Arbor Private Wealth offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to Arbor Private Wealth rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Arbor Private Wealth setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Arbor Private Wealth filed for registration as an investment adviser in August 2021 and is owned by Eric C. Showalter as of October 1, 2021. As of December 31, 2023, Arbor Private Wealth had $151,870,891 of assets under management; $115,098,306 of which was managed on a discretionary basis and $36,773,083 of which was managed on a non-discretionary basis. While this brochure generally describes the business of Arbor Private Wealth, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on Arbor Private Wealth’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services Arbor Private Wealth offers clients a broad range of financial planning and consulting services, which include any or all of the following functions:
• Trust and Estate Planning
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Social Security Withdrawal Planning
• Education Planning While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, Arbor Private Wealth is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Arbor Private Wealth recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Arbor Private Wealth or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding Page | 5 © MarketCounsel 2024 implementation and are under no obligation to act upon any of the recommendations made by Arbor Private Wealth under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Arbor Private Wealth’s recommendations and/or services. Investment and Wealth Management Services While clients can engage Arbor Private Wealth to provide investment management only services, the Firm generally provides clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. Arbor Private Wealth primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”) and individual debt and equity securities in model portfolios in accordance with their stated investment objectives. The Firm will also recommend the independent investment managers (“Independent Managers”) to certain clients. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Arbor Private Wealth to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Arbor Private Wealth directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider.

In these situations, the Firm’s fee can be collected by the custodian and paid to the Firm. Arbor Private Wealth tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Arbor Private Wealth consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Arbor Private Wealth if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Arbor Private Wealth determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Page | 6 © MarketCounsel 2024 Consulting Services to/through DPL Financial Partners for Commission-Based Annuities The Firm can provide advice to clients regarding their variable annuities and/or insurance policies through a relationship with DPL Financial Partners, LLC (“DPL”). DPL engages the Firm to advise the client on the investment of the subaccounts amongst the various options available. The services are provided to DPL for customers (“Brokerage Customers”) who provide written consent requesting to receive the Firm’s consulting services. The Firm only provides these services to clients that have signed an Advisory Agreement with the Firm and have consented to such with DPL. Retirement Plan Consulting Services Arbor Private Wealth provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Arbor Private Wealth as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Arbor Private Wealth’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Use of Independent Managers As mentioned above, Arbor Private Wealth selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Arbor Private Wealth evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers Page | 7 © MarketCounsel 2024 themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Arbor Private Wealth also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Arbor Private Wealth continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Arbor Private Wealth seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests.