General Information Guardian Wealth Advisors, LLC (formerly “GWP Holdings, LLC”) was founded in 2019. GWA is principally owned by Christian Keedy, Michael Hensley, and Todd Misenheimer. Additionally, Rand Millwood, Russell Smith, Greg Rhinehardt, Marissa Pratt, and Maddy Carlson serve as partners of GWA. GWA offers the following services, each of which is more fully described below:
• Investment Advisory Services;
• Financial Planning Services; and
• Retirement Plan Consulting Services. Investment Advisory Services Financial Profile and Investment Plan GWA provides discretionary and non-discretionary Investment Advisory Services to individuals and high net worth individuals, retirement plans (including defined contribution plans, 401(k) plans, 403(b) plans, and profit-sharing plans) and their participants, charitable organizations, trusts, estates, endowments, foundations, corporations and other business entities. At the outset of each client relationship, GWA spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, tolerance for risk, and broadly identifying major goals of the client. Based on its reviews, GWA generally develops with each client:
• a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile”); and
• the client’s investment objectives and guidelines (the “Investment Plan”). The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments GWA will make or recommend on behalf of the client based on GWA’s own research and analysis in order to meet those goals. The Investment Plan generally includes investment management strategies designed to achieve the client’s near-term and long- term goals while managing the influence of risk on their success. The Adviser will help the client understand their overall asset allocation, their investment options, and the Adviser’s recommendations. The Financial Profile and Investment Plan are designed to balance the client’s expectations of risk and return. The elements of the Financial Profile and the Investment Plan are discussed periodically with each client but are not necessarily written documents. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by GWA based on updates to the client’s financial or other circumstances. It is the responsibility of the client to notify GWA of any changes to their financial situation or objectives or any other factors that may impact the client’s Financial Profile. Portfolio Management To implement the client’s Investment Plan, GWA will manage the client’s investment portfolio on a discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the client. As a discretionary investment adviser, GWA will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non- discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Notwithstanding the foregoing, clients may request certain reasonable restrictions on GWA in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship, with written notice to GWA. Each client should note, however, that restrictions, if accepted by GWA, may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of GWA. Separate Account Managers GWA may recommend or select one or more third party investment advisers or model portfolio providers (each a “Manager”), when appropriate and in accordance with the client’s Investment Plan. Having access to various Managers offers a wide variety of manager styles and provides the opportunity to utilize more than one Manager for the portfolio. Factors that GWA considers in recommending/selecting Managers generally includes the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing and research. Pursuant to a Sub-Advisory Agreement, the Manager(s) may be granted discretionary or non-discretionary trading authority to provide investment supervisory services for all or a portion of the portfolio. Other Managers may be engaged to provide research and trading signals to GWA in connection with certain model portfolios offered by the Manager. Where a Manager has been engaged to provide non-discretionary investment advice, GWA will typically receive the Manager’s recommendations and thereafter effect trades on behalf of the client’s portfolio as determined by GWA; however, GWA may allow the Manager to effect trades in the client’s portfolio if GWA determines it is in the client’s best interests to do so. Although, GWA retains the authority to terminate the Manager’s relationship or to add new Managers without specific client consent, clients are typically consulted prior to the engagement or termination of any Manager when it is practicable to do so. GWA may utilize Managers in the following ways: (i) through one or more direct relationships, where GWA contracts directly with a Manager to provide sub-advisory, or research services to a client portfolio, or (ii) through one or more Unified Managed Account Platforms (each, a “UMA Platform”), where GWA contracts with the UMA Platform to gain access to the model portfolios of the various Managers available on the UMA Platform. However, under certain circumstances, the client will select one or more Managers recommended by GWA and the client, and not GWA, will enter into a separate agreement which each Managers.
• Direct Relationships. When GWA engages a Manager directly to provide discretionary or non- discretionary advisory services for a client portfolio, it will enter into a Sub-Advisory Agreement with the Manager on behalf of all or a portion of a client’s portfolio. The Manager will then have either discretionary authority to manage the client’s portfolio (or portion thereof), or the Manager will make recommendations to GWA on a non-discretionary basis, in each case in accordance with the Manager’s strategy that GWA has selected for the client. Other Managers may be engaged pursuant to a research, signal or model portfolio agreement, pursuant to which the Manager will provide research and trading signals to GWA in connection with certain model portfolios offered by the Manager.
• UMA Platforms. A UMA Platform is a program sponsored by a third-party investment adviser (a “UMA Manager”) that provides access to a variety of model portfolios (“Strategies”) created and managed by Managers included on the UMA Platform, which Managers may be independent of or affiliated with the UMA Manager. Although the Managers are typically registered investment advisers, Strategies are not tailored to the particular needs or circumstances of a client. Instead, the Strategies are provided by the Managers to the UMA Platform as impersonal, generalized, non- discretionary advice that the UMA Manager will implement as the UMA Manager deems appropriate pursuant to the UMA Manager’s discretion. When GWA uses a UMA Platform for a client account, GWA will allocate all or a portion of the client’s portfolio to one or more Strategies selected for the client. The UMA Manager will then monitor the client portfolio and implement the Strategies through the UMA Platform as directed by the Managers. With respect to assets managed by a Manager, whether directly through a sub-advisory or other agreement or through a UMA Platform, GWA’s role will be to monitor the overall financial situation of the client, to monitor the investment approach and performance of the Manager(s), and to assist the client in understanding the investments of the portfolio. Clients will be provided each Manager’s and UMA Platform’s Form ADV Part 2A Brochure, which contains important information regarding the strategies, fees and risks of the Manager or UMA Platform, upon request. GWA is charged fees by Managers and UMA Platforms that are engaged on behalf of a client (collectively, “Manager Fees”). Manager Fees are typically calculated by applying the Manager’s or UMA Platform’s fee schedule to the amount of client assets serviced by the Manager or UMA Platform; however,

certain Managers or UMA Platforms may charge flat fees. Any applicable Manager Fees will be calculated separately from, and added to, GWA’s investment advisory service fees (“Investment Advisory Service Fees”). GWA’s fees do not include: custodial or transaction costs paid to the client’s custodian, brokers or other third-party consultants; fees or taxes on brokerage accounts and securities transactions; wire fees; or fees and expenses charged by mutual funds, exchange traded funds (“ETFs”) or other investment pools to their shareholders (collectively, “Funds”) (generally including a management fee and fund expenses, as described in each Fund’s prospectus or offering materials). Clients should review the statements they receive from their custodian carefully, and promptly notify GWA of any discrepancies. Please see Item 5 – Fees and Compensation for additional information. Certain clients may request that GWA hold assets in a client’s portfolio that are not subject to management by GWA as an accommodation to the client. If GWA agrees to hold such assets in a client portfolio, GWA typically will not charge a management fee with respect to such assets. Clients that enter into such arrangements with GWA should understand that they will not receive the benefits of GWA’s management services with respect to the unmanaged asset, which means that GWA will have no obligation to manage, make any recommendation with respect to, monitor or otherwise consider any such asset, even during periods of adverse market conditions or when GWA otherwise believes that such actions or recommendations are likely to benefit the client or avoid adverse consequences. Clients will remain responsible for any custodial, transaction or other third-party fees and expenses associated with such unmanaged assets. Services to Retirement Plan Participants GWA may also provide investment advice directly to plan participants, on a non-discretionary basis. In such a case, GWA will provide participants with diversification strategies and investment recommendations, and the participants will have the sole responsibility to execute the transactions. In some cases, GWA may, after approval of the client, instruct the record-keeper or third-party administrator to execute recommendations on the client’s behalf. From time to time, GWA will also meet with plan participants to provide general investment education, which may include basic information regarding insurance products, annuities, inflation, risk, diversification and asset allocation. Financial Planning Services GWA also offers Financial Planning Services to clients. Financial Planning Services are either provided in conjunction with the management of a client’s portfolio, in connection with the creation of the client’s Financial Profile and Investment Plan or may be offered as a stand-alone service for a separate fee. GWA’s Financial Planning Services normally address areas such as general cash flow planning, retirement planning, education planning, “windfall” planning, estate and wealth transfer planning, special needs planning, asset management, tax planning, insurance needs analysis and asset allocation. The goal of this service is to assess the financial circumstances of the client in order to develop a financial plan for the client. To create this plan, GWA will typically gather information on the client’s financial data and goals, which may include information on the client’s family, employment, property, investments, businesses, insurance, income, expenses, savings, retirement goals, risk tolerance and the client’s objectives related to the foregoing. It is however the responsibility of the client to notify GWA of any changes to their financial situation or objectives or any other factors that may impact the client’s financial plan. In all matters, GWA’s Financial Planning Services are analytical and advisory only and do not include legal, tax, accounting or other professional services unless specifically stated. GWA’s representatives may work with a client’s legal, accounting, tax, insurance or other professional advisors to ensure the coordination of all pieces involved in the financial planning and/or estate planning process at the client’s request. The financial plan may include specific financial and investment strategies as well as specific product recommendations, including equity, fixed income, insurance products, as well as asset allocation recommendations. At no time, however, is the client under any obligation to implement (with GWA or with any other firm) any of the suggestions outlined in the financial plan. Rather, implementation of a client’s financial plan is solely at the client’s discretion. Certain information provided in connection with Financial Planning Services may include educational materials regarding the effect of taxes, which information is general in nature. However, clients should be aware that GWA does not render tax, legal or accounting advice, and that GWA does not prepare any legal documents for the implementation of any of its recommendations. Nothing recommended or outlined by GWA should be used by a client as a substitute for competent legal, accounting or tax counsel provided by the client’s personal attorney, accountant and/or tax advisor. As part of its Financial Planning Services, GWA may provide insurance reviews. These reviews are general in nature and are intended to provide a client with an understanding of the general amount of insurance coverage recommended for persons in comparable financial situations. Unless otherwise expressly requested by the client and agreed to by GWA, these reviews will not include any recommendations about the client’s property or casualty policies (e.g., homeowner’s, automobile and similar policies). Clients should be aware that risk management through the use of insurance coverage is important, and GWA strongly recommends that each client review each area of potential and/or actual coverage need with the client’s insurance agent to ensure that adequate coverage exists. Retirement Plan Consulting Services GWA may provide retirement plan consulting services to companies (“plan sponsors”) that sponsor qualified retirement plans and/or non-qualified executive deferred compensation programs. In providing such services, GWA works with the plan sponsor to provide the following initial and ongoing services (as selected by the plan sponsor):
• Establishment of an Investment Policy Statement;
• Analysis, review, and recommendations of the plan’s investment options;
• Attend plan review meeting and/or investment committee meeting;
• Educational/enrollment meetings for employees;
• Continuing individual participant support; and
• Other services negotiated by GWA and the plan sponsor. Investment selection includes an analysis of the existing investment menu and a review of the other investment options available based on the provider/record-keeper/custodian’s capabilities. GWA will then recommend a diverse group of funds, based on the guidelines established in the Investment Policy Statement. After the selection of the initial investment menu, GWA will provide ongoing investment due diligence reports, and when applicable, recommendations for investment changes. For each 401(k) and similar plan, GWA will generally make themselves available for the initial participant meetings to provide retirement planning education and summarize the investment options available within the plan. If requested by the plan sponsor, GWA will make annual or semi-annual presentations to plan participants to provide plan awareness, investment education, retirement planning guidance, and other relevant information. GWA is also available to plan participants by phone or email to address their investment-related or retirement planning related questions they may have. Cash Management Services GWA makes available to clients the Cantor Fitzgerald Cash Management Program (“Cash Management Program”) offered by StoneCastle Network, LLC (“StoneCastle”), an affiliate of StoneCastle, LLC. This Cash Management Program allows clients to place funds in deposit accounts at banks, savings institutions and credit unions (collectively, “Insured Depositories”) in a manner that maintains full insurance of the funds by the Federal Deposit Insurance Corporation (“FDIC”) or National Credit Union Administration (“NCUA”), whichever is applicable. Funds are deposited within StoneCastle’s network of Insured Depositories (“Deposit Network”). GWA will assist clients in signing up for this program and facilitating the transfer of funds between the client’s like-titled brokerage accounts and the FICA account. GWA will earn a fee from StoneCastle if clients participate in this program, which gives GWA an incentive to recommend its clients participate in the program. General Consulting Services In addition to the foregoing services, GWA may provide general consulting services to clients. These services are typically provided in conjunction with Financial Planning Services or Retirement Plan Consulting Services, as and when requested by the client and agreed to by GWA. Financial Institution Consulting Services GWA provides investment consulting services to certain broker/dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive the firm’s consulting services. Brokerage Customers have entered into a written advisory agreement with GWA. Assets Under Management as of December 31, 2023: Discretionary basis: $1,450,056,309; 3650 accounts. Non-Discretionary basis: $210,845,910; 20 accounts.