Description of Services and Fees WealthTrak Capital Management, LLC ("WealthTrak") is a registered investment adviser based in Virginia Beach, Virginia. We primarily operate under the name WealthTrak Advisors ("WealthTrak"). We are organized as a limited liability corporation under the laws of the State of Virginia. We have been providing investment advisory services since 2012. R. Chris Whited and Tracy W. Whited are our firm's principal owners. Currently, we offer the following investment advisory services, which are personalized to each individual Client:
• Portfolio Management Services
• Financial Planning Services
• Advisory Consulting Services
• Selection of Other Advisers
• Sub-advisory Services
• Pension Consulting The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this Brochure, the words "we", “our” and “us” refer to WealthTrak, and the words “you”, “your” and “client” refer to you as either a client or prospective Client of our firm. Portfolio Management Services We offer discretionary portfolio management services where our investment advice is tailored to meet our Client’s needs and investment objectives. Discretionary accounts are offered through our Managed Portfolio Program and Managed Variable Insurance Program. See below for more information regarding these programs. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information at the beginning of our advisory relationship. We will use the information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice to make investments on your behalf. As part of our portfolio management services, we may customize an investment portfolio for you according to your risk tolerance and investing objectives, or we may invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you or select a WealthTrak model portfolio, we will monitor your portfolio’s performance on an ongoing basis and rebalance the portfolio as required by changes in the market conditions and in your financial circumstances. We will require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities and the amount of securities to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. Managed Portfolio Program ("MPP") We are a portfolio manager and sponsor of the Managed Portfolio Program (MPP). The MPP is a discretionary investment program that provides clients access to several money managers and/or our firm’s proprietary managed portfolios. The overall cost you will incur if you participate in the MPP may be higher or lower than you might incur by separately purchasing the types of securities available in the program. Managed Variable Insurance Program ("MVIP") We offer discretionary portfolio management services for certain variable insurance products where our investment advice is tailored to meet our Client’s needs and investment objectives. Financial Planning Services We offer financial planning services, which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based on an analysis of their individual needs. These services can range from broad, comprehensive, financial planning to consultative or single subject planning. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation when we present the plan to you and on the financial information you provide us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. Advisory Consulting Services We offer consulting services that primarily involve advising clients on specific financial-related topics. The topics we address may include, but are not limited to, risk assessment/management, investment planning, financial organization, or financial decision making/negotiation. Automated Retirement Asset Allocation Services We may recommend that you use the services of Howard Capital Management, Inc. ("HCM") to provide assistance to plan participants who are seeking advice in choosing and allocating investments within their 401(k) or similar defined contribution plan. Based on the information submitted, HCM will provide recommendations that are personally designed for your particular investment goals. The recommendations will include advice on which investments to select to properly diversify your portfolio, as well as an asset allocation strategy. HCM will continuously monitor your investments and will update its recommendations at least

quarterly. In some cases, HCM's recommendations may not change from the previous quarter, but this does not mean your investment options were not analyzed. HCM may also make additional recommendations when indicated by the HCM-BuyLine®, a proprietary indicator that signals when and how much to invest in equities. All recommendations and correspondence will be communicated via e-mail and the HCM website. You should review the Form ADV Part 2A Disclosure Brochure for HCM for more information. 401(k) Management Services - HCM 401(k) Optimizer® The HCM 401(k) Optimizer® service is designed to assist employees in choosing and allocating investments of assets held in a 401(k) plan. Thrift Savings Plan Management - "TSP Navigator" The HCM TSP Navigator service is designed to assist federal employees in choosing and allocating investments of assets held in a Thrift Savings Plan. Selection of Other Advisers We may recommend that you use the services of a third-party money manager ("MM") to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific MM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the MM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the MM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives. The MM(s) will actively manage your portfolio and will assume discretionary investment authority over your account. We will assume discretionary authority to hire and fire MM(s) and/or reallocate your assets to other MM(s) where we deem such action appropriate. Sub-advisory Services We may offer sub-advisory services to unaffiliated third-party money managers (the “Primary Investment Adviser”). As part of these services, we will provide model portfolios, which the Primary Investment Adviser selects for their clients. We will not directly manage the Primary Investment Adviser’s individual client accounts. The Primary Investment Adviser will be responsible for selecting the appropriate model for its clients. Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services may be either discretionary or non-discretionary. If non-discretionary, the ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. We may also assist with participant enrollment meetings and provide investment-related educational media to plan participants on such topics as:
• Diversification;
• Asset allocation;
• Risk tolerance; and
• Time horizon Our educational materials may include other investment-related topics specific to the particular plan. We may also provide additional types of pension consulting services to plans on an individually negotiated basis. These services may include but are not necessarily limited to discretionary portfolio management of the plan assets. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. Either party to the pension consulting agreement may terminate the agreement upon written notice to the other party in accordance with the terms of the agreement for services. The pension consulting fees will be prorated for the quarter in which the termination notice is given and any unearned fees will be refunded to the Client. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your 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 your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Types of Investments We offer advice on equity securities, fixed income securities, separately managed accounts, exchange traded fund shares, mutual funds, and variable insurance product sub-accounts. Assets Under Management As of March 8, 2024, we manage $137,934,693 in client assets on a discretionary basis and $2,698,300 on a non-discretionary basis.