Stronghold Wealth Management, LLC. is a state-registered investment adviser with its principal place of business located in Florida. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• Keith Downey
• Richard Alley Stronghold Wealth Management offers the following advisory services to our clients: PORTFOLIO MANAGEMENT Our firm provides discretionary portfolio management to clients regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a client portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. We do not limit our advice to any particular investments or investment strategies. Envestnet Envestnet Asset Management, Inc. (Envestnet) is an investment management company based in Chicago, Illinois. Envestnet’s platform provides Stronghold’s clients with access to portfolio management services through independent investment advisers as well as institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations. Envestnet provides our firm with an extensive range of services through its Private Wealth Management programs, including Separately Managed Accounts, Mutual Fund Solutions, ETF Solutions, Unified Managed Account, Multi-Manager Account, Manager Blends, ETF Portfolios, Enhanced Portfolio Strategies and PMC Ultra Short-Term Fixed Income Portfolio (each a “Program” and collectively “Programs”). Envestnet reviews the investment strategies and performance of a wide range of sub- managers and model providers then selects and monitors the approved sub-managers that make investment decisions. Envestnet evaluates managers specializing in each of the asset categories listed, including equities (both domestic and foreign); corporate debt; commercial paper; certificates of deposit; municipal securities; mutual funds; real estate investment trusts; government securities; options; and futures. Depending upon the model or strategy chosen by the client, a portfolio may typically hold between 5 and 250 securities. Selection of Other Advisors In addition to Envestnet, Stronghold may refer clients to other Advisors. Stronghold will retain discretionary authority to terminate the client’s relationship with the other adviser. All selected advisors will be appropriately registered. Stronghold Investment Portfolio Service Stronghold clients have the option of participating in our firm’s Wrap Fee Program, which has been designed to simplify the payment of management fees and brokerage expenses. Under this program, Stronghold pays the transaction/execution costs associated with securities trading in client accounts managed by Stronghold. This program poses a significant conflict of interest for Stronghold since it presents a disincentive for our firm to trade securities in the client account. Please see Part 2A Appendix 1 of our Form ADV (the “W ra p F e e Pr og r a m Br o ch u r e ”) f o r

more information. PENSION CONSULTING Stronghold Wealth Management works with the Third Party Administrator and the Retirement Plans (RP) to review the investment options available to the RP. Stronghold will obtain quotes or proposals from plan administrators for Client to review, recommend investment options to be included in the Plan, assist in monitoring investment options in the Plan and assist in ongoing education to Plan participants as allowed by Client. Once the RP’s investments are selected, the TPA will execute any transactions and clear the accounts. Stronghold, on a periodic basis, will review reports and information generated from the TPA to assist the RP Sponsor/Trustee in monitoring and evaluating the RP’s investment alternatives. FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability and long-term care.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes and elder law. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant and insurance agent. Implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, if contracted for, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. Assets Under Management As of 12/31/2023, our firm managed discretionary assets totaling $136,009,181.