Description of the Firm SMART Wealth, LLC ("SMART Wealth"), is an investment adviser registered with the United States Securities and Exchange Commission ("SEC") and is a Nebraska limited liability company founded in 2020 with its principal place of business in Nebraska and is solely owned by David Andrew Brooks, Sr. The firm’s initial registration with the Securities & Exchange Commission was approved on September 23, 2021. Registration as an investment adviser with the SEC does not imply a certain level of skill or training. We are a financial services firm helping individuals create retirement strategies using a variety of investment and insurance products to custom suit their needs and objectives. Description of Services Offered Retirement Income Strategies / Investment Advisory / Portfolio Management Services Our firm offers continuous and ongoing investment advice and portfolio management services. Investment planning is designed to provide a retirement roadmap of income and expenses over the client's life. Our advice and services are tailored to meet our client's individual needs, life circumstances and investment goals. We conduct a vision meeting initially, and subsequent meetings, as necessary, (in person, telephone, or video conference, or via email) with clients in order to understand their current financial situation, existing resources, financial goals, investment objectives, risk tolerance, time horizons and liquidity needs. The primary investment management service we provide is a discretionary asset management program. Clients participating in this program are generally placed in a model overseen by a financial professional at our firm and sub-advised by a third-party investment adviser. Under this program, SMART Wealth, and any sub-advisers we hire to manage the assets in your account are authorized to buy and sell investments in the account without asking you in advance. We will monitor the portfolio's performance on an ongoing and continuous basis, unless otherwise agreed, and will make adjustments and reallocations as necessary due to changes in market conditions and your unique circumstances. Clients have the ability to impose reasonable restrictions and guidelines on investing in certain securities, types of securities or industry sectors. We expect all such restrictions to be timely communicated to us. Client restrictions and guidelines could negatively affect investment performance. Clients must inform us of any changes to their financial circumstances, investment objectives or risk tolerance, or of any modifications or restrictions that are imposed on the management of the client's account. In this manner, our firm can better serve clients' needs. On a case-by-case basis, we may also agree to provide non-discretionary asset management services where appropriate. For these services, we will receive a limited power of attorney to effect securities transactions on your behalf and we will continue to make investment recommendations based on your individualized investment strategy. However, unlike discretionary accounts, we would first be required to obtain your approval before executing transactions. Requests for approval will be communicated via electronic mail to an authorized account or via a telephone call to an authorized phone number. The client will be responsible for responding in a timely manner. Our services encompass asset management designed to assist clients in meeting their retirement financial goals using financial investments. We explore different types of investment options and strategies in the design of a client’s portfolio. Our investment recommendations are not limited by any specific product or service. Below is a list of commonly recommended investment vehicles.
• Exchange listed securities and over the counter traded securities
• Mutual funds
• Exchange-traded fund shares
• Commodities
• Separate accounts; and
• Money market funds and other cash instruments We will also provide advice regarding the following security types:
• Certificates of deposit
• Corporate debt securities
• Municipal securities
• U.S. governmental securities
• Variable (No-Load) annuity products
• Life Insurance Products Each type of security has its own unique set of risks associated with it, and it would not be possible to list all the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it. Because some types of investments involve certain additional degrees of risk, they will only be recommended and implemented when consistent with the client's risk tolerance, investment objectives, and where the investment is determined to be suitable. Financial Planning and Financial Consulting Services Our firm also provides financial planning and consulting services. Depending on your particular circumstance, such services could include a comprehensive evaluation of your financial situation by using currently known facts and variables, or it might focus on a few items of particular importance to you. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client's current situation, financial goals, and objectives. For financial consulting clients, we will usually not provide a written summary of our observations and recommendations, as the process is a less formal engagement. Regardless of the nature of the service, the implementation of all recommendations will be at the client's discretion. A financial plan or financial consultation will address one or more of the following areas:
• Financial Position: Understanding of a client's current financial situation.
• Investment Planning: Determining the most suitable

way to structure investments to meet financial goals, and determine the appropriate account type (e.g., joint tenants, IRA, Roth IRA, etc.).
• Personal Tax Planning: Evaluating the current tax situation to help minimize a client's taxes and find more profitable ways to use the extra income generated.
• Retirement Planning: Assessing retirement needs to help a client determine how much to accumulate, as well as distribution strategies designed to create a source of income during retirement years.
• Insurance Planning and Risk Management: Evaluating the client's insurance needs and reviewing insurance policies and the like.
• Estate Planning: Reviewing the client's cash needs at death, income needs of surviving dependents and estate planning goals.
• Charitable Planning: Providing strategic charitable giving plans for clients and researching and evaluating charitable entities and private foundations.
• Mortgage/Debt Analysis: Analyzing client's current mortgage debt, home equity, and financing alternatives.
• Review of Employee Benefit Plans: Reviewing the client's investment options, allocation models and historical performance of client assets held through employee benefit plans. We gather information at an initial vision meeting which includes interviews and a review of documents provided by the client. Information gathered includes the client's current financial status, future goals, investment objectives, risk tolerance and family circumstances. Typical financial planning or financial consultation services include one or more of each of the service components. A financial plan could require the services of a specialist such as an insurance specialist, attorney or tax accountant. We will recommend third-party service providers if we feel it is appropriate and in your best interest, but the client is under no obligation to use any service provider recommended by us. Likewise, the client is under no obligation to act on our financial planning recommendations. We do not receive referrals or other fees from third-party service providers. Our financial plans offer a high degree of personalization that matches your investments to your goals and ability to take on risk. We analyze each potential opportunity to find just the right ones for you, your family, and your goals, while also helping to maintain your liabilities so you can feel confident in your complete financial picture. Financial plans and consultations are based on the client's financial situation at the time we present the financial plan or consultation to the client, and on the information provided to us. The client must promptly notify us if his/her financial situation, goals, objectives or needs change. Certain assumptions are made with respect to interest rates, inflation rates, and use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. We do not offer any guarantees or promises that a client's financial goals will be met. Client Assets Under Management As of M a r c h 1, 2024. SMART Wealth had approximately $302,935,897 in assets under management, $288,785,831 of which was managed on a discretionary basis and approximately $14,150,066 of which was advised on a non-discretionary basis. Information Regarding Potential Conflicts of Interest Although we seek to avoid them, our firm has actual or potential conflicts of interest arising from our advisory services. These include, but are not limited to:
• Conflicts related to allocating time and resources between client accounts, allocation of brokerage commissions and investment opportunities generally. For further information on our brokerage and allocation policies, and related conflicts of interest, please refer to Item 12 below.
• Conflicts related to asset-based fees. At times our investment professionals will recommend that a client move assets from another investment account to one managed by our firm. This would result in a higher total advisory fee for that investment professional and generate revenue for the firm. There is therefore a conflict of interest whenever we encourage clients to move their assets to our firm. For further information, please refer to Item 5, which discusses the fees we earn when providing advisory services.
• Conflicts related to one or more of our investment advisor representatives also being licensed as an independent insurance agent through licensed insurance brokers. For further information, please refer to Item 10 below.
• Conflicts related to investing in securities recommended to clients and contemporaneous trading of securities (i.e., personal trading) by the firm and its related persons. Please refer to Item 11 for further information.
• Conflicts related to third parties. When appropriate, we will recommend third parties to advise a client on matters including but not limited to: legal, tax or accounting advice. These recommendations are sometimes made because of the existing relationships our firm and its employees have with these groups or individuals. We do not currently have any formal promoter or referral arrangements. Actual or potential conflicts of interest generally can be addressed in several ways, including prohibiting the conduct that gives to the conflict of interest, implementing procedures to prevent a person from gaining or utilizing knowledge that potentially give rise to a conflict; establishing parameters for conduct that are designed to protect client interests or limit the benefit that creates the conflict of interest, or disclosing the conflict of interest to our clients. Our firm has adopted a Code of Ethics. (Please refer to Item 11 below for further information on our Code of Ethics) and we also have policies and procedures in place to mitigate and address conflicts of interest. We believe that such policies and procedures are reasonably designed to treat clients equitably and to advance the best interests of the clients. The clients' best interest is paramount in any situation involving a conflict of interest.