A. Snyder Wealth Group (the “Registrant”) is a corporation formed on March 5, 1991, in the State of New York. The Registrant became registered as an Investment Adviser Firm with the U.S. Securities and Exchange Commission on March 5, 1991. The Registrant is principally owned by Mark J. Snyder, who also serves as the company’s President. B. As discussed below, the Registrant offers to its clients (individuals, business entities, trusts, estates and charitable organizations, pension and profit-sharing plans, etc.) discretionary investment advisory services and, to the extent specifically requested by the client, retirement consulting services. Registrant does not provide comprehensive financial planning or related consulting services. To the extent specifically requested by a client, Registrant may provide limited financial planning consulting services. Any such consultation services, to the extent rendered, shall be rendered exclusively on an unsolicited basis, for which Registrant may determine to charge a mutually agreed upon fixed or hourly separate fee. INVESTMENT ADVISORY SERVICES The client can determine to engage the Registrant to provide discretionary investment advisory services on a wrap or non-wrap fee basis as described at Item 5below. If a client engages the Registrant on a wrap fee basis the client will pay a single fee for bundled services (i.e. investment advisory, brokerage, custody). The services included in a wrap fee agreement will depend upon each client’s particular need. All wrap fee programs are provided by Osaic Wealth, Inc. (“Osaic”) subject to the terms and conditions of those wrap fee program agreements. If the client determines to engage the Registrant on a non-wrap fee basis the client will select individual services on an unbundled basis, paying for each service separately (i.e. investment advisory, brokerage, custody). The Registrant provides investment advisory services specific to the needs of each client. To commence the investment advisory process, Registrant will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, Registrant provides ongoing supervision of the account(s). Before engaging Registrant to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. NON-WRAP FEE BASIS The client can engage the Registrant to provide discretionary investment advisory services on a non-wrap fee basis. The Registrant’s annual investment advisory fee shall be based upon a percentage (%) of the market value and type of assets placed under the management as set forth in Item 5 below. Prior to engaging the Registrant to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with the Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and any fees that are due from the client prior to Registrant commencing services. VISION 2020 Wealth Management Program The Registrant offers individual portfolio management services to its advisory clients through the VISION2020 Wealth Management Program sponsored by and offered through Osaic Wealth, Inc. The Registrant will provide continuous advice to a client regarding the investment of client funds based on the client’s individual needs. Through personal discussions in which a client’s goals and objectives are established, the Registrant develops and manages a portfolio based on these objectives. We manage these advisory accounts on a discretionary basis. Clients may impose reasonable restrictions, in writing, on investing in certain securities, types of securities, or industry sectors. Participants in the VISION2020 Wealth Management Platform should refer to VISION2020 Wealth Management Corp.'s Firm Brochure and Wrap Fee Program Brochure (Part 2A of Form ADV) for additional information regarding the services and programs offered in this platform. The VISION 2020 Wealth Management Platform - Advisor Managed Portfolios Program The Wealth Management Platform – Advisor Managed Portfolios Program (“Advisor Managed Portfolios”) provides investment management of your assets through the application of asset allocation planning software as well as the provision of execution, clearing and custodial services. Advisor Managed Portfolios provides risk tolerance assessment, efficient frontier plotting, fund profiling and performance data, and portfolio optimization and re-balancing tools. Utilizing these tools and based on your responses to a risk tolerance questionnaire (“Questionnaire”) and discussions that we have together regarding, among other things, investment objective, risk tolerance, investment time horizon, account restrictions, and overall financial situation, we construct a portfolio of investments. This portfolio may consist of mutual funds, exchange traded funds, equities, options, debt securities, variable life, variable annuity sub-accounts (certain restrictions may apply) and other investments. Each portfolio is designed to meet your individual needs, stated goals and objectives. Additionally, you have the opportunity to place reasonable restrictions, in writing, on the types of investments to be held in the portfolio. Please Note: As indicated in the Vision2020 and Osaic Wrap Fee Program Disclosure Brochures, participation may cost more or less than purchasing such services separately. The fee charged by Registrant for participation may be higher or lower than those charged by other sponsors of comparable wrap fee programs along with brokerage and custodial services for a single, annual, asset-based advisory fee. Please Also Note: Since the custodian/broker-dealer is determined by the Program Sponsor, Registrant will be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, participants may pay higher commissions or other transaction costs or greater spreads or receive less favorable net prices on transactions for the account than would otherwise be the case through alternative clearing arrangements recommended by Registrant. Higher transaction costs adversely impact account performance. The Registrant’s Chief Compliance Officer, Mark J. Snyder, remains available to address any questions that a client or prospective client may have regarding participation in a wrap fee program. For additional Advisor Managed Portfolios details, please see the Advisor Managed Portfolios Wrap Fee Program Part 2A – Appendix 1 Disclosure Brochure. We provide this brochure to you prior to or concurrent with your enrollment in Advisor Managed Portfolios. Please read it thoroughly before investing. Wealth Management Platform - SMA and UMA Account Program The Wealth Management Platform – SMA and UMA Account Program (“Wealth Managed Account Program” or “WMAP”) provides clients the opportunity to invest their assets across multiple investment strategies and asset classes by implementing an asset allocation strategy. Sponsored by VISION2020 Wealth Management Corp. – an SEC-registered Investment Advisor (“Program Sponsor”), WMAP is a wrap account program that offers investment advisory services and planning. The Registrant will present the client with a WMAP asset allocation model (“WMAP Model”) for client approval which will consist of: (1) Certain investment managers available in the program that provide asset allocation services in mutual funds or exchange traded funds who have agreements directly with Vision 2020 Wealth Management Corp. (“Strategists”), or (2) Third Party Managers (“Third Party Managers”) who will manage client funds according to a particular equity or fixed income model or strategy, (Together the Strategist and Third Party Managers are referred to as “WMAP Investment Managers”) or (3) no-load mutual funds (“Funds”), or (4) exchange traded funds (“ETFs”) or any combination thereof (individually or collectively, “WMAP Investments”). WMAP Investments will be managed according to the selected WMAP Model. WMAP Models consist of a separately managed account or a series of separately managed accounts (collectively, “SMA Account”) or a unified managed account (“UMA Account”) as further described below. A WMAP Model will be suggested to the client based upon client responses to a risk tolerance questionnaire (“Questionnaire”) and/or discussion between Registrant and client regarding among other things, investment objective, risk tolerance, investment time horizon, account restrictions, and overall financial situation. WMAP clients enter into an advisory client agreement (“Client Agreement”) with Registrant, as adviser, and Program Sponsor as co-adviser. Registrant will monitor the client’s WMAP Investments on an ongoing basis. Registrant and client will be responsible for determining initial and ongoing suitability. Program Sponsor has entered into a sub-agreement with Envestnet Asset Management, Inc. (“Envestnet”). Envestnet will perform due diligence and provide research on WMAP Investment Managers, construct and recommend asset allocation targets to be used in WMAP Models and provide a password protected web site and associated technology to assist Registrant and client with the selection and adjustment of WMAP Models. Additional Program Sponsor services are disclosed in the Client Agreement SMA Account: An SMA Account may contain one or multiple WMAP Investment Managers with each WMAP Investment Manager investing according to a specific model or strategy and each in their own custodial account. The SMA account may also contain Funds, generally used to compliment the WMAP Investment Managers employed within the SMA Model and when the recommended allocation to an asset class is too small for a WMAP Investment Manager to manage. After discussion with the client and after the relevant information is processed, WMAP provides an asset allocation model which consists of asset allocation targets or sleeves across various asset classes and investment strategies. Registrant and the client complete the SMA Account by choosing which WMAP Investment Managers and Funds will be contained within each asset allocation sleeve. Upon suitability determinations made by Registrant and the client, Registrant may adjust the aforementioned asset allocation targets, within predetermined limits. UMA Account: A UMA Account may contain one or multiple WMAP Investment Managers with each WMAP Investment Manager investing according to a specific model or strategy. The UMA Account may also contain Funds and ETFs. Unlike the SMA Account, all WMAP Investment Manager Funds and ETFs will be held in a single custodial account. Overlay management can be provided to coordinate the trading activities of UMA Third Party Managers, rebalancing and to provide greater tax-efficiency. After discussion with the client and after the relevant information is processed, WMAP provides an asset allocation model which consists of asset allocation targets or sleeves across various asset classes and investment strategies. Registrant and the client complete the UMA Account by choosing which WMAP Investment Managers, Funds and ETFs will be contained within each asset allocation sleeve. Upon suitability determinations made by Registrant and client, Registrant may adjust the aforementioned asset allocation targets or create its own asset allocation model within predetermined limits. All WMAP Investments will be held by the custodian designated in a customer agreement provided to client. The custodian will also serve as broker-dealer for securities transactions directed by WMAP Investment Managers. Clients will be charged an annual fee based upon the value of the Program assets they have under management which covers management, administrative and transaction costs (“Account Fee” or “Wrap Fee”). Depending upon the level of the Account Fee, the amount of portfolio activity in your Account, the value of custodial and other services provided under the Program and other factors, the Wrap Fee may or may not exceed the aggregate cost of such services if they were to be provided to you separately. Participation in a wrap fee program may cost more or less than purchasing such services separately. Please Also Note: Since the custodian/broker-dealer is determined by the Program Sponsor, Registrant will be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, participants may pay higher commissions or other transaction costs or greater spreads or receive less favorable net prices on transactions for the account than would otherwise be the case through alternative clearing arrangements recommended by Registrant. Higher transaction costs adversely impact account performance. The Registrant’s Chief Compliance Officer, Mark J. Snyder, remains available to address any questions that a client or prospective client may have regarding participation in a wrap fee program. For further SMA and UMA Program details please see the SMA & UMA Program Brochure. The Registrant provides this brochure to clients or prospective client prior to or concurrent with their enrollment in the SMA/UMA Program. Clients should read the brochure thoroughly before engaging. Any Questions: Registrant’s Chief Compliance Officer, Mark J. Snyder, remains available to answer any questions a client or prospective client may have regarding any of the above Wrap Fee Programs. Please Note: Clients should always refer to the appropriate Wrap Fee Program Form ADV 2A Brochure – Appendix 1 for more detailed information regarding the Wrap Fee Program and its fees. RETIREMENT PLANNING AND CONSULTING To the extent specifically requested by client, Registrant may provide its clients with retirement planning consulting services. Registrant will charge a fee (fixed fee and/or hourly) for these services. Registrant’s consulting fees are negotiable depending upon the level and scope of service(s) required and the professional rendering the service(s). Prior to engaging the Registrant to provide retirement planning services, the client will be required to enter into a Retirement Planning and Consulting Agreement with Registrant setting forth the terms and conditions of the engagement and describing the scope of the services to be provided. In the event the client terminates Registrant’s consulting services, the balance of any unearned fee shall be refunded to the client. In performing its services, Registrant shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. If requested by the client, Registrant shall recommend the services of other professionals for implementation purposes, including Registrant’s President, Mark J. Snyder and/or other investment adviser representatives (“IARs”), in their separate individual licensed capacities as registered representatives of Osaic Wealth, Inc. ("Osaic"), an SEC registered and FINRA member broker- dealer and/or as licensed insurance agents (See disclosure below at Item 10. C.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. Please Also Note: If the client engages any professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not the Registrant, shall be responsible for the quality and competency of the services provided. Clients are encouraged to renew Registrant’s retirement planning services engagement on an annual basis for the purpose of reviewing/updating Registrant’s previous recommendations and/or services. Moreover, each client is advised that it remains their responsibility to promptly notify the Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Registrant’s previous recommendations and/or services. Please Also Note: Conflict of Interest: The recommendation by a Registrant’s IAR that a client purchase a securities or insurance commission product from once of Registrant’s IARs in his/her individual capacity as a registered representative of Osaic and/or as an insurance agent, presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any securities or insurance commission products from any of Registrant’s IARs. Clients are reminded that they may purchase securities and insurance products recommended by Registrant through other, non-affiliated broker- dealers and/or insurance agents. EMPLOYER SPONSORED RETIREMENT PLAN ALLOCATION SERVICES The Registrant also provides pension consulting services, pursuant to which it assists sponsors of self-directed retirement plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, the Registrant shall also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement shall generally be set forth in a Retirement Plan Consulting Agreement between the Registrant and the plan sponsor. Personalized investment advice may be provided to plan participants regarding their plan assets. Plan participants who wish to engage the Registrant for individualized financial planning or consulting services regarding assets outside the scope of the qualified plan may do so by executing a separate written agreement, including separate fees. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by the client, Registrant may, in limited circumstances, provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Please Note: We do not serve as an attorney or accountant, and no portion of our services should be construed as same. Accordingly, we do not prepare estate planning documents or tax returns. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.), including IARs of Registrant in their separate individual capacities as registered representatives of Osaic Wealth, Inc (“Osaic”) and / or as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Registrant and/or its representatives (see Item 10. C. below). Please Note: If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not the Registrant, shall be responsible for the quality and competency of the services provided. Please Also Note-Conflict of Interest: The recommendation by a Registrant representative that a client purchase a securities or insurance commission product from once of Registrant’s representatives in his/her individual capacity as a representative of Osaic and/or as an insurance agent, presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any securities or insurance commission products from any of Registrant’s representatives. Clients are reminded that they may purchase securities and insurance products recommended by Registrant through other, non-affiliated broker-dealers and/or insurance agents. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Mark J. Snyder, remains available to address any questions that a client or prospective client may have regarding the above conflicts of interest Variable Annuity Management. The Registrant may be engaged to allocate client investment assets on a discretionary basis among the investment sub accounts of variable annuity

products previously purchased by the client. The Registrant manages the variable annuity on a tactical investment strategy basis, the objective of which is to be invested in the equity market during an anticipate uptrend and in cash during an anticipated pullback/correction. Of course, there can be no assurance or guarantee that the Registrant’s market decisions will be correct or profitable. The Registrant includes the variable product assets as part of “assets under management” for the purposes of calculating its annual advisory fee. In the event that the variable product is sold on a commission basis by one of the Registrant’s IARs in his/her individual capacity as a registered representative of Osaic, and the client thereafter determines to engage the Registrant to manage the product by allocating among the investment subdivisions, the Registrant’s management fee shall be waived. No client is under any obligation to purchase a variable product from the Registrant’s representatives. The offer and sale of such a commission product presents a conflict of interest (Please see disclosure in Item 5E below). Retirement Rollovers-Conflict of Interest: 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 the Registrant recommends that a client roll over their retirement plan assets into an account to be managed by the Registrant, such a recommendation creates a conflict of interest if the Registrant will earn new (or increase its current) compensation as a result of the rollover. Whether Registrant provides a recommendation as to whether a client should engage in a rollover or not, Registrant is acting as a fiduciary 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. No client is under any obligation to rollover retirement plan assets to an account managed by Registrant. Registrant’s Chief Compliance Officer, Mark J. Snyder, remains available to address any questions that a client or prospective client may have regarding the conflict of interest presented by such rollover recommendation. Independent Managers. Registrant may allocate a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) or separately managed accounts in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) will have day-to-day responsibility for the active discretionary management of the allocated assets, including, to the extent applicable, proxy voting responsibility. Registrant shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors that Registrant shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Please Note. The investment management fee charged by the Independent Manager[s] is separate from, and in addition to, Registrant’s investment advisory fee disclosed at Item 5 below. The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, Registrant’s advisory fee as set forth in Item 5. Use of Mutual and Exchange Traded Funds. Registrant utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Registrant’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Registrant will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Registrant determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Registrant will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by the Registrant will be profitable or equal any specific performance level(s). Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of the Registrant. Generally, with potential exceptions, the Registrant does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the replacement securities purchased by the Registrant will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by the Registrant) will be profitable or equal any specific performance level(s)In addition, there may be other securities and/or accounts owned by the client for which the Registrant does not maintain custodian access and/or trading authority; and,
• hold other securities and/or own accounts for which the Registrant does not maintain custodian access and/or trading authority. Corresponding Services/Fees: When agreed to by the Registrant, the Registrant shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent;(3) shall generally consider these securities as part of the client’s overall asset allocation; and, (4) report on such securities/accounts as part of regular reports that may be provided by the Registrant; and, (5) include the market value of all such securities for purposes of calculating advisory fee. Cash Positions. Registrant continues to treat cash as an asset class. As such, unless determined to the contrary by Registrant, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Registrant’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Registrant may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Registrant’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Mark J. Snyder, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Registrant generally recommends that Osaic or Pershing serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Osaic and Pershing charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark- ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Osaic and Pershing, do not currently charge fees on individual equity transactions, others do). When beneficial to the client, individual fixed‐income and/or equity transactions may be effected through broker‐dealers with whom Registrant and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by Osaic and Pershing). These fees/charges are in addition to Registrant’s investment advisory fee at Item 5 below. Registrant does not receive any portion of these fees/charges. Exception: if Registrant executes transactions in conjunction with a wrap program, transaction fees shall generally be included in the wrap advisory fee paid to the wrap program sponsor. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Mark J. Snyder, remains available to address any questions that a client or prospective client may have regarding the above. Please Note: Non-Discretionary Service Limitations. Clients that determine to engage Registrant on a non-discretionary investment advisory basis must be willing to accept that Registrant cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Registrant would like to make a transaction for a client’s account, and client is unavailable, Registrant will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Legacy Positions. If a client transfers in legacy securities (i.e., securities that the client purchased before and/or independent of the Registrant) to be managed by the Registrant, then Registrant shall supervise such legacy securities, and the market value of all such securities shall be included as part of assets under management for purposes of calculating the Registrant’s advisory fee. In the case of former LIFA clients, the applicable fee schedule will be the legacy LIFA fee schedule unless otherwise agreed to, in writing, between Registrant and legacy LIFA client. Cybersecurity Risk. The information technology systems and networks that Registrant and its third-party service providers use to provide services to Registrant’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Registrant’s operations and result in the unauthorized acquisition or use of clients’ confidential or non- public personal information. Clients and Registrant are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Registrant has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that Registrant does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. ESG: We don’t have or recommend a strategy: Please Note: Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Registrant), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Registrant does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. If implemented, Registrant shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. WE DON’T RECOMMEND Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, the Registrant, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services, but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, the Registrant will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please Note: The Registrant does not recommend or advocate the purchase of, or investment in, cryptocurrencies. The Registrant considers such an investment to be speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Reporting Services. Registrant can also provide, for a separate fee, account reporting services, which can incorporate client investment assets that are not part of the assets that Registrant manages (the “Excluded Assets”). Unless agreed to otherwise, the client and/or his/her/its other advisors that maintain trading authority, and not Registrant, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless also agreed to otherwise, Registrant does not provide investment management, monitoring or implementation services for the Excluded Assets. If the Registrant is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and Registrant shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client can engage Registrant to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between Registrant and the client.
• emoney. In the event that the Registrant provides the client with access to an unaffiliated vendor’s website such as emoney, and the site provides access to information and/or concepts, including financial planning, the client, should not, in any manner whatsoever, infer that such access is a substitute for services provided by the Registrant. Rather, if the client utilizes any such content, the client does so separate and independent of the Registrant. Client Obligations. In performing its services, Registrant shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify the Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Registrant’s previous recommendations and/or services. Disclosure Statement. A copy of the Registrant’s written Privacy Notice, Disclosure Brochure as set forth on ADV Part 2A and ADV Part 2B, ADV Part 2A Appendix 1 (as applicable) and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement and/or Retirement Planning and Consulting Agreement. C. The Registrant shall provide investment advisory services specific to needs of each client. Prior to providing investment advisory services, an investment adviser representative will discuss with each client, their particular investment objective(s). The Registrant shall allocate each client’s investment assets consistent with their designated investment objective(s). Clients may, at any time, impose restrictions, in writing, on the Registrant’s services. D. Wrap / Separately Managed Account Programs: In the event that Registrant is engaged to provide investment advisory services as part of an unaffiliated wrap-fee program, Registrant will be unable to negotiate commissions and/or transaction costs. Under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the participant more or less than purchasing such services separately. In the event that Registrant is engaged to provide investment advisory services as part of an unaffiliated managed account program, Registrant will likewise be unable to negotiate commissions and/or transaction costs. The program sponsor will determine the broker-dealer though which transactions must be effected, and the amount of transaction fees and/or commissions to be charged to the participant investor accounts. Please Note: In these type of engagements, the unaffiliated investment advisers that engage Registrant's services shall maintain both the initial and ongoing day-to-day relationship with the underlying investor, including initial and ongoing determination of the of the investor’s suitability for Registrant's designated investment strategies. Since the custodian/broker-dealer is determined by the unaffiliated wrap and/or managed account program sponsor, Registrant will be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, clients may pay higher commissions or other transaction costs or greater spreads or receive less favorable net prices on transactions for the account than would otherwise be the case through alternative clearing arrangements recommended by Registrant. Higher transaction costs adversely impact account performance. The Registrant’s Chief Compliance Officer, Mark J. Snyder, remains available to address any questions that a client may have regarding participation in a wrap fee program. Please Note: When managing a client’s account on a wrap fee basis, the Registrant shall receive payment for its investment advisory services from Osaic in accordance with the respective wrap fee brochure, and the balance of the wrap fee shall be retained by Osaic as the sponsor to cover all other costs and fees discussed in Osaic’s Wrap Fee Brochure. E. As of December 31, 2023, the Registrant had $345,487,200 in assets under management on a discretionary.