Williams & Novak Wealth Management, LLC: investment adviser

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

fees. AssetMark provides services that may include: access to third-party investment managers and model portfolios • portfolio construction and manager selection • trade execution and rebalancing • performance reporting • operational and administrative support. When clients participate in an AssetMark program, the selected investment manager or model portfolio provider may have discretionary authority to manage the account in accordance with the program's investment mandate. Our role typically includes: • evaluating the appropriateness of the AssetMark program for the client • assisting the client in selecting an investment strategy or manager available on the platform • providing ongoing advice and monitoring of the client's account. W&N assists clients in selecting among available investment managers or model portfolios offered through the AssetMark platform based on the client's investment objectives and circumstances. We do not control the day-to-day investment decisions made by third-party managers available through AssetMark. Clients should review all disclosure documents provided by AssetMark, including its Form ADV brochure and program documentation, for additional details regarding services, fees, and conflicts of interest. Third-party Administrative Support. Certain aspects of our investment and platform operations are performed by Dynamic Advisor Solutions, LLC. The administration of, and access to, Dynamic's wealth management platform as well as advisor and client portal are utilized by our firm for a fee charged to our firm. Dynamic provides assistance in trading and rebalancing our designed models and investment models designed by Dynamic. Investment models are selected by our firm based upon client circumstances. Dynamic generates our fee calculations and performs fee debiting and other administration based upon our specifications. Outside Accounts. Some of our Financial Advisors also manage and recommend allocations as well as provide consolidated reporting for Outside Accounts such as sub accounts of variable annuities, fixed annuities, 529 Plans, 401ks, REITs and other similar accounts. Generally, these accounts are not held by a custodian that is holding other accounts managed by W&N and Financial Advisors. We regularly review the current holdings and available investment options in these accounts, monitor the accounts, rebalance and implement our strategies as necessary. In some cases, we use an Order Management System to implement asset allocation or rebalancing strategies on behalf of the client. In other cases, we do not have the ability to execute the recommended asset allocation or strategies and therefore you are responsible for implementing any such recommendations. Outside Accounts may be included in the accounts on the IMA and subject to an Investment Advisory Fee, if applicable (See "Fees and Compensation" section herein below and your IMA). Employee Retirement Income Security Act ("ERISA"). W&N may authorize certain of its Financial Advisors to provide fiduciary or non-fiduciary services to ERISA plans. ERISA plan documents typically designate one of more persons, such as the plan trustee, to undertake fiduciary responsibility for the operation of, and take actions on behalf of, the plan. Such persons are known as Responsible Plan Fiduciaries ("RPFs"). Financial Advisors may provide the following services to ERISA plans: • Assessment and Selection of Investments • Investment Policy Statement Development • Non-ERISA Fiduciary Services • Investment Policy Statement Review • Performance Monitoring • Employee Enrollment and/or assistance • Employee Education • Vendor Review and Conversion. When we provide investment advice to you regarding your retirement plan or individual retirement plan account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. The Firm and its associated persons operate in multiple capacities, including as investment adviser representatives, insurance agents, and affiliated tax professionals. As a result, conflicts of interest exist whenever compensation is received from multiple sources. The Firm seeks to mitigate these conflicts through disclosure, adherence to fiduciary standards, and policies designed to ensure recommendations are

made in the best interest of clients. Your Adviser may provide additional or other services to you which are not described in this Brochure. You should read and review your Adviser's ADV Part 2A Brochure for information regarding services provided by your Adviser. FINANCIAL PLANNING, RETAINER FINANCIAL PLANNING and CONSULTING SERVICES Financial Advisors provide a variety of financial planning and consulting services to individuals, families, and businesses, depending upon their circumstances. In certain cases, your Financial Advisor will request that you enter into a separate Financial Planning or Retainer Financial Planning Agreement with W&N for the performance of these planning services. Generally, such financial planning services involve preparing a financial plan or rendering a financial consultation for you based upon your financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, personal savings, education savings and other areas of your financial situation. A financial plan developed for you or financial consultation rendered to you usually includes general recommendations for a course of activity or specific actions to be taken by you. For example, recommendations may be made that you initiate or revise your investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. The financial planning agreement may be for a specific project, a specified period or on-going, depending upon your situation, goals, objectives and other factors. Financial Advisors may also refer you to an accountant, attorney, or another specialist, as appropriate for your unique situation. For certain financial planning engagements, Financial Advisors generally provide a written summary of your financial situation, observations, and recommendations. For retainer, consulting or ad-hoc engagements, your Financial Advisor may not provide you with a final written summary, depending on the arrangement. Your Financial Advisor will communicate the work performed and any recommendations as defined in the Agreement throughout the engagement. W&N may provide general tax planning as part of its investment advisory services; however, the Firm does not prepare tax returns. Tax preparation services are offered separately through an affiliated tax preparation firm. The Firm may provide financial planning services that include coordination with tax planning strategies. In certain cases, clients may be referred to an affiliated tax preparation firm for implementation of tax- related recommendations. Clients are under no obligation to use any affiliated service providers. You are not obligated to implement any recommendations made by your Financial Advisor and your Financial Advisor is in no way responsible for ensuring you do so. Types of Investments Stocks, Bonds, Mutual Funds and ETFs. We primarily offer advice on Direct Indexing. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment. IRA ROLLOVER RECOMMENDATIONS Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable,

which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. As of December 31, 2025, total assets under management were $342,843,363; with discretionary assets under management of $342,843,363 and non-discretionary assets under management of $0.

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.

Clients should be aware that because certain program benefits — including reduced transaction fees and enhanced cash yields — are available only to enrolled clients, non-enrolled clients may incur higher transaction costs or receive lower cash yields than enrolled clients holding similar positions on the Altruist platform. Fees for Third-party Account Managers. If you are using a third-party manager under a separate agreement, you will pay W&N's Investment Advisory Fee plus the third-party manager's fee. Both fees are deducted from your account, with W&N's Investment Advisory Fee paid as outlined above. The third-party manager's fee is usually calculated in the same manner and charged quarterly. The amount of the third-party manager's fee is disclosed in the separate agreement between you and the thirdparty manager and in the third-party manager's Form ADV 2 (or similar disclosure as this). Investment Advisory Fees plus the third-party manager's fee shall not exceed 2.25% annually. Clients who participate in programs offered through AssetMark generally pay fees that may include several components, which may be assessed as a single unified fee or as separate fees. These fees may include: • W&N's advisory fee • AssetMark platform or program fees • fees charged by third-party investment managers • custodial fees charged by the account custodian • expenses associated with underlying investment funds or securities Participation in a TAMP program may result in layered fees, meaning that clients may pay W&N's advisory fee in addition to platform fees, third-party manager fees, and expenses associated with underlying investments. As a result, the overall cost to the client may be higher than if the client purchased the investments directly without the use of the platform. Clients utilizing AssetMark will incur fees charged by AssetMark in addition to the Firm's advisory fee. AssetMark's fees generally include portfolio management, trading, custody support, and administrative services, and are typically calculated as a percentage of assets under management. These fees are separate from and in addition to the Firm's advisory fee and will increase the overall cost to the client. In some cases, these fees are deducted directly from client accounts. The Firm has a financial incentive to recommend AssetMark because the Firm benefits from offering a scalable platform and may receive operational efficiencies or support from the platform. W&N's advisory fee is typically deducted directly from the client's account pursuant to the client's advisory agreement. AssetMark program fees and other related costs are generally deducted by the platform or custodian. Clients should carefully review all program documentation provided by AssetMark to understand the total fees associated with the program. The Firm utilizes AssetMark, a third-party asset management platform ("TAMP"), to provide model portfolios, trading, and account management services. Clients incur fees charged by AssetMark in addition to the Firm's advisory fee. This creates an incentive for the Firm to recommend the platform. Clients who participate in programs offered through Altruist and who participate in the Altruist model marketplace may incur additional fees charged by Altruist LLC for model portfolio access and tax management tools. These fees range between 0.00% and 1.00% annually and are listed in the Altruist LLC Fee Schedule at altruist.com/legal. These fees are separate from W&N's advisory fee and are either deducted from W&N's house account or passed through directly to client accounts per W&N's instruction. Direct indexing strategies are offered through Altruist's platform at no additional overlay fee beyond W&N's standard advisory fee, unless otherwise disclosed in the client agreement. In the event that you decide to terminate your relationship with a third-party manager, the provisions for termination are set forth in the respective agreements between you and such certain third parties. W&N and your Financial Advisor will assist you with the termination and transition process, as appropriate.

Fees for Outside Accounts. Financial Advisors may also manage and recommend allocations, as well as provide consolidated reporting for Outside Accounts as such sub-accounts of variable annuities, fixed annuities, 529 Plans, 401ks, REITs, private equity, private debt, and other similar accounts generally not held by a custodian of other Client securities managed by W&N and Financial Advisors. If included as managed accounts in an IMA, Outside Accounts are subject to an Investment Management Fee as described above. Investment Advisory Fees for Outside Accounts may range up to 2.25% annually, depending upon several factors, including the size of accounts managed and type of assets held within the accounts. Outside Accounts Holding Non-Tradeable Assets Financial Advisors may recommend that a portion of your account be invested in illiquid securities or securities that are not regularly valued or immediately redeemable ("Non-tradeable Assets"). Nontradeable Assets may not be held by a custodian that is holding other accounts managed by W&N and Financial Advisors. Non-tradeable Assets may be included in the accounts on the IMA and subject to a Fee. Some Non-tradeable Assets do not provide regular valuation updates or accurate and current valuations. Consequently, Fees could be over or understated on Non-tradeable Assets. W&N relies upon third- party sources for account data to determine the calculation of Fees, including Fees for Nontradeable Assets. We attempt to obtain statements for Non-tradeable Assets in order to properly value these positions for Fees. Clients should immediately notify W&N or their Financial Advisor if they believe their Fees are incorrect. W&N may receive a service fee from third party vendors that act as agent for certain Clients with variable insurance products or contracts who were referred to one of these vendors by a Financial Advisor. The receipt of service fees creates a conflict of interest that incentivizes Financial Advisors to recommend that Clients transfer their insurance product or contract to one of these vendors. Although the receipt of the service fee creates a conflict of interest for WNWM, we believe many Clients can benefit from this arrangement by receiving a more comprehensive and integrated service of their Assets. We will adhere to our fiduciary duty and make a recommendation when we deem it to be in your best interest. Clearing, Trading, and Settlement Costs. The investment management fee charged by the Firm does not include commission charges, mark-up or mark-down charges resulting from securities transactions affected with or through broker-dealers on the client's behalf. The costs of clearing, settlement, and trading of W&N Investment Management Accounts are billed separately by the custodian holding your accounts (See "Brokerage Practices" section herein below). Other Fees and Expenses. You may incur certain fees or charges imposed by third parties, other than W&N, in connection with investments made on behalf of your account. You are responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer. The Investment Advisory Fee charged by W&N is separate and distinct from these custodian and execution fees. In addition, all fees paid to W&N are separate and distinct from the expenses charged by mutual funds and exchange traded funds to their shareholders, if applicable. These fees and expenses are described in each fund's prospectus. You may be able to invest in some of these products directly, without the services of W&N, but would not receive the services provided by W&N. These services are designed, among other things, to assist you in determining which products or services are most appropriate to your risk tolerance, financial condition, and objectives. Compensation for Sales of Insurance Products. Certain Financial Advisors are engaged in professions other than providing financial planning and investment advice for which they receive additional compensation. They may be licensed to sell insurance products through various insurance companies that are affiliated (as noted in Item 10, Williams & Novak Insurance, LLC) or unaffiliated with W&N. Any such transactions result in the receipt of commissions and other compensation to the Financial Advisor. In addition, insurance sales through the firm's affiliated insurance company (Williams

& Novak Insurance, LLC) may be a conflict of interest as there is affiliated ownership and revenue through Williams & Novak Insurance, LLC. The insurance product sales create a conflict of interest since there is an incentive to recommend such products based upon the commissions and other compensation paid by insurance companies to Financial Advisor rather than based upon a client's needs. W&N has policies and procedures in place to address the conflict of interest with disclosure, including the information contained herein and on Financial Advisors' Form ADV 2B. Compensation for Tax Preparation and Tax Planning Services. Tax preparation and tax planning services offered through our affiliated tax firm are separate from advisory services provided by the firm. Clients who chose to engage the affiliated tax firm will be charged separate fees for those services. As a W&N Client, you are under no obligation to utilize the services of your Financial Advisor in the purchase or sales of other products or services, including insurance, tax preparation or mortgages. Commissions and other compensation received by your Financial Advisor for these products and services do not reduce advisory fees paid to W&N. It is the client's ultimate responsibility to determine whether insurance, mortgage, and tax products/services being offered to them are appropriate investment products. Clients should understand that when utilizing third-party platforms such as AssetMark and Altruist, they will incur multiple layers of fees, including the Firm's advisory fee and separate fees charged by these third-party providers. These fees are in addition to one another and will increase the total cost paid by the client. Although the Firm does not receive any portion of fees charged by Altruist, the Firm has a financial incentive to recommend the Altruist platform because it provides operational efficiencies, integrated technology, and administrative support that benefit the Firm. This creates a conflict of interest. Certain associated persons of the Firm may receive transaction-based compensation, including commissions, in connection with securities transactions conducted in their separate capacity as registered representatives of a broker-dealer. Please see Item 10 for additional information regarding these activities and related conflicts of interest.

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.

Money Market Funds: A money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, there is no guarantee that the share price will stay at $1/share. If the share price goes down, you can lose some or all of your principal. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than you expected to earn, you may end up needing more cash. A final risk you are taking with money market funds has to do with inflation. Because money market funds are considered to be safer than other investments like stocks, long-term average returns on money market funds tends to be less than long term average returns on riskier investments. Over long periods of time, inflation can eat away at your returns. Certificates of Deposit: Certificates of deposit ("CD") are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company ("FDIC") up to a certain amount. However, because the returns are generally low, there is risk that inflation outpaces the return of the CD. Certain CDs are traded in the market place and not purchased directly from a banking institution. In addition to trading risk, when CDs are purchased at a premium, the premium is not covered by the FDIC. Municipal Securities: Municipal securities, while generally thought of as safe, can have significant risks associated with them including, but not limited to: the credit worthiness of the governmental entity that issues the bond; the stability of the revenue stream that is used to pay the interest to the bondholders; when the bond is due to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same amount of interest or yield to maturity. Bonds: Corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can be affected by many other factors including, but not limited to the class of stock (for example, preferred or common); the health of the market sector of the issuing company; and, the overall health of the economy. In general, larger, better established companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. Mutual Funds and Exchange Traded Funds: Mutual funds and exchange traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and

sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas "closed end" funds have a fixed number of shares to sell which can limit their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or other benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks on a daily basis, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but which are expected to yield similar performance. Leveraged Exchange Traded Funds: Leveraged Exchange Traded Funds ("Leveraged ETFs" or "LETF") seeks investment results for a single day only, not for longer periods. A "single day" is measured from the time the L-ETF calculates its net asset value ("NAV") to the time of the L-ETF's next NAV calculation. The return of the L-ETF for periods longer than a single day will be the result of each day's returns compounded over the period, which will very likely differ from multiplying the return by the stated leverage for that period. For periods longer than a single day, the L-ETF will lose money when the level of the Index is flat, and it is possible that the L-ETF will lose money even if the level of the Index rises. Longer holding periods, higher index volatility and greater leverage both exacerbate the impact of compounding on an investor's returns. During periods of higher Index volatility, the volatility of the Index may affect the L-ETF's return as much as or more than the return of the Index. Leveraged ETFs are different from most exchange-traded funds in that they seek leveraged returns relative to the applicable index and only on a daily basis. The L-ETF also is riskier than similarly benchmarked exchange-traded funds that do not use leverage. Accordingly, the L-ETF may not be suitable for all investors and should be used only by knowledgeable investors who understand the potential consequences of seeking daily leveraged investment results. Leveraged ETF Leveraged Risk: The L-ETF obtains investment exposure in excess of its assets in seeking to achieve its investment objective — a form of leverage — and will lose more money in market environments adverse to its daily objective than a similar fund that does not employ such leverage. The use of such leverage could result in the total loss of an investor's investment. For example: a 2X fund will have a multiplier of two times (2x) the Index. A single day movement in the Index approaching 50% at any point in the day could result in the total loss of a shareholder's investment if that movement is contrary to the investment objective of the L-ETF, even if the Index subsequently moves in an opposite direction, eliminating all or a portion of the earlier movement. This would be the case with any such single day movements in the Index, even if the Index maintains a level greater than zero at all times. Leveraged ETF Compounding Risk: Compounding affects all investments, but has a more significant impact on a leveraged fund. Particularly during periods of higher Index volatility, compounding will cause results for periods longer than a single day to vary from the stated multiplier of the return of the Index. This effect becomes more pronounced as volatility increases.

Leveraged ETF Use of Derivatives: The L-ETF obtains investment exposure through derivatives. Investing in derivatives may be considered aggressive and may expose the L-ETF to greater risks than investing directly in the reference asset(s) underlying those derivatives. These risks include counterparty risk, liquidity risk and increased correlation risk (each as discussed below). When the L-ETF uses derivatives, there may be imperfect correlation between the value of the reference asset(s) and the derivative, which may prevent the L-ETF from achieving its investment objective. Because derivatives often require only a limited initial investment, the use of derivatives also may expose the L-ETF to losses in excess of those amounts initially invested. The L-ETF may use a combination of swaps on the Index and swaps on an ETF that is designed to track the performance of the Index. The performance of an ETF may not track the performance of the Index due to embedded costs and other factors. Thus, to the extent the L-ETF invests in swaps that use an ETF as the reference asset, the L-ETF may be subject to greater correlation risk and may not achieve as high a degree of correlation with the Index as it would if the L-ETF only used swaps on the Index. Moreover, with respect to the use of swap agreements, if the Index has a dramatic intraday move that causes a material decline in the L-ETF's net assets, the terms of a swap agreement between the L-ETF and its counterparty may permit the counterparty to immediately close out the transaction with the L-ETF. In that event, the L-ETF may be unable to enter into another swap agreement or invest in other derivatives to achieve the desired exposure consistent with the L-ETF's investment objective. This, in turn, may prevent the L-ETF from achieving its investment objective, even if the Index reverses all or a portion of its intraday move by the end of the day. Any costs associated with using derivatives will also have the effect of lowering the LETF's return. Commercial Paper: Commercial paper ("CP") is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer may default. There is less risk in asset based commercial paper (ABCP). The difference between ABCP and CP is that instead of being an unsecured promissory note representing an obligation of the issuing company, ABCP is backed by securities. Therefore, the perceived quality of the ABCP depends on the underlying securities. Real Estate: Real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. In fact, real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and thus real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or by property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trust: A real estate investment trust ("REIT") is a corporate entity which invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong or the REIT must either dip into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding, and getting harsher

terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, which will lead to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. Warrants: A warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – normally an equity – at a certain price before expiration. The price at which the underlying security can be bought or sold is referred to as the exercise price or strike price. Warrants that confer the right to buy a security are known as call warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Options Contracts: Options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope that the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the price of the stock will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks pertaining to options buyers are: • Risk of losing your entire investment in a relatively short period of time. • The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). • European style options which do not have secondary markets on which to sell the options prior to expiration can only realize its value upon expiration. • Specific exercise provisions of a specific option contract may create risks. • Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks pertaining to options sellers are: • Options sold may be exercised at any time before expiration. • Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continues to risk a loss due to a decline in the underlying stock. • Writers of Naked Calls risk unlimited losses if the underlying stock rises. • Writers of Naked Puts risk substantial losses if the underlying stock drops. • Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker.

• Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how the leverage in options can work against the option trader. • Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. • Call options can be exercised outside of market hours such that effective remedy actions cannot be performed by the writer of those options. • Writers of stock options are obligated under the options that they sold even if a trading market is not available or that they are unable to perform a closing transaction. • The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: • The complexity of some option strategies is a significant risk on its own. • Option trading exchanges or markets and option contracts themselves are open to changes at all times. • Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. • Risk of erroneous reporting of exercise value. • If an options brokerage firm goes insolvent, investors trading through that firm may be affected. • Internationally traded options have special risks due to timing across borders. Risks that are not specific to options trading include market risk, sector risk and individual stock risk. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. PIPES: In a Private Investment in Public Equity ("PIPE") transaction, investors typically purchase securities directly from a publicly traded company in a private placement. Depending on the structure of the transaction, this can be done at a premium to or at a discount from the market price of the company's common stock. Because the sale of the securities is not pre-registered with the U.S. Securities and Exchange Commission ("SEC"), the securities are "restricted" and cannot be immediately resold by the investors into the public markets. Accordingly, the company will usually agree as part of the PIPE transaction to register the restricted securities with the SEC. Thus, the PIPE transaction can offer the company the speed and predictability of a private placement, while providing investors with a nearly liquid security. Risks of investing in PIPES include but may not be limited to substantial entry requirements, limited liquidity, limited investor control, potential for unfunded commitments, and loss of investment. Derivatives: Derivatives are types of investments where the investor does not own the underlying asset. There are many different types of derivative instruments, including, but not limited to, options, swaps, futures, and forward contracts. Derivatives have numerous uses as well as various risks associated with them, but they are generally considered an alternative way to participate in the market. Investors typically use derivatives for three reasons: to hedge a position, to increase leverage, or to speculate on an asset's movement. The key to making a sound investment is to fully understand the characteristics and risks associated with the derivative, including, but not limited to counter-party, underlying asset, price, and expiration risks. The use of a derivative only makes sense if the investor is fully aware of the risks and understands the impact of the investment within a portfolio strategy. Due to the variety of available derivatives and the range of potential risks, a detailed explanation of derivatives is beyond the scope of this disclosure.

Structured Products: A structured product, also known as a market-linked product, is generally a prepackaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity, and have two components: a note and a derivative. The derivative component is often an option. The note provides for periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell to the investor the security or securities at a predetermined price. Other products use the derivative component to provide for a call option written by the investor that gives the buyer of the call option the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; they may only be insured by the issuer, and thus have the potential for loss of principal in the case of a liquidity crisis, or other solvency problems with the issuing company. Investing in structured products involves a number of risks including but not limited to: fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Private Placements: A private placement (nonpublic offering) is an illiquid security sold to qualified investors and are not publicly traded nor registered with the Securities and Exchange Commission. Risk: Private placements generally carry a higher degree of risk due to illiquidity. Most securities that are acquired in a private placement will be restricted securities and must be held for an extended amount of time and therefore cannot be sold easily. The range of risks are dependent on the nature of the partnership and are disclosed in the offering documents. Digital Assets: Generally refers to an asset that is issued and/or transferred using distributed ledger or blockchain technology, including, "virtual currencies (also known as crypto-currencies)," "coins," and "tokens". We may invest in and/or advise clients on the purchase or sale of digital assets. This advice or investment may be in actual digital coins/tokens/currencies or via investment vehicles such as exchange traded funds (ETFs) or separately managed accounts (SMAs). The investment characteristics of Digital Assets generally differ from those of traditional securities, currencies, and commodities. Digital Assets are not backed by a central bank or a national, international organization, any hard assets, human capital, or other form of credit and are relatively new to the market place. Rather, Digital Assets are market-based: a Digital Asset's value is determined by (and fluctuates often, according to) supply and demand factors, its adoption in the traditional commerce channels, and/or the value that various market participants place on it through their mutual agreement or transactions. The lack of history to these types of investments entail certain unknown risks, are very speculative and are not appropriate for all investors. Price Volatility of Digital Assets Risk: A principal risk in trading Digital Assets is the rapid fluctuation of market price. The value of client portfolios relates in part to the value of the Digital Assets held in the client portfolio and fluctuations in the price of Digital Assets could adversely affect the value of a client's portfolio. There is no guarantee that a client will be able to achieve a better than average market price for Digital Assets or will purchase Digital Assets at the most favorable price available. The price of Digital Assets achieved by a client may be affected generally by a wide variety of complex factors such as supply and demand; availability and access to Digital Asset service providers (such as payment processors), exchanges, miners or other

Digital Asset users and market participants; perceived or actual security vulnerability; and traditional risk factors including inflation levels; fiscal policy; interest rates; and political, natural and economic events. Digital Asset Service Providers Risk: Service providers that support Digital Assets and the Digital Asset marketplace(s) may not be subject to the same regulatory and professional oversight as traditional securities service providers. Further, there is no assurance that the availability of and access to virtual currency service providers will not be negatively affected by government regulation or supply and demand of Digital Assets. Accordingly, companies or financial institutions that currently support virtual currency may not do so in the future. Custody of Digital Assets Risk: Under the Advisers Act, SEC registered investment advisers are required to hold securities with "qualified custodians," among other requirements. Certain Digital Assets may be deemed to be securities. Some Digital Assets do not currently fall under the SEC definition of security and therefore many of the companies providing Digital Assets custodial services fall outside of the SEC's definition of "qualified custodian". Accordingly, clients seeking to purchase actual digital coins/tokens/currencies may need to use nonqualified custodians to hold all or a portion of their Digital Assets. Government Oversight of Digital Assets Risk: Regulatory agencies and/or the constructs responsible for oversight of Digital Assets or a Digital Asset network may not be fully developed and subject to change. Regulators may adopt laws, regulations, policies or rules directly or indirectly affecting Digital Assets their treatment, transacting, custody, and valuation.

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.

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.

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.

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 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.

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.