A. Firm Information Spectrum Planning & Advisory Services Inc. d/b/a Bamboo Wealth Strategies (“Bamboo Wealth” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Bamboo Wealth is organized as a corporation under the laws of the State of California. Bamboo Wealth was founded in December 2013 and is owned and operated by Danielle L. Luster (President), Brentt A. Hoover (Chief Executive Officer & Chief Compliance Officer) and Jeremy S. Martinson (Chief Financial Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Bamboo Wealth. B. Advisory Services Offered Bamboo Wealth offers investment advisory services to individuals, high net worth individuals, businesses, trusts, estates, charitable organizations, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Bamboo Wealth’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Bamboo Wealth provides customized investment advisory solutions for its Clients. This is achieved through frequent personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. Bamboo Wealth works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an allocation. Bamboo Wealth will then construct a portfolio, consisting primarily of low-cost diversified exchange-traded funds (“ETFs”), including ETFs in the gold precious metals and commodity sectors, foreign and domestic equities, and mutual funds to achieve the Client’s investment goals. The Advisor may also utilize real estate funds, including REITs, as well as bonds to meet the needs of its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. Bamboo Wealth’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re- allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Bamboo Wealth will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Bamboo Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Bamboo Wealth may, on occasion, redistributing investment allocations to diversify the portfolio. Bamboo Wealth may buy specific positions to increase sector or asset class weightings. The Advisor may employ cash positions as a possible hedge against market movement. Bamboo Wealth may sell positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Bamboo Wealth accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the agreement. Please see Item 12 – Brokerage Practices. Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services Financial planning services are designed to provide highly customized financial planning advice for the Client that will address the Client’s stated financial objectives and/or concerns. Bamboo Wealth Strategies will provide financial planning services to the Client, pursuant to a written financial planning agreement. The content and scope of the financial planning recommendations may include but will not be limited to: a net worth statement, a cash flow statement, analysis of the aforementioned, and a recommended course of action detailing the

specific financial recommendations being made to help the Client achieve their stated financial goals and objectives. In addition, and/or in conjunction with the Client’s stated financial goals and objectives, on an ongoing or fixed engagement basis, the following areas shall be addressed in the financial analysis and subsequent recommendations as applicable: 1. Financial Position (cash flow & debt structure management) 2. Income Tax Planning 3. Investment Planning 4. Employee Benefits Planning 5. Retirement Planning 6. Business Planning 7. Insurance Planning & Risk Management 8. Estate Planning Bamboo Wealth is configured to provide for financial planning advice in two distinct methods as follows: One Time Fixed Engagement – Development and delivery of customized financial advice tailored to the Client’s unique financial objectives and circumstance. The financial advice will address the Client’s specific and current financial objectives and/or concerns (not ongoing financial advice). Based on the need of the Client, a fixed engagement may also be narrow in scope (such as an engagement specifically focused on estate planning, business planning, or major purchase planning). In most circumstances, a personalized interactive financial planning website will be created and shared with the Client. This provides the Client with secure access to on demand financial reports that may include but are not limited to; cash flow, balance sheet, income statement, and retirement projections. The Client relationship in the fixed engagement financial planning capacity terminates once the recommendations addressing all the Clients specific financial objectives have been delivered to the Client and all questions and concerns regarding the recommendations have been addressed. Unless otherwise stated, the total timeframe for a fixed engagement shall not exceed 12 months. Ongoing Financial Advice – This includes the development and delivery of customized financial advice as illustrated above in the One Time Fixed Engagement model, plus ongoing advice. Ongoing financial advice includes unlimited telephone and in person meetings to address any and all financial concerns of the Client. Also included are periodic meetings initiated by the Advisor to proactively address financial considerations and opportunities that may arise due to macroeconomic factors or potential changes in the Client’s financial circumstance. Bamboo Wealth may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Bamboo Wealth provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Investment Oversight Services (ERISA 3(21))
• Ongoing Investment Recommendation and Assistance These services are provided by Bamboo Wealth serving in the capacity of a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Bamboo Wealth’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Bamboo Wealth to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – Bamboo Wealth, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – Bamboo Wealth will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. ● Portfolio Construction – Bamboo Wealth will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – Bamboo Wealth will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Bamboo Wealth does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Bamboo Wealth. E. Assets Under Management As of December 31, 2023, the Advisor manages $151,901,509 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor.