Independent Wealth Network, Inc. (“IWN”, “Firm”, “Advisor”, “we”, “our”, or “us”) is a privately-owned Iowa corporation and has been in business since August 2017. The principal owners are Jeff Zupancic, Art Dinkin, and Andrew Endelman. Types of Advisory Services IWN through its Investment Adviser Representatives (“IAR”), offers investment advisory services that are tailored to each client’s individual situation. Many factors such as the client’s investment objectives and the IAR’s expertise and business practices are considered when determining which advisory program may be most appropriate for the client. IWN requires its IARs to have successfully passed the applicable required industry examinations and to have obtained and maintain registration in the state in which a client resides. After reviewing the client’s financial situation, risk tolerance, time horizon and goals, the IAR will make specific recommendations for the client on how to meet stated investment goals. To implement a recommendation, the client must complete an Investment Advisory Agreement (“Agreement”) which includes the Investment Policy Statement (“IPS”) with the assistance of their IAR. The advisory agreement discloses the services to be provided and the fee that will be charged. The IPS outlines the client’s investment objectives, financial circumstances, risk tolerance and any restrictions the client may wish to impose on their investment activities. Information provided by the client influences the way the IAR invests the client’s assets. The IAR will be available to the client for consultation on these matters and will act on any changes in a client’s financial circumstances deemed to be material or appropriate as soon as practical after the IAR becomes aware of the change. Financial Planning or Consulting Services Ongoing financial planning and/or consultation services are available if specifically requested by a client. In the event the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of IAR), IAR may decide to charge for such additional services, the dollar amount of which shall be set forth in a separate written agreement with the client. With respect to IAR’s planning and consulting services, client acknowledges:
• Client is free to accept or reject any recommendation and client acknowledges that they have the sole authority regarding the implementation, acceptance, or rejection of any recommendation or advice.
• Recommendations for estate planning, retirement planning, taxes, insurance, and/or other services may be discussed and/or implemented, at client’s sole discretion, with corresponding professional(s) such as a broker, accountant, attorney, or insurance agent who may be affiliated entities and/or IAR of IWN or otherwise of client’s choosing.
• In respect to estate planning and tax planning matters, IAR’s role shall be that of a facilitator between client and their corresponding professional(s).
• No portion of IWN’s services should be construed as legal or accounting advice. Rather, client should defer to a properly credentialed attorney or accountant; and
• Clients must notify their IAR if there is a change in financial situation or investment objective(s) for reviewing, evaluating, and/or revising Advisor’s previous recommendations and/or services and/or to address new planning or consulting matters. In the annual notification of updated registration and disclosure documents, the Firm will remind the Client of this obligation to keep their IAR informed. Each IAR utilizes different planning and investment strategies along with IWN-approved software tools when making recommendations and recommending investment allocations for client accounts, which may differ from the advice, timing, or action taken regarding other client(s). Plan supervision is guided by the stated Independent Wealth Network, Inc. Page | 5 objectives of the client as written in the Investment Policy Statement (“IPS”) attached to Agreement as Exhibit A. Financial plans or consulting services may make future and hypothetical projections using information provided by the client. Information provided to IAR is believed to be accurate. There are no guarantees on the performance of the plan or consulting services provided. Wealth Management By signing an Investment Advisory Agreement with IWN, the client has provided their IAR discretionary authority to initiate trades or transactions on their behalf. The client’s Investment Policy Statement specifies any trading or investment limitations. A Client who gives discretion to an IAR must have complete trust in the IAR as the arrangement may be risky. However, any decisions made by an IAR must be in the client’s best interest and suitable for the client based on the client’s objective’s and tolerance for risk. Each client account may be offered different advice or services depending on the specific needs of the client and the expertise of the IAR. Third-Party Managers IWN has agreements with third-party managers which IARs may recommend to clients. When employed, the third-party manager will manage a part or all of the client’s assets on a discretionary basis. The IAR assists the client in completing a suitability review and a review of the manager’s strategies to meet the client’s goals. IARs do not provide daily management of these assets but supervise the managers and monitors the accounts to ensure compliance with the client’s stated objectives. The IAR may periodically recommend changes in investment strategy, third-party manager, or asset allocation due to market factors or changes in the client’s financial goals. Please consult the third-party manager’s disclosure brochure for more information about their methods, costs, fees, risks, etc. Their brochure should be provided by your IAR and should be in a similar format to the document you are now reading. Third-party managers may require some notice before cancellation; however, any unearned portion of a prepaid fee shall be refunded to the client on a pro rata basis. Third-Party Models, Model Providers and Overlay Managers Many asset managers available are accessed using investment models (“Third-Party Models”), whereby the asset manager, acting as a “Model Provider”, constructs an asset allocation and selects the underlying investments for each portfolio. Overlay Managers perform overlay management of the Third-Party Models by implementing trade orders and periodically

updating and rebalancing each Third-Party Model pursuant to the direction of the Model Provider. The Model Provider may, from time to time, replace existing models or hire others to create models and cannot guarantee the continued availability of these models. Certain Model Providers may pursue an investment strategy that utilizes underlying mutual funds or exchange traded funds advised by the Model Provider or its affiliate(s) (“Proprietary Funds”). In such situations, the Model Provider or its affiliate(s) may receive fees from their Proprietary Funds for serving as investment advisor or other service provider to the Proprietary Fund (as detailed in the Proprietary Fund’s prospectus). These fees will be in addition to the management fees that a model provider receives for its ongoing management of the Third-Party Models and create a financial incentive for the Model Provider to utilize proprietary funds. This creates a conflict of interest with the client. Clients should discuss any questions with or request further information from their IAR concerning the use of Proprietary Funds and Third-Party Models, or the conflict of interest this creates. Independent Wealth Network, Inc. Page | 6 Advisor Managed Accounts An IAR may recommend that clients establish a brokerage account with a custodian to maintain custody of the client’s assets and to affect trades for their accounts. The IAR acts with discretionary trading authority based on the client’s IPS and the advisor’s investment strategies they believe will best achieve the stated objectives of the client. IWN and the custodian each reserve the right to reject and not provide services to any client or with respect to any client account for any reason. In some instances and depending on the custodian used to custody accounts and clear trades, the client will be responsible for transaction charges in addition to the IAR’s advisory fee. The advisory fee is negotiated between the client and their IAR based on the complexity of the investment strategy and the account size. Client Brokerage and Custody Costs IWN is not affiliated with any custodian. IWN does not maintain custody of the client assets on which we advise. Client assets must be maintained in an account at a “qualified custodian”. The custody costs, if any, are found in the prospectus or program brochure and detailed in the selected Exhibit B - Schedule of Fees, from the Investment Advisory Agreement. The custodian does not charge the client for custody services. However, some custodians are compensated by charging client commissions or other fees on trades that it executes or that settle into client accounts. The custodian executes trades for client accounts based on instructions provided by the IAR. By having the custodian execute the trades, it is consistent with our duty to seek “best execution”. Best execution means the most favorable terms for transaction based on all relevant factors, including those listed above. The client acknowledges that in some instances brokerage commissions, custodial fees, stock transfer fees, transaction fees, charges imposed directly by mutual funds, exchange traded funds, fees imposed by variable annuity providers, certain deferred sales charges, wire transfers, and other similar charges incurred in connection with transactions for client account imposed by custodian or unaffiliated third parties will be paid out of the assets in the account and are in addition to the fees paid by client to IWN. Held Away Account Services We provide an additional service for accounts not directly held with one of our custodians but where we do have discretion and may leverage an Order Management System to implement asset allocation or rebalancing strategies on behalf of the client. These are primarily 401K accounts, 529 plans, variable annuities, and other assets not held with our custodian. We regularly review the current holdings and available investment options in these accounts, rebalance, and implement our strategies as necessary. In cases where the client chooses to have IWN advise on assets that are not held at a qualified custodian with whom IWN has an advisory relationship, IWN will have the ability to provide investment management services of those held-away accounts through a third-party portfolio management provider, Pontera. Such accounts will be studied, analyzed, allocated, monitored, managed, tactically adjusted, and rebalanced when necessary and periodically reviewed by the Firm in detail on behalf of the Client, considering the Client’s evolving individual circumstances, goals, and objectives. Access to held away accounts is achieved by the Client permitting access via a provided link through Pontera for the Firm to make asset allocation changes via the Client’s online login credential. These online credentials Independent Wealth Network, Inc. Page | 7 are never made available to, or held, or stored by IWN. Access is restricted and the Firm will only have permissions to make changes to the allocation of funds or other securities in the account and will not at any time be able to adjust, add to or subtract from investment options, or any other plan policies or fees assessed by the plan or the fund providers, access the financial assets in the account, make deposits, withdrawals or distributions. The assets will be monitored by the IAR to insure the portfolio’s adherence to the investment objectives and risk tolerances of the Client. These assets are included in calculating the total assets under management when assessing the advisory fees. Client Imposed Restrictions Clients may impose reasonable restrictions on investing in certain securities, types of securities, industry sectors or asset classes. These restrictions must be disclosed in the client's Investment Policy Statement (Exhibit A of their Investment Advisory Agreement). However, IWN reserves the right to not accept and/or terminate the advisory relationship if we feel that the client-imposed restrictions would limit or prevent us from maintaining the client's investment strategy or achieving the client’s stated objectives. Additionally, if the client’s-imposed restrictions would require IWN to deviate from its standard suite of services, the Firm reserves the right to end the relationship. Assets Under Management IWN manages approximately $306,827,681 on a discretionary basis and $51,499,703 on a non-discretionary basis for total assets under management of $358,327,384 through December 31st, 2023.