Halbert Wealth is an SEC registered Investment Advisory firm founded in 1995 by Gary and Debi Halbert. Halbert Wealth provides advisory services to clients in nearly all 50 states. Halbert Wealth is 100% owned by Gary D. Halbert. We categorize our business into three main groups: AdvisorLink, Managed Strategies and the HWM Alpha Advantage Strategy. We focus on programs and strategies that feature active money management and some type of risk management. We also offer select individual mutual funds on a limited basis. Halbert Wealth’s advice is primarily limited to recommendations concerning the products we offer. For AdvisorLink, Halbert Wealth researches and evaluates the performance of third party Investment Advisors and recommends or refers clients to them. These Investment Advisors direct client assets into various mutual funds, including stock and bond funds, or they may invest directly in stocks, bonds, Exchange Traded Funds (“ETFs”), options and other securities. They use active management strategies, such as tactical management and sector rotation. Managed Strategies programs invest clients in one or more active management strategies, limited partnerships, Business Development Companies (“BDC”), mutual funds, stocks, Interval Funds, REITs or other investments based on the needs and goals of the client. These are managed by one or more underlying Advisors, Sub-Advisors, General Partners or other managers. Unlike AdvisorLink where we recommend or refer clients to various strategies, with Managed Strategies we have discretion over a client account to add or replace strategies, partnerships, BDCs, Interval Funds, REITs, mutual funds or other investments as needed. The HWM Alpha Advantage Strategy invests in long and short leveraged mutual funds and is actively managed by a Sub-Advisor. The Sub-Advisor utilizes a variety of market signals in combination with the goal of capitalizing on investment opportunities in up or down markets. The strategy also seeks to manage overall risk through this combination. Before a prospective client invests in any of our programs, they will be asked to complete a Confidential Investor Profile (the “Profile”) and provide other requested information as needed to help determine their suitability in selected investments. For AdvisorLink, Managed Strategies and the HWM Alpha Advantage Strategy, clients should refer to the ADV Part 2 or other additional offering materials for more information on the underlying Advisors, Sub-Advisors, General Partners or other money managers for each particular investment program. The recommendation of programs is based on each client’s individual needs, financial goals and risk tolerance. The

goal is to help the client build an investment portfolio that best suits their particular situation. Certain client restrictions may be placed on the programs or securities the client invests in, depending on the type of program, and any limitations the individual Investment Advisor managing the money may have. In Managed Strategies, Halbert Wealth selects investments from an approved list based on the perceived needs of the client. If a client invests in mutual funds, no restrictions are generally allowed at the fund level since mutual funds usually do not allow investors to put restrictions on their investments with them. However, a client can put restrictions on funds to be purchased. Limited partnerships, REITs and interval funds may also not allow investors to place restrictions on their investments. Our assets under management are split between discretionary and non-discretionary assets. Managed Strategies and the HWM Alpha Advantage Strategy accounts are considered discretionary accounts because Halbert Wealth directly manages client assets or selects one or more underlying Managers, Sub-Advisors, limited partnerships, BDCs, interval funds, REITs, mutual funds or other investments to manage the assets. AdvisorLink accounts are considered non-discretionary accounts, because the client selects the strategies and third-party Investment Advisors to manage their assets, usually based on recommendations from us. Written Acknowledgement of Fiduciary Status 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. As of December 31, 2023, the approximate total assets under management are: Discretionary $0 Non-Discretionary $69,076,616