of these investments creates a conflict of interest for the thirdparty manager. These third-party managers disclose conflicts of interests, including their selection of such investments, in their Form ADV Part 2. You are provided with the third-party manager's Form ADV Part 2 (or a brochure such as this one) Proprietary Model Portfolios. As part of our portfolio management services, in addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm. AssetMark, Inc. ("AssetMark"), an SEC-registered investment adviser, used with some clients as a third-party asset management platform ("TAMP"). AssetMark provides model portfolios, portfolio management services, trading, rebalancing, and administrative support. The Firm is responsible for recommending AssetMark, selecting appropriate investment strategies or model portfolios, and monitoring client accounts on an ongoing basis. Depending on the engagement, AssetMark may exercise discretionary authority over client accounts pursuant to the client agreement with AssetMark. Clients utilizing AssetMark will incur fees charged by AssetMark in addition to the Firm's advisory fee, Oversight and Due Diligence of Third-Party Managers. When W&N recommends a third-party investment manager or investment program available through platforms such as Altruist and AssetMark, we conduct due diligence designed to evaluate the manager's investment process, experience, historical performance, regulatory background, and operational capabilities. We also perform ongoing monitoring of recommended managers and programs. This monitoring may include periodic reviews of performance, risk characteristics, portfolio holdings, organizational developments, and regulatory filings. Although W&N conducts due diligence and monitoring, it does not control the day-to-day investment decisions made by third-party managers. The success of these investment strategies depends in part on the manager's ability to implement its investment approach effectively. Direct Indexing Services. Altruist Direct Indexing. W&N also offers direct indexing strategies through the Altruist platform for eligible clients. Direct indexing allows clients to hold a portfolio of individual securities designed to replicate the performance of a target index, while enabling tax-loss harvesting at the individual security level. Unlike index mutual funds or ETFs, direct indexing provides clients with direct ownership of the underlying securities, which may allow for greater customization and tax efficiency. Direct indexing strategies are implemented and managed by W&N on a discretionary basis through Altruist's infrastructure. To accommodate clients at lower account minimums, Altruist utilizes fractional share ownership, which allows the purchase of partial shares of individual securities to approximate index weights within smaller account sizes. While fractional shares enable broader participation in direct indexing strategies, clients should be aware that not all available indexes may be accessible at lower account balances. The range of index strategies available to a client may expand as account value increases, and we will work with each client to identify the most appropriate strategy given their account size and investment objectives. Direct indexing is generally available to clients with a minimum account value of $2,000. Clients may impose reasonable restrictions on specific securities or sectors within a direct indexing strategy, which we will seek to accommodate subject to the operational capabilities of the Altruist platform. Tax-loss harvesting activity within direct indexing accounts is conducted at W&N's discretion and is not guaranteed to reduce a client's overall tax liability. Clients should consult their tax advisor regarding the tax implications of direct indexing strategies.

Vanguard Direct Indexing. In addition to direct indexing strategies available through the Altruist platform, W&N offers a direct indexing program powered by Vanguard's direct indexing technology and index methodology. W&N serves as the sole investment adviser for these accounts and retains full discretionary authority over all investment decisions. Vanguard provides the technology infrastructure and index construction methodology underlying the program but does not serve in an advisory capacity to us or our clients. This program allows clients to hold a portfolio of individual securities designed to replicate a target index, with the potential for tax-loss harvesting at the individual security level. Accounts are held in custody at our preferred custodians through W&N's existing custodial relationship. The program is available to clients with a minimum account value of $250,000, which reflects the capital required to construct a sufficiently diversified individual security portfolio consistent with the target index methodology. W&N charges its standard advisory fee on these accounts. The technology costs associated with the Vanguard platform are borne by W&N as a firm expense and are not passed through to clients. We will evaluate the appropriateness of this program for each client based on account size, investment objectives, risk tolerance, and tax situation. Clients may impose reasonable restrictions on specific securities or sectors, which we will seek to accommodate subject to the operational capabilities of the platform. Altruist One Program. W&N may enroll eligible client accounts in the Altruist One Program ("Altruist One"), a bundled subscription offering provided by Altruist Corp, the parent company of Altruist Financial LLC and Altruist LLC. Clients enrolled in Altruist One may receive certain benefits, which may include higher interest rates on cash balances, waived or discounted transaction fees for certain securities, and waived or discounted fees for tax management tools and model portfolio access. Only clients enrolled in Altruist One have access to these benefits. Altruist One may not be suitable for all clients. W&N will evaluate the appropriateness of Altruist One enrollment on a client-by-client basis. Third-Party Investment Management Platforms. Williams & Novak Wealth Management, LLC may recommend that clients participate in investment management programs offered through third-party investment platforms, commonly referred to as Turnkey Asset Management Platforms ("TAMPs"). Through our relationship with Altruist Financial LLC , we offer clients access to model portfolio strategies sourced through Altruist's model marketplace. W&N participates in the Model Marketplace and uses tax management tools of Altruist LLC, an SECregistered investment adviser and affiliate of Altruist Financial LLC. Through the Model Marketplace. We have access to model portfolios including Altruist LLC-generated portfolios and ThirdParty Portfolios, to assist it in managing or advising W&N client accounts. We also have the ability to create custom model portfolios, and have access to tax management tools for use with Altruist LLCgenerated portfolios, Third-Party Portfolios, and custom model portfolios, to assist us in managing or advising our client accounts. Altruist LLCʼs Model Marketplace fees and tax management tool fees – each of which range between 0.00% and 1.00% and are listed in the Altruist LLC Fee Schedule available at altruist.com/legal – are automatically deducted from W&N's house account or passed through to and debited from clientsʼ accounts, according to the instruction of W&N. Altruist LLC and its affiliates do not act as investment advisers or fiduciary to our clients. We are responsible for suitability of all investment decisions and transactions for client accounts subscribed to model portfolios through the Model Marketplace. Another such platform is AssetMark, Inc. ("AssetMark"), an SEC-registered investment adviser, as a third- party asset management platform ("TAMP"). AssetMark provides model portfolios, portfolio management services, trading, rebalancing, and administrative support. The Firm is responsible for recommending AssetMark, selecting appropriate investment strategies or model portfolios, and monitoring client accounts on an ongoing basis. Depending on the engagement, AssetMark may exercise discretionary authority over client accounts pursuant to the client agreement with AssetMark. Clients should be aware that the Firm and AssetMark each provide services and each charge separate

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W&N Investment Management and Advisory Account Fees. Investment Advisory Fees ("Fees") are paid monthly, in arrears, pursuant to the terms of the IMA or IAA, unless otherwise agreed to in writing by you and W&N. Fees are generally determined by the Financial Advisors and are based upon the market value of all the assets subject to an IMA or IAA ("Assets"). Unless stated in writing elsewhere, W&N's billing is in arrears, and the Fee is based on the average daily balance of the Assets held for the period in which the fee is charged. Account fees are negotiated with you depending on the type and complexity of the investment management strategy employed as well as the size of your account(s). Generally, larger accounts, or accounts with less complexity may be offered a lower Fee relative to fees generally assessed by a Financial Advisor. Certain accounts may have a higher Fee based on complex situations, including, but not limited to, accounts with multiple investment objectives, multiple underlying registrations, or aggressive growth strategies and/or accounts which require active trading to achieve your objectives. Fees may be negotiable at the discretion of Financial Advisors. Fees vary among Financial Advisors. Some Financial Advisors establish minimum Fees. Please refer to your IMA or IAA and Fee Schedule for details about your Fees. Because the Firm charges asset-based fees, the Firm has an incentive to encourage clients to increase the amount of assets under management, including recommending the rollover of retirement assets or consolidation of accounts. Clients with margin accounts are subject to Fees on the additional amount of assets resulting from the use of margin, if any. For example, an account with a value of $100,000 before margin that later uses margin of $20,000, would be subject to a Fee on $120,000. The use of margin creates a conflict of

interest since we receive a Fee on the entire balance. In addition, unless specifically excluded from Fees by you or your Advisor Representative, all Assets are included in the Fee charged, including cash and cash equivalents. All securities held in accounts managed by W&N and Financial Advisors are independently valued by the custodian or other third-party pricing services. We do not have the authority or responsibility to value portfolio securities. W&N relies upon third-party sources for account data to determine the calculation of fees to be charged. While we review and periodically samples the data to ensure it is accurate, there may be cases where the account data does not match the source of the data. In these cases, the Fees charged may be different than expected. If W&N discovers, is made aware of, or is advised by clients of differences, then any bills generated and Fees collected will be updated, if necessary. Fees are deducted from your account(s) by the custodian as requested by our firm. You provide written authorization permitting W&N to bill your accounts directly from the custodian when you execute an IMA or IAA and separate account forms required by the custodian. If billed quarterly, the Fee due is calculated by applying the quarterly rate (annual rate divided by 4) to the total market value of your Assets as of the end of preceding quarter. If billing is in arrears, the Fee will be based on the average daily balance of your Assets held during the billing period. Fees can be primarily structured in one of the following ways: 1. Blended Management Fee: Total Fee is calculated based upon sum of Asset value multiplied by the fee percentage in all asset ranges; 2. Breakpoint Management Fee: Total Fee is calculated based upon total Asset value multiplied by the fee percentage of highest total asset value range applicable for Assets in the account(s); or 3. Flat Management Fee: Total Fee is calculated based upon sum of Asset value multiplied by the fee percentage. If your Assets are billed in advance, Fees in the initial quarter of service are prorated to include the number of days in the previous quarter your account(s) was managed. Additional contributions to accounts may be charged a prorated fee pursuant to your IMA. If your Assets are billed in arrears, the Fee is based on the average daily balance of the Assets held during the billing period. You may request a Fee Statement showing the Fees charged by account and the annual Fee used to calculate your Fees. You should also receive, at least quarterly, a statement from the custodian reflecting the deduction of the Fees (please note: usually this is coded as a "management fee" by the custodian). It is your responsibility to verify the accuracy of any fees listed on the custodian's brokerage statement as neither the custodian nor WNWM assume this responsibility. You should immediately notify your Financial Advisor or WNWM if you are not receiving statements from custodians, or if you have questions about Fees. Clients utilizing AssetMark and / or Altruist programs may incur fees charged by AssetMark / Altruist in addition to the Firm's advisory fee. These fees are separate from and in addition to the Firm's advisory fee and will increase the total cost paid by the client. AssetMark / Altruist fees typically include portfolio management, trading, custody support, and administrative services, and are generally calculated as a percentage of assets under management. These fees are often deducted directly from client accounts. The Firm has a financial incentive to recommend AssetMark / Altruist because it provides operational efficiencies and support services that benefit the Firm. Because the Firm charges asset-based fees, the Firm has an incentive to encourage clients to increase the amount of assets under management, including recommending the rollover of retirement assets or consolidation of accounts.

Certain associated persons of the Firm are affiliated with a tax preparation and consulting business and/or licensed insurance agencies. If a client elects to engage these services, the associated person may receive separate compensation, including fees or commissions. This creates a conflict of interest because the associated person has a financial incentive to recommend these services. Clients are not required to engage any affiliated firm or purchase any recommended insurance products. Termination of Investment Management or Advisory Agreement You may request to terminate your IMA or IAA with W&N, in whole or in part, by providing advance written notice. You are responsible for Fees up to and including the effective date of termination. W&N mostly bills in arrears, wherein the Fee will be calculated up to the termination date and charged to the account based on the average daily balance of the Assets held as of the end of the final billing period. Your IMA is nontransferable and cannot be assigned to another registered investment advisor without your consent. W&N Financial Planning, Retainer Financial Planning and Consulting Services Fees. W&N offers financial planning on a fixed rate or hourly basis. The hourly rate generally ranges from $150 to $500 per hour and fixed fees may range from $1,000 to $20,000 per project, depending on the nature and complexity of the specific services involved in each certain engagement. Fixed fee engagements are based on the estimated hours to complete the deliverable for the engagement. You may also be charged for any out-of-pocket expenses, such as, postage, copying, etc. involved with the engagement. Fixed fees are due upon receipt, unless you and your Financial Advisor specifically agree otherwise. If you are billed on a quarterly basis and/or upon completion of work performed, you may be required to provide an advance payment of up to 50% of the expected cost of the financial plan. These fees may be negotiated by the Financial Advisor at his or her sole discretion. In addition, some of our advisors include financial planning services without charging a separate fee. Financial Advisors cannot charge pre-planning fees of $1,200 more than 6 months in advance. Consequently, services to the Client must be performed on an ongoing basis once the initial fee is received. For example, Financial Advisors may charge Clients a Retainer where the annual fee is $5,000 to be paid monthly or quarterly (e.g., $416.66 per month or $1,250 per quarter). The Retainer Agreement renews automatically every year unless terminated in writing by the Client or the Financial Advisor or if payment is not received by the Client as agreed upon. A Retainer Agreement includes financial planning, consulting and related services, and in certain cases discretionary or non-discretionary investment management is included. Retainer fees are generally billed monthly or quarterly in advance, unless you and your Financial Advisor specifically agree otherwise. Retainer fee arrangements generally range from $1,000 to $20,000 per year, depending upon several factors including, but not limited to the scope of work in the Agreement, the type or amount of Client assets and/or net worth, and on the nature and complexity of the specific services involved in each engagement. Whether you implement any investment recommendations resulting from the financial planning services provided by your Financial Advisor is entirely your decision. If you implement recommendations, you may do so through the financial professional of your choice. If you implement recommendations through your Financial Advisor, W&N and your Financial Advisor may receive compensation for the services provided in conjunction with that implementation. Certain Financial Advisors are also licensed to sell insurance products and are compensated with commission's for recommending insurance solutions to you as part of your financial plan. See your Financial Advisor's ADV 2B for information about additional compensation. You may terminate a planning or fixed retainer fee agreement at any time by providing written notice to Dynamic. In the event you wish to cancel the agreement under which any plan or service is being provided, any unearned fees will be returned to you.

Educational Workshops and Newsletters Fees for workshops and / or newsletters are paid by the W&N investment advisor representative. At times, W&N investment adviser representatives receive an expense reimbursement for educational workshops and newsletter marketing expenses from distributors of investment and/or insurance products. Marketing expense reimbursements are the result of informal expense sharing arrangements in which product sponsors underwrite costs incurred for marketing such as client appreciation events, advertising, publishing, and seminar expenses. Although receipt of these marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are made by those sponsors for which sales have been made or for which it is anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of clients. W&N attempts to control for this conflict by always basing investment decisions on the individual needs of clients. Fees for Sub-advisors. The fees for sub-advisors used by W&N to sub-advise Client portfolios are usually paid from Investment Advisory Fees. W&N charges as outlined above. In certain instances, you may pay higher Investment Advisory Fees to W&N if a sub-advisor is used. Total Investment Advisory Fees shall not exceed 2.25% per year, including the sub-advisor. Vanguard-Powered Direct Indexing Fees. Clients who participate in W&N's Vanguard-powered direct indexing program are subject to W&N's standard advisory fee as described above. Usually, no additional fee is charged to clients for access to this program. The technology costs associated with the Vanguard platform are borne entirely by W&N as a firm expense and are not separately charged to or passed through to clients. Altruist Platform Fees. Clients utilizing the Altruist platform will incur fees charged by Altruist and its affiliates, including fees associated with brokerage, custody, model portfolios, and tax management tools. The Firm does not retain any portion of these fees. All Altruist-related fees are passed through to and borne by the client. These fees are separate from and in addition to the Firm's advisory fee and will increase the total cost paid by the client. The Firm has a financial incentive to recommend the use of the Altruist platform because it provides operational efficiencies, integrated technology, and administrative support that benefit the Firm. This creates a conflict of interest even though the Firm does not receive direct compensation from Altruistrelated fees. Depending on the service utilized, these fees are typically deducted directly from client accounts. Model Marketplace and Tax Management Tools. The Firm may utilize model portfolios and tax management tools made available through Altruist LLC, an affiliated investment adviser of Altruist Financial LLC. These tools may include model portfolios created by Altruist or third-party managers, as well as automated tax optimization features. Fees associated with these services are charged by Altruist and are passed through to clients. The Firm does not retain these fees. The Firm is responsible for selecting appropriate investment strategies and ensuring that recommendations are suitable and in the best interest of clients. Altruist One Program Fees. The Altruist One Program is subject to a monthly subscription fee as detailed in the Altruist One Terms of Use available at altruist.com/legal. This fee may be absorbed by W&N as a firm expense or passed through to and charged to enrolled client accounts, at W&N's discretion. W&N will disclose to each client whether the Altruist One subscription fee will be charged to their account prior to enrollment.

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Our Methods of Analysis and Investment Strategies We use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Charting Analysis - involves the gathering and processing of price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data is used to detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Technical Analysis - involves studying past price patterns, trends and interrelationships in the financial markets to assess risk-adjusted performance and predict the direction of both the overall market and specific securities. Risk: The risk of market timing based on technical analysis is that our analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Cyclical Analysis - a type of technical analysis that involves evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and may have many fluctuations between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Modern Portfolio Theory - a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk that is common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification.

Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long-term which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities' shortterm price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short-term which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. There are many factors that can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of times. Margin Transactions - a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. Risk: If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a "margin call." An investor's overall risk includes the amount of money invested plus the amount that was loaned to them. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the expiration date of the option. When an investor sells a call option, he or she must deliver to the buyer a specified number of shares if the buyer exercises the option. When an investor sells a put option, he or she must pay the strike price per share if the buyer exercises the option, and will receive the specified number of shares. The option writer/seller receives a premium (the market price of the option at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. ESG Criteria ESG screening has risks including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we may review investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. We may perform quantitative or qualitative analysis of individual securities. Additionally, we may advise you on how to allocate your assets among various classes of securities or third party money managers. We may rely on investment model portfolios and strategies developed by the third party

money managers and their portfolio managers. We may replace/recommend replacing a third party money manager if there is a significant deviation in characteristics or performance from the stated strategy and/or benchmark. Cash Management In managing the cash maintained in your account, we utilize the cash vehicle market) made available by the custodian(s). There may be other cash management options away from the custodian available to you with higher yields or safer underlying investments. We manage cash balances in your account based on the yield, and the financial soundness of the money markets and other short term instruments. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Other Risk Considerations When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of any potential losses. The following risks may not be all-inclusive, but should be considered carefully by a prospective client before retaining our services. Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price or it may not be possible to sell the investment at all. Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many types of fixed income investments to decline. Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time that the markets are down, you may lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired, or are nearing retirement. Recommendation of Particular Types of Securities - Tanya to adjust Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment.

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We offer investment advisory services to individuals, high net worth individuals, corporations, pension and profit sharing plans and charitable organizations. In general, we do not require a minimum dollar amount to open and maintain an advisory account; however, we have the right to terminate your Account if it falls below a minimum size which, in our sole opinion, is too small to manage effectively. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum.

We do not accept performance-based fees or participate in side-by-side management. Performancebased fees are fees that are based on a share of a capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performancebased fees. Our fees are calculated as described in the Fees and Compensation section above, and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account.

Registrations with Broker-Dealer Certain Financial Advisors of the Firm are registered representatives of a broker-dealer not affiliated with the Firm. In this separate capacity, these individuals may effect securities transactions and receive transaction-based compensation, including commissions and other incentives. This creates a conflict of interest because these individuals have a financial incentive to recommend securities transactions or products that generate commissions. When acting in their capacity as registered representatives of a broker-dealer, these individuals are not acting as investment adviser representatives of the Firm and are not subject to the Firm's fiduciary duty.

Clients should be aware that they may have the option to receive services through either an advisory account or a brokerage account, and the costs and compensation associated with each may differ. Commissions may be higher or lower than those charged by other broker-dealers Commissions are earned by hybrid advisors. This creates a conflict of interest because these individuals have an incentive to recommend securities transactions that generate commissions. When acting in this capacity, they are not acting as investment adviser representatives of the Firm. Clients are under no obligation to purchase or sell securities through their W&N hybrid financial advisor. Clients may execute securities transactions independent of their W&N hybrid financial advisor. However, if they do choose to purchase, sell securities, or implement securities recommendations made through a financial plan by their W&N hybrid financial advisor, commissions will be earned by their W&N hybrid financial advisor. Daniel Novak is registered as a registered representative of an Alexander Capital, an unaffiliated Broker Dealer. Michael De Luz is a registered representative with Vistia Capital, LLC, an unaffiliated Broker Dealer. In this separate capacity, Mr. De Luz participates in capital formation and the offering and sale of private placement securities. Insurance Certain Financial Advisors are engaged in other professions in addition to providing financial planning and may or may not be affiliated with W&N for which they receive additional compensation. They may be licensed to sell insurance products through various insurance companies that are unaffiliated with W&N or through affiliated firm, Williams and Novak Insurance, LLC. As a W&N client, these products are offered separate and apart from your Financial Advisor's relationship with W&N. You are under no obligation to utilize the services of your Financial Advisor in the purchase or sales of other products including securities, insurance, annuities, commodities, or futures products. Any such transactions you effect through a Financial Advisor will result in the receipt of commissions and other compensation in addition to any Investment Advisory Fees as discussed above. The commissions and other compensation from the sale of other products do not offset the regular advisory fees charged to client accounts managed by W&N. It is the client's ultimate responsibility to determine whether other products being offered to them are appropriate investment products. This creates a conflict of interest because the receipt of commissions provides an incentive to recommend insurance products. Insurance products may be paid for by withdrawals from client accounts managed by W&N, assuming properly completed custodian forms are on file indicating client consent. Certain Financial Advisors may serve, in a separate capacity, as insurance agents. When acting, in a separate capacity, as an insurance agent, your investment adviser representative will sell, for commissions, life insurance, annuities, and other insurance products to you. Investment adviser representatives are also eligible to receive incentives and other compensation based on and related to insurance transactions. These incentives include, but are not limited to: gifts, meals, entertainment, participation in bonus programs, reimbursement for training, marketing assistance, educational efforts, advertising, and travel expenses to conferences and events. Consequently, your investment adviser representative is incentivized to recommend that you purchase insurance products due to the receipt of commissions and other compensation. We address this conflict of interest by: (1) disclosing it to you in this brochure and (2) ensuring no advisory fee is charged on insurance products, which are held outside of the advisory relationship, in addition to the commission the representative earns from the sale the same insurance.

As a W&N client, these products are offered separate and apart from your Financial Advisor's relationship with W&N. You are under no obligation to utilize the services of your Financial Advisor in the purchase or sales of other products including securities, insurance, annuities, commodities, or futures products. Any such transactions you effect through a Financial Advisor will result in the receipt of commissions and other compensation in addition to any Investment Advisory Fees as discussed above. The commissions and other compensation from the sale of other products do not offset the regular advisory fees charged to client accounts managed by W&N. It is the client's ultimate responsibility to determine whether other products being offered to them are appropriate investment products. H4 Capital Partners, LLC Certain of our supervised persons, including Jacob Williams and Daniel Novak, hold passive ownership interests in a privately held company, H4 Capital Partners, LLC, a Florida limited liability company. H4 Capital Partners is a Private Equity business that partners and provides advice to Property & Casualty Agency owners. Mr. Williams owns approximately 16.2%, and Mr. Novak owns approximately 10.8% of H4 Capital Partners. Both interests are non-managing, investor-only roles, meaning they do not participate in management or decision-making of the entity and have no authority to bind or act on behalf of the company. These outside business interests are maintained on a passive basis only and are not related to the investment advisory services we provide to clients. At present, our advisory clients are not solicited to invest in, nor are they recommended, H4 Capital Partners. If this were to change, we would provide updated disclosure regarding the nature of the conflict and how it Williams & Novak Tax Partners, LLC Williams & Novak Tax Partners, LLC is affiliated with W&N, and in such capacity may offer services for a fee or complimentary to investment advisory clients of W&N. Williams & Novak Tax Partners, LLC offerings are recommended to clients of W&N on an individual basis and based upon a good faith judgment of a client's specific needs. Services provided by this affiliated firm, may be paid for by withdrawals from client accounts managed by W&N, assuming properly completed custodian forms are on file indicating client consent. The recommendation could result in conflicts of interest for W&N as an affiliate. W&N will directly benefit from a client utilizing an affiliate's services based upon its recommendation because it may generate revenue for the affiliated subsidiary and W&N. This creates a conflict of interest because there is a financial incentive to recommend these services. Clients are not required to use the affiliated tax firm and may choose any tax professional. Clients are under no obligation to utilize the tax services provided by the Advisor or its Supervised Persons. Williams & Novak Insurance, LLC Williams & Novak Insurance, LLC ("the Insurance Agency") is affiliated with W&N and in such capacity may offer services for a commission to investment advisory clients of W&N . The insurance agency is under common control and ownership with W&N . Williams & Novak Insurance, LLC offerings may be recommended to clients of W&N on an individual basis and based upon a good faith judgment of a client's specific needs. If a client elects to purchase an insurance product through the Insurance Agency, the Insurance Agency and/or its licensed representatives may receive commissions or other compensation from the carrier. Services provided by this affiliated firm, may be paid for by withdrawals from client accounts managed by W&N, assuming properly completed custodian forms are on file indicating client consent. The recommendation could result in conflicts of interest for W&N as an affiliate. W&N will directly benefit from a client utilizing an affiliate's services based upon its recommendation because it may generate revenue for the affiliated

subsidiary and W&N . These activities are conducted outside of the Firm's advisory services. Clients are under no obligation to utilize the Insurance Agency services and are free to obtain such products through unaffiliated insurance providers. The firm addresses this conflict by maintaining policies and procedures designed to ensure that any insurance recommendations are made in the best interest of the client and are consistent with the Firm's fiduciary duty. Affiliations with Third-Party Investment Managers Our firm may have business relationships with third-party investment managers, including separate account managers, private fund sponsors, or alternative investment platforms. These relationships may involve due diligence arrangements, operational support agreements, or other affiliations that do not impact our fiduciary obligation to clients. If any compensation, referral arrangements, or revenuesharing agreements exist with third-party managers, we will disclose such arrangements to clients before they make an investment decision. Other Business Relationships We use third-party resources to help run our business and provide services to our clients. We have developed a network of professionals, accountants, lawyers, and otherwise, for which our firm and associates may receive compensation for such use or referrals.

Personal Trading Description of Our Code of Ethics Code of Ethics W&N has implemented a Code of Ethics to define our fiduciary commitment to you. This Code of Ethics applies to all persons associated with W&N. The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. W&N and its personnel owe a duty of loyalty, fairness, and good faith to you. It is the obligation of W&N associates to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code of Ethics. The Code of Ethics covers a range of topics that may include; general ethical principles, reporting personal securities trading, exceptions to reporting securities trading, reportable securities, initial public offerings, and private placements, reporting ethical violations, distribution of the Code of Ethics, review and enforcement processes, amendments to Form ADV, managing conflicts of interest, and supervisory procedures. W&N has established its Code of Ethics to meet and exceed regulatory standards. We will provide a copy of our Code of Ethics to any client or prospective client upon request. Personal Trading and Conflicts of Interest W&N allows employees to purchase or sell the same securities that may be recommended to and purchased on your behalf. Owning the same securities, we recommend to you present a potential conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. Affiliated Firms Because W&N is affiliated with tax preparation and insurance Firms, W&N has a financial incentive to recommend that clients use these firms for insurance and tax services.

Your assets must be maintained in an account at a "qualified custodian," generally a broker-dealer. We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, the most favorable compared to other available providers and their services. We consider various factors, including: • • • • • • •

Capability to buy and sell securities for your account itself or to facilitate such services. The likelihood that your trades will be executed. Availability of investment research and tools. Overall quality of services. Competitiveness of price. Reputation, financial strength, and stability. Existing relationship with our firm and our other clients.

Research and Other Soft Dollar Benefits We have soft dollar arrangements with SmartX. Economic Benefits As a registered investment adviser, we have access to the institutional platform of your account custodians. As such, we will also have access to research products and services from your account custodian and/or other brokerage firm. These products may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decisionmaking responsibilities. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms, and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Directed Brokerage You are serviced on a "directed brokerage basis", where W&N will place trades within the established account at the custodian designated by you. Further, your accounts are traded within their respective brokerage accounts. Because you are selecting the custodian for your accounts, W&N will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by your designated custodian. Please note that not all advisers require their clients to direct brokerage. Aggregated Trades We may combine multiple orders for shares of the same securities purchased for discretionary advisory accounts we manage (this practice is commonly referred to as "aggregated or block trading"). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. Generally, participating accounts will pay a fixed transaction cost regardless of the number of shares transacted. In certain cases, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs on any given day. In the event an order is only partially filled, the shares will be allocated to participating accounts in a fair and equitable

manner, typically in proportion to the size of each client's order. Accounts owned by our firm or persons associated with our firm may participate in aggregated trading with your accounts; however, they will not be given preferential treatment. We do not aggregate trades for non-discretionary accounts. Accordingly, non-discretionary accounts may pay different costs than discretionary accounts pay. If you enter into non-discretionary arrangements with our firm, we may not be able to buy and sell the same quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs than clients who enter into discretionary arrangements with our firm. Trade Errors From time-to-time W&N may make an error in submitting a trade order on your behalf. An overriding principle in dealing with a trading error made by W&N or a Financial Advisor (or any other party to the trade other than the client) is that the client will not pay for losses resulting from such errors. In general, when the error and responsible party are identified, the trade is broken if possible, the error is corrected the same day.

Referrals W&N may have Agreements with certain unaffiliated investment advisors, other outside RIA Firms, custodians, and other professionals to compensate them for referring Clients to W&N. As disclosed in an Agreement between such Parties and W&N, W&N pays a portion of the Investment Advisory Fee to the Party who refers a Client to W&N . Any such referral fee is paid solely from W&N 's Investment Advisory Fee and does not result in any additional charge to the Client. W&N is required to disclose this arrangement with the referred Client. This disclosure contains the terms and conditions of the arrangement. Referral arrangements comply with the Marketing Rule and that written agreements and required disclosures are provided. W&N may refer advisory clients to its affiliated tax preparation firm for tax-related services or it's affiliated insurance firm. This creates a conflict of interest because W&N has an incentive to recommend services and products provided by these affiliated entities. There are no referral fees. The Firm may refer clients to affiliated or unaffiliated service providers, including tax professionals or insurance providers. In certain cases, associated persons of the Firm may receive compensation from these referrals. This creates a conflict of interest because the Firm or its associated persons have a financial incentive to make such referrals. Clients are not obligated to engage any referred service provider Other Compensation W&N Financial Advisors, in certain cases, receive benefits and other support from product sponsors and custodians used and recommended by Financial Advisors. In certain cases, these companies provide for technology, training, education, industry meetings, due diligence, client events and marketing. The benefits are generally paid in the form of reimbursement or direct payment of expenses. The receipt of such benefits is a conflict of interest as W&N and/or Financial Advisors may recommend products or custodians based upon these arrangements. W&N and Financial Advisors are obligated to act in the client's best interest at all times. The Firm and its associated persons may refer clients to affiliated or unaffiliated service providers, including tax professionals and insurance providers. In certain cases, associated persons of the Firm may receive compensation or economic benefits from these referrals.

We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our advisory business or the integrity of our management. Our firm or a management person has been involved in the event(s) described below. Neither our firm nor any of our Associated Persons have had any reportable disciplinary information A federal or state regulatory agency took certain disciplinary actions against for alleged violations of certain securities regulations, rules, and/or statutory provisions. The matters have been resolved. has no outstanding issues and is registered without restriction as an investment adviser representative on behalf of Williams & Novak Wealth Management, LLC. The details on these matters related to 's disciplinary history can be found on the IAPD. The IAPD link is www.adviserinfo.sec.gov.

During periodic reviews, W&N seeks to analyze a variety of factors, including risk tolerance, suitability and fiduciary standards. W&N requires that the Financial Advisors have a reasonable basis to believe that recommended investment strategies are in the best interest of its clients based on information obtained from clients through reasonable diligence. In addition, account reviews will take into consideration the current economic environment, the outlook for the securities markets, and the merits of the securities in which the accounts are invested. Clients are strongly encouraged to immediately notify their Financial Advisor of the following: (a) a change in the client's investment objectives, guidelines and/or financial situation; (b) change in strategy or diversification; (c) change in tax considerations; (d) plans to add or withdrawn from the account; and (e) any other changes or concerns their Financial Advisor may need to know to properly manage their accounts. For discretionary accounts, the allocation of each portfolio is adjusted, and securities selected, at the Financial Advisor's discretion, in accordance with the client's investment objectives, risk tolerance, and financial needs. Accounts are reviewed by Financial Advisors on a periodic basis. Reports You will receive brokerage statements no less than quarterly from the trustee or custodian of your account. These brokerage statements are sent directly from the custodian to you either electronically or by physical mail, at your election. You may also establish electronic access to the custodian's website so that you may view these reports and your account activity. Your brokerage statements will include all positions, transactions and fees relating to your account. W&N may also provides you with periodic reports regarding your holdings, allocations, and performance via an on-line portal which you may access with a unique user ID and password. You may request that your Financial Advisor provide physical copies of these W&N reports to you. You are encouraged to compare any reports from W&N or your Financial Advisor with statements from custodians. Third Party Managers W&N may review third party money manager reports provided to the client in order to review client's investment and financial profile. W&N will assist client to understand and evaluate services provided by the third-party manager. The client is expected to notify W&N of any changes in his/her financial

situation, investment objectives, or account restrictions that could affect their account. Upon client request, W&N will contact directly the third-party money manager managing to account to facilitate any request from the client.

W&N does not accept or maintain custody of your accounts. You must place your assets with a qualified third-party custodian. You select your custodian in consultation with your Financial Advisor and direct W&N to utilize that custodian for your securities transactions. You authorize the deduction of fees from your accounts. You will receive statements from your custodian at least quarterly. We urge you to review these statements and ensure the transactions are consistent with your objectives. For more information about custodians and brokerage practices, see "Brokerage Practices" herein above.

W&N and any other authorized third-party asset manager generally has discretion over the selection and amount of securities to be bought or sold in your accounts without obtaining prior consent or approval from you. However, these purchases or sales are subject to specified investment objectives, guidelines, or limitations previously set forth by you and agreed to by W&N. Discretionary authority will only be authorized upon full disclosure to you. The granting of such authority will be evidenced by your execution of an Investment Management Agreement containing all applicable limitations to such authority and necessary custodian agreements and required custodian forms. All discretionary trades made by W&N are designed to be in accordance with your investment objectives and goals. W&N is authorized to make the following determinations in accordance with client objectives and restrictions without obtaining prior consent from the client: (1) which securities or instruments to buy or sell; (2) the total amount of securities or instruments to buy or sell; (3) W&N has time and price discretion over security execution; (4) whether to hire or fire a third-party manager.

We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder.

Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. We do not take physical custody of client funds or securities, or serve as trustee or signatory for client accounts, and, we do not require the prepayment of more than $1,200 in fees six or more months in advance. Therefore, we are not required to include a financial statement with this brochure. We have not filed a bankruptcy petition at any time in the past ten years.