INTRODUCTION FullCircle Wealth LLC (“FullCircle,” the “Firm,” “We,” or “Us”) is a registered investment adviser with the US Securities and Exchange Commission. We became registered on March 22, 2013, and have been operating as an investment adviser since then. Our registration as a Registered Investment Adviser does not imply any level of skill or training. The oral and written communications We provide you, including this Brochure, are information you can use to evaluate Us and other advisers, which are factors in your decision to hire Us or to continue maintaining a relationship with Us. This Brochure provides information about our qualifications and business practices. If you would like a free copy of our most recent brochure, please contact us at: FullCircle Wealth LLC 15660 North Dallas Parkway, Suite 910 Dallas, Texas 75248 972-480-6200 www.fullcircle-wealth.com DESCRIPTION & OWNERSHIP FullCircle was formed as a limited liability company in December 2012 and is headquartered in Dallas, Texas. FullCircle’s two equal members and owners are Brent Sikes and Wesley Pingelton. PORTFOLIO MANAGEMENT SERVICES We provide financial planning, portfolio management, and pension consulting services, and We assist with selecting other advisers. Our client base consists of individuals, high-net-worth individuals, estates, partnerships, charitable organizations, retirement plans, and their participants. We are a professional investment advisory firm committed to managing assets on a discretionary or non- discretionary basis. On a discretionary basis, We design, revise, and reallocate custom portfolios for you. Clients may impose reasonable restrictions on investing in specific securities by notifying Us in writing. On a non-discretionary basis, We provide periodic recommendations to you, and if such recommendations are approved, We will ensure that the authorized recommendations are carried out. Clients must approve all securities transactions prior to implementation. Our portfolio management program is designed to provide the appropriate asset allocation, diversification, and risk characteristics consistent with prudent portfolio management. We manage equity, fixed income, and balanced portfolios using clearly defined investment objectives and guidelines established in private consultation with each Client. We construct, manage, execute, and monitor portfolios that meet each Client's unique set of needs. The investments are determined based on your investment objectives, risk tolerance, net worth, income, age, investment time horizon, tax situation, and other relevant factors. We primarily allocate client assets among cash and cash equivalents, individual stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), municipal bonds, corporate bonds, futures and options, alternative investments, and limited partnerships, all of which are considered asset allocation categories for the client’s investment strategy. Clients may impose reasonable restrictions on investing in certain securities by notifying Us through written notification. Our Firm may recommend that certain clients utilize margin in the client’s investment portfolio or other borrowing. We only recommend such borrowing for non-investment needs, such as bridge loans and other financing. The Firm’s fees are determined based on the value of the assets being managed gross of any margin or borrowing. ADMINISTRATIVE SERVICES PROVIDED BY ORION ADVISOR SERVICES, LLC Our Firm has contracted with Orion Advisor Services, LLC (referred to as “Orion”) to utilize its technology platforms to support data reconciliation, performance reporting, fee calculation and billing, research, client database maintenance, quarterly performance evaluations, payable reports, web site administration, models, trading platforms, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Orion will have access to client accounts, but Orion will not serve as an investment advisor to our clients. Modern Wealth Management and Orion are non-affiliated companies. Orion charges our Firm an annual fee for each account administered by Orion. Please note that the advisory fee charged to the client will not increase due to the annual fee our Firm pays to Orion. The annual fee is paid from the portion of the management fee retained by our Firm. NITROGEN (FORMERLY RISKALYZE) To further fine-tune our understanding of a client’s risk tolerance, We utilize Nitrogen, a third-party vendor tool, to assist in identifying the client’s risk tolerance. Nitrogen technology assists financial planners in two critical tasks: (1) measuring the risk preferences of investors and (2) applying these preference measurements to portfolio selection. Nitrogen summarizes an investor’s mean-variance risk aversion on a 99-point scale. In connection with this output, the Nitrogen tool “quantifies” the client’s indicated investment risk tolerance through the illustration of expected return (plus/minus) and investment volatility (investment variance), which uses past data to calculate expected variance. FINANCIAL INSTITUTION INVESTMENT SERVICES – MUTUAL SECURITES, INC. Our Firm has an agreement(s) with brokers/dealers to provide investment advisory services to Annuity Brokerage Customers. This advisory arrangement does not include assuming discretionary authority over Brokerage Customers’ brokerage accounts or monitoring securities. These advisory services are offered to Brokerage Customers and include a general review of investment holdings, which may or may not result in our investment adviser representatives making specific sub-account recommendations or offering general investment advice. Brokerage Customers will execute a written non-discretionary investment services agreement directly with FullCircle. This relationship presents conflicts of interest. Potential conflicts are mitigated by Brokerage Customers consenting to receive investment services from FullCircle; by FullCircle not accepting or billing for additional compensation on broker dealer assets outside of our non-discretionary services we provide Mutual Securities, Inc. clients; and by FullCircle not engaging as, or holding itself out to the public as, a securities broker/dealer. Our firm is not affiliated, nor are our advisors registered, with any broker/dealer. ERISA ACCOUNTS, PROFIT SHARING 401(K), SEP’S & DISCLOSURE We may also have other retirement accounts subject to ERISA rules and regulations. In all cases, an “eligible investment advice arrangement” or advisory agreement will be executed with the Client. When We provide investment advice to clients regarding their 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 our Client’s interests, so We operate under a special rule that requires us to act in our Client’s best interest and not put our interests ahead of our Clients. FullCircle may recommend that a Client roll over their retirement plan assets into an account to be managed by FullCircle. A Client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If A client or potential client asks us to make a recommendation from among these choices, We have a conflict of interest in that We have an incentive to recommend that a Client roll over their retirement plan assets into an account to be managed by FullCircle, such a recommendation creates a conflict of interest as We will earn a new (or increase our current) Advisory Fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation

to ensure it is in the best interest of the Client. No Client is under any obligation to roll over retirement plan assets to an account We manage. FINANCIAL PLANNING AND CONSULTING SERVICES We also offer financial planning analysis, consulting, and comprehensive written financial plans. Our financial planning analysis services may include an analysis of only isolated area(s) of your financial affairs, such as estate planning, retirement planning, any other specific topic, or any other investment and financial concerns you may have. We also offer comprehensive Financial Planning services. If you purchase this service, you will receive a written report with a detailed financial plan designed to achieve your stated goals and objectives. The financial plan, as directed by you, may include asset protection, tax planning, business succession, strategies for exercising stock options, cash flows, education planning, estate planning and wealth transfer, charitable gifting, long-term care and disability planning, retirement planning, insurance planning, asset allocation comparisons, and risk management. We gather the required information through in-depth personal interviews. Information gathered includes a Client’s current financial status, future goals, and attitudes towards risk. Related documents supplied by you and a completed Client questionnaire are carefully reviewed, and a written report is prepared. Implementation of the prepared plan or recommendations is solely at your discretion, and you will also determine how you want to implement the plan or recommendations. For plans requiring tax or legal expertise, We encourage you to utilize any desired tax or legal professional or group of professionals to assist in the implementation. EMONEY ADVISOR PLATFORM We make available to our Clients the “eMoney Advisor” platforms to provide periodic comprehensive reporting services that can incorporate all the Client’s investment assets, including those investment assets that are not part of the assets managed by the Firm (“Excluded Assets”). The Client and their other advisors who maintain trading authority, not the Firm, shall be exclusively responsible for the investment performance of the excluded assets. Unless otherwise expressly agreed to in writing, the Firm’s service relative to the excluded assets is limited to reporting only. Therefore, We shall not be responsible for the investment performance of the excluded assets. Instead, the Client and the Client’s designated outside investment professional(s) maintain supervision, monitoring, and trading authority for the excluded assets. If our Client prefers, the Firm will provide recommendations on any excluded assets. The Client has no obligation to accept the recommendation, and We shall not be responsible for any implementation error (timing, trading, etc.) relative to the excluded assets. The Client may engage us under the terms and conditions of a Consulting or Investment Advisory Agreement between the Firm and the Client. eMoney Advisor Platform may also provide access to other types of information, including financial planning concepts, which should not be construed as the Firm’s personalized investment advice or recommendations. We shall not be held responsible for any adverse results a Client may experience if the Client engages in financial planning or other functions available on the eMoney Advisor Platform without our assistance or oversight. FINANCIAL PLANNING REVIEWS/MAINTENANCE AND SPECIALIZED ANALYSIS SERVICES Over time, as the economic climate and personal circumstances change, you may wish to adjust your goals, resulting in a change in planning strategy. You can engage Us to prepare a review or update of your plan. This reappraisal can include updates and projections regarding cash flow, net worth, tax liabilities and retirement projections, etc. We provide special services, including participation in the analysis, development, and implementation of budgeting and cash flow management, coordination and oversight of banking and investment advisory relationships, negotiations of certain real or personal property purchases, and other requested projects or services. THIRD-PARTY INVESTMENT MANAGER SELECTION SERVICES FullCircle recommends the services of third-party managers. ENVESTNET ASSET MANAGEMENT Generally, FullCircle will use third-party managers through the Unified Managed Accounts Exchange platform (“UMAX”). We may recommend that you utilize the services of Envestnet Asset Management (“Envestnet” or “Overlay Manager”), an investment advisor registered with the SEC. Envestnet is a subadvisor offering Unified Managed Account (“UMA”) programs and services. UMAs are fee-based investment solutions that allow advisers to combine multiple professionally managed investment products into a single account with automated services such as rebalancing, performance reporting, billing, and advanced functionality such as managing securities restrictions. The third-party-managed investment products are managed by advisors to model portfolios (“Model Portfolio Advisors”) selected for the Client by FullCircle. Envestnet also acts as an Overlay Manager for your portfolio under this program. Under this program, We recommend one or more unaffiliated, third-party investment managers whose investment style is believed to be consistent with your financial needs, investment goals, tolerance for risk, and stated investment objectives. Upon selection and after the initial allocation of your portfolio, We will monitor the performance of the models to ensure their performance and investment style remain aligned with the investment goals and objectives. You grant the Overlay Manager discretionary authority to manage and invest your assets. We retain the ultimate discretionary authority to terminate the Overlay Manager relationship and will do so if it is in the best interest of the Client. By signing the Unified Managed Account Exchange Application and Agreement (“UMA Agreement”), the Client appoints Envestnet to provide overlay management services to FullCircle Clients. Envestnet is responsible for ongoing management and supervision of accounts; implementation and coordination of model portfolios and related recommendations received from Model Portfolio Advisors; periodic rebalancing of accounts; cash management; loss harvesting for taxable accounts (but without tax management); initial investment of accounts and tradition of legacy assets; incorporating Client-requested restrictions for specific securities and social and industry categories; and providing tax overlay management on accounts for which the Advisor has selected tax management on behalf of Clients. The Overlay Manager will have authority and discretion to select brokers and dealers to execute portfolio transactions initiated by the Overlay Manager and to select the markets in which the transactions will be executed. Clients offered Envestnet will receive all required disclosure documents, including the Firm’s ADV Part 2A and Privacy Policy. Envestnet may impose a minimum dollar amount of initial Client assets for the investment advisory services as disclosed in the management agreement. These minimums may be waived at their discretion. ASSETMARK INC. From time to time, FullCircle will enter into agreements with individuals and organizations where FullCircle refers clients to third-party managers, such as AssetMark, Inc. All such agreements will be in writing. If a client is introduced to a third-party manager by FullCircle, FullCircle may receive promoter fee(s) in accordance with the requirements of state and/or federal securities law, as applicable. The specific terms of each agreement may differ but will be delivered to each referred client. Any such fee shall be paid solely from the third-party manager’s management fees and shall not result in any additional charge to the client. For more information, please see Item 14 – Client Referrals and Other Compensation. WRAP FEE PROGRAMS We do not manage, sponsor, or participate in wrap fee programs. ASSETS UNDER MANAGEMENT We currently have $310,551,631 in discretionary assets under management as of December 31, 2023.