A. The Company FC360 Wealth Management, Inc. is a privately-held California corporation that h a s b e e n providing investment advisory services since June 26, 2014 and h a s b e e n registered with the SEC as an investment advisor since March 29, 2021. Throughout this disclosure brochure, the company is referred to as “FC360” or the “firm.” The pr i n c i pa l o w n e r of FC360 is Louis J. Barrientos. B. Advisory Services FC360 provides full service investment management, which includes investment management services, financial planning, retirement planning, insurance planning, and referrals to professionals who handle tax and estate planning on behalf of our clients. The firm also provides investment advice to participants and plan sponsors of employer sponsored plans. FC360’s Investment Management Services Full Circle 360 Platform Under the Full Circle 360 Platform, FC360 will provide personalized discretionary investment management services by taking a holistic approach to wealth management. FC360 begins each relationship through a discovery process with the client to identify and discuss specific goals, objectives, risk tolerance and time horizon. Thereafter, FC360 will create and manage a customized portfolio based on that profile, allocating the client’s assets among various investments. Also, FC360 will provide other benefits to the client’s such as retirement planning, financial planning, insurance planning, and tax and estate planning through outside licensed professionals. Options Overlay Clients can choose to add an options overlay strategy to their investment strategy. This strategy seeks to deliver capital appreciation and an enhanced level of income through building a portfolio of stocks, primarily dividend stocks, and then writing covered calls and/or selling cash secured puts on the investment positions. This strategy is used to either reduce overall volatility in the portfolio and/or add incremental income. Tactical Investment Platform Under the Tactical Investment Platform, FC360 will provide personalized discretionary investment management services by taking an active non-constrained investment approach to wealth management. FC360 begins each relationship through a discovery process with the client to identify and discuss specific goals, objectives, risk tolerance and time horizon. Thereafter, FC360 will create and manage a customized portfolio based on that profile, allocating the client’s assets among various investments. Also, FC360 will provide other benefits to the client’s such as retirement planning, financial planning, insurance planning, and tax and estate planning through outside licensed professionals. Low Cost Indexing Platform Under the Low-Cost Indexing Platform, FC360 will provide personalized discretionary investment management services by taking a passive investment approach to wealth management. FC360 begins each relationship through a discovery process with the client to identify and discuss specific goals, objectives, risk tolerance and time horizon. Thereafter, FC360 will create and manage a customized portfolio based on that profile, allocating the client’s assets among various investments that consist primarily of Exchange Traded Funds. 401(k) Retirement Consulting Services FC360 provides 401(k) Retirement Consulting Services to both the sponsor of non- pooled retirement plans (the “Client”) and plan participants (the “Plan Participants”). Services Provided to Plan Sponsors FC360 shall provide to the Client the scope of services in connection with the investment and reinvestment of securities, cash and/or other investments held from time to time in the Client’s plan account (the “Plan”). If the client elects the Full-Service Retirement Platform, FC360 shall act as the 3(21) & 3(38) fiduciary of the Plan, as defined under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), with respect to the investment advice FC360 provides to the Plan. The scope of services to the Client includes:
• Consultation via in person, phone or video conferencing on the plan anniversary date to discuss the details of the plan, including investment selections, administration and education of the participants;
• Consultation related to the monitoring of service providers, including but not limited to Plan asset custodians and third party plan administrators;
• As the 3(38) fiduciary, FC360 will monitor, assess, and remove or implement funds within a client’s Plan. Services Provided to the Plan Participants To the extent the Client is a plan sponsor of an individual account plan as defined under Section 404(c) of ERISA, FC360 shall provide Plan Participants the services set forth in the scope in connection with the investment and reinvestment of securities, cash and/or other investments held from time to time in the Plan Participants’ accounts under the Plan. A Plan Participant shall exercise control over the assets in his or her account by providing the recordkeeper with investment instructions in the form requested by the plan administrator regarding the investment of the account. FC360 also provides Plan Participants with sufficient information to make informed decisions about investment alternatives available under the Plan in accordance with ERISA regulation Section 2550.404c-1(b)(2)(i)(B)(1) and (2). This service satisfies the ERISA 3(21) fiduciary requirement. The scope of services to Plan Participants includes:
• Take Plan Participants through an investor questionnaire that will determine a client’s time horizon to retirement and their overall risk tolerance.
• Based on the questionnaire results, Plan Participants will be

provided with general asset allocation models based on generally accepted investment theories, which is specific to their time horizon to retirement.
• Provide Plan Participants with investment materials through a third-party application website. Financial Planning Services Financial planning is primarily an analytical process designed to organize financial data, identify needs and opportunities and evaluate alternative courses of action; it may include analysis of current net worth, income taxes, cash flow and budgeting, investments and asset allocation, retirement planning, employee benefit plan analysis, estate and gift tax planning, education pre- funding and risk management focusing on life, health and disability coverage. In general, FC360 gathers required information through personal interviews. FC360 will typically meet with the client to conduct an evaluation of the client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are reviewed, including a questionnaire the client completes that provides relevant information and authorizations. FC360 conducts a financial analysis and prepares a written plan that describes the client’s current situation, identifies needs and opportunities and makes suggestions designed to help the client achieve stated goals. While financial analyses may include investment advice concerning mutual funds and securities, it may also include investment advice with respect to products that may or may not constitute “securities,” such as life insurance and annuities. It also takes into consideration estate tax planning issues that may not constitute “investment” advice. FC360 may recommend its own services, the services of its own investment advisor representatives, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if FC360 recommends its own services or that of its own investment advisor representatives. The client is under no obligation to act upon any of the recommendations made by FC360 under a financial planning engagement and/or engage the services of any such recommended professional, including FC360 or any of its related persons. Clients retain absolute discretion over all such implementation decisions and are free to accept or reject any of FC360’s recommendations. In performing its services, FC360 shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. If requested by the client, FC360 may suggest the services of other professionals for implementation services, but the client is under no obligation to engage the services of any suggested professional. In addition, each client is advised that it remains their responsibility to promptly notify FC360 if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising FC360’s previous recommendations and/or services. C. Full Circle 360 Platform FC360 offers investment advisory services which are tailored to meet the specific needs of each client. Our Full Circle 360 Platform gives our FC360 clients a higher level of benefits and services than one would usually receive while working with a traditional advisor. In order to provide appropriately individualized services, FC360 will obtain information regarding the client’s financial circumstances, investment objectives, overall financial condition, income and tax status, personal and business assets, risk profile and other information regarding the client’s financial and investment needs through our discovery “Get to Know our Client” process. FC360 will periodically review with clients their financial circumstances, investment objectives and risk profile. In order for FC360 to provide effective advisory services, it is critical that clients provide accurate and complete information to FC360 and inform the firm anytime such information needs to be updated or anytime there is a change in their financial circumstances, investment objectives and/or risk profile. Generally, clients are permitted to impose reasonable restrictions on investing in certain securities or types of securities in their advisory accounts, provided, however, that some restrictions may not be accommodated when utilizing Exchange Traded Funds, mutual funds or with respect to certain third-party products or services made available through FC360. In addition, a restriction request may not be honored if it is fundamentally inconsistent with FC360’s investment philosophy, runs counter to the client’s stated investment objectives, or would prevent FC360 from properly servicing client accounts. All Full Circle 360 accounts will be managed on a discretionary basis. D. Wrap Fee Programs FC360 does not provide portfolio management services to a wrap fee program(s). Under a wrap fee program, advisory services (which may include portfolio management or advice concerning the selection of other investment advisors) and transaction services (e.g., execution of trades) are provided for one fee. This is different than traditional investment management programs whereby services are provided for a fee, but transaction services are billed separately on a per-transaction basis. E. Assets Under Management As of March 25, 2024, the total amount of client assets managed collectively by FC360 is approximately $113,486,163. Of this total amount, $107,086,773 of client assets are managed on a discretionary basis and $6,399,390 of client assets are managed on a non-discretionary basis. FC360’s business model is one where the majority of the fees earned by the firm are solely fee-based for investment advice.