BALBOA WEALTH PARTNERS, INC.

Balboa Wealth Partners, Inc. Form ADV Part 2A – Disclosure Brochure Effective: March 21, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Balboa Wealth Partners, Inc. (“Balboa Wealth” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at 949-445-1465. Balboa Wealth is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Balboa Wealth to assist you in determining whether to retain the Advisor. Certain Advisory Persons of Balboa Wealth provide advisory services under a practice name or “doing business as” name. However, advisory services are engaged exclusively through Balboa Wealth. Additional information about Balboa Wealth and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 282329. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 https://balboawealth.com/  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Balboa Wealth. Balboa Wealth believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Balboa Wealth encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on 02/08/2024: • The Advisor has added disclosure to Item 4 regarding the affiliation between Balboa Wealth and Axxcess Wealth Management, LLC. Please see Item 4 for more details. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 282329. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 949-445-1465. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 2 https://balboawealth.com/  Item 3 – Table of Contents Item 1 – Cover Page 1 Item 2 – Material Changes....................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................... 3 Item 4 – Advisory Services ..................................................................................................................................... 4 A. Firm Information .............................................................................................................................................................. 4 B. Advisory Services Offered ............................................................................................................................................... 4 C. Client Account Management ........................................................................................................................................... 7 D. Wrap Fee Programs ........................................................................................................................................................ 7 E. Assets Under Management ............................................................................................................................................. 7 Item 5 – Fees and Compensation ........................................................................................................................... 7 A. Fees for Advisory Services.............................................................................................................................................. 7 B. Fee Billing........................................................................................................................................................................ 9 C. Other Fees and Expenses ............................................................................................................................................ 10 D. Advance Payment of Fees and Termination ................................................................................................................. 10 E. Compensation for Sales of Securities ........................................................................................................................... 11 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................. 11 Item 7 – Types of Clients....................................................................................................................................... 12 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 12 A. Methods of Analysis ...................................................................................................................................................... 12 B. Risk of Loss ................................................................................................................................................................... 13 Item 9 – Disciplinary Information ......................................................................................................................... 15 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 15 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 16 A. Code of Ethics ............................................................................................................................................................... 16 B. Personal Trading with Material Interest ......................................................................................................................... 16 C. Personal Trading in Same Securities as Clients ........................................................................................................... 16 D. Personal Trading at Same Time as Client .................................................................................................................... 16 Item 12 – Brokerage Practices ............................................................................................................................. 17 A. Recommendation of Custodian[s] ................................................................................................................................. 17 B. Aggregating and Allocating Trades ............................................................................................................................... 17 Item 13 – Review of Accounts .............................................................................................................................. 18 A. Frequency of Reviews ................................................................................................................................................... 18 B. Causes for Reviews ...................................................................................................................................................... 18 C. Review Reports ............................................................................................................................................................. 18 Item 14 – Client Referrals and Other Compensation ......................................................................................... 18 A. Compensation Received by Balboa Wealth .................................................................................................................. 18 B. Compensation for Client Referrals ................................................................................................................................ 19 Item 15 – Custody .................................................................................................................................................. 19 Item 16 – Investment Discretion ........................................................................................................................... 20 Item 17 – Voting Client Securities ........................................................................................................................ 20 Item 18 – Financial Information ............................................................................................................................ 20 Privacy Policy......................................................................................................................................................... 21 Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 3 https://balboawealth.com/  Item 4 – Advisory Services A. Firm Information Balboa Wealth Partners, Inc. (“Balboa Wealth” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Corporation under the laws of the State of Delaware. Balboa Wealth was founded in December 2015 and is owned and operated by Jeffrey Gilbert (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Balboa Wealth. Certain Advisory Persons market and deliver advisory services under a practice name or “doing business as”, whose names and logos may appear on marketing materials as approved by Balboa Wealth, or client statements approved by the custodian. It is important to note that the businesses are legal entities of the Advisory Persons and not Balboa Wealth, nor the custodian. However, advisory services are engaged exclusively through Balboa Wealth. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Balboa Wealth. For questions regarding this Disclosure Brochure, please contact Jeffrey Gilbert at 949- 445-1465. B. Advisory Services Offered Balboa Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations, businesses, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Balboa Wealth's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Comprehensive Portfolio Management Balboa Wealth provides Clients with comprehensive portfolio management services, which generally includes a broad range of comprehensive financial planning and consulting services in connection with discretionary and non- discretionary management of investment portfolios. These services are described below. Asset Management Services Balboa Wealth provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary asset management and related advisory services. Balboa Wealth works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Balboa Wealth will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Balboa Wealth’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Balboa Wealth will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Balboa Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Balboa Wealth may recommend, on occasion, redistributing investment allocations to diversify Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 4 https://balboawealth.com/  the portfolio. Balboa Wealth may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Balboa Wealth may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Balboa Wealth accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers Balboa Wealth will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Client’s investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Use of Sub-Advisors – Balboa Wealth may recommend and refer Clients to unaffiliated turnkey asset management programs (“TAMPs”) at Balboa Wealth’s discretion or the Client’s request. The Advisor has a relationship with the SEC registered RIA Axxcess Wealth Management, LLC (“Axxcess”), which offers TAMP services. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the TAMP that defines the terms in which the TAMP will provide its services. Balboa Wealth will remain the Client’s primary Advisor and oversee the Client’s investment allocation[s] and overall investment performance. While the TAMP will assume day-to-day investment management of the assets, Balboa Wealth will be responsible for establishing the Client’s investment objectives and recommending a TAMP’s investment strategy to meet those objectives. The Client will be provided with the Sub-Advisor’s or TAMP’s Form ADV Part 2A (or a brochure that makes the appropriate disclosures). The billing methodology when Clients are referred to Axxcess is specified in Item 5A. Axxcess Wealth Management, LLC provides sub-advisory services to assist us with the management of accounts through our Asset Management services. Therefore, we will recommend to clients the use of Axxcess to help manage Account(s) or a portion of the assets of Account(s). Your agreement with Balboa Wealth will include the authorization to utilize Axxcess. Axxcess provides Balboa Wealth with investment management and “back-office” (i.e. administrative and operational services) functions that include but are not limited to technology platforms to support data reconciliation, Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 5 https://balboawealth.com/  performance reporting, client database maintenance, quarterly performance evaluations, models, trading platforms, and other functions related to the administrative tasks of managing client accounts. They also make available and provide access to sub-advisers available on their respective platforms. A complete description of Axxcess respective services, practices and fees are provided in their respective Form ADV Part 2A brochure, a copy of which will be provided to you if they are utilized to assist in the management of your Account. Participant Account Management (Pontera) As part of the Advisor’s Asset Management Services, when appropriate, the Advisor will use a third-party platform, Pontera Solutions, Inc. (“Pontera”), to facilitate management of held away assets such as defined contribution plan participant accounts, with investment discretion. The platform enables the Advisor to gain access to Client account without having access through the Client’s credentials. This independent advisor access ensures that the Advisor will not have custody of Client funds or securities when implementing trades for the Client. The Advisor is not affiliated with the platform in any way and receives no compensation from the platform. A link will be provided to the Client allowing them to connect their account[s] to the platform for the Advisor’s secure access. Financial Planning Services Balboa Wealth will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Balboa Wealth may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Consulting Services Balboa Wealth provides 3(21) retirement plan consulting services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: ∙ Investment Policy Statement (“IPS”) Design and Monitoring ∙ Ongoing Investment Recommendation and Assistance Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 6 https://balboawealth.com/  ∙ Performance Reporting These services are provided by Balboa Wealth serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Balboa Wealth’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Balboa Wealth does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). C. Client Account Management Prior to engaging Balboa Wealth to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – Balboa Wealth, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – Balboa Wealth will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. ● Portfolio Construction – Balboa Wealth will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – Balboa Wealth will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs For certain Clients, Balboa Wealth includes, in addition to securities transaction fees (herein “Covered Costs”) together with its investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor sponsors the Balboa Wealth Partners, Inc. Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Balboa Wealth’s Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of December 31, 2024, Balboa Wealth manages $804,833,455 in Client assets, $785,486,265 of which are managed on a discretionary basis and $19,347,455 on a non-discretionary basis. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements/a written agreement with the Advisor. A. Fees for Advisory Services Comprehensive Portfolio Management Comprehensive portfolio management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment advisory agreement. Asset management fees are based on the market value of assets under management at the end of the prior calendar quarter. Asset management fees are based on the following schedule: Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 7 https://balboawealth.com/  Annual Rate (%) Assets Under Management ($) *$0.00 to $249,999.99 $250,000 to $499,999.99 $500,000 to $749,999.99 $750,000 to $999,999.99 $1,000,000 to and over 2.3% 2.1% 1.9% 1.8% 1.7% *Accounts with assets under management less than $250,000 are assessed a $15 fee per quarter for reporting purposes. Asset Management Services Asset management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment advisory agreement. Asset management fees are based on the market value of assets under management at the end of the prior calendar quarter. Asset management fees are based on the following schedule: Annual Rate (%) Assets Under Management ($) *$0.00 to $249,999.99 $250,000 to $499,999.99 $500,000 to $749,999.99 $750,000 to $999,999.99 $1,000,000 to and over 1.5% 1.4% 1.3% 1.2% 1.1% *Accounts with assets under management less than $250,000 are assessed a $15 fee per quarter for reporting purposes. The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Balboa Wealth will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Use of Independent Managers As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. In circumstances where Clients authorize and enter into an investment management agreement with the Independent Manager[s], the terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. In circumstances where clients are not required to enter into an investment management agreement with the Independent Manger, the Advisor will allocate a portion of the advisory fee collected to the Independent Manager pursuant to the terms of the executed agreement between the Advisor and the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.50% annually. Participant Account Management (Pontera) Pontera will separately charge the Client 0.25% annually based on the level of assets under management on the platform. The Pontera fee is in addition to the Advisor’s fee. The Advisor does not receive any portion of the Pontera fee. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 8 https://balboawealth.com/  Financial Planning Services Balboa Wealth offers financial planning services either on an hourly basis or a fixed engagement fee. Hourly fees range up to $350 per hour. Fixed fees range from $1,500 to $10,000. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. Clients can also engage Balboa Wealth for ongoing financial planning services. The fees for ongoing financial planning services can be charged hourly or a fixed fee. Hourly fees range up to $350 per hour. Fixed fees range from $1,500 to $10,000. Retirement Plan Consulting Services Balboa Wealth offers retirement plan consulting services on an hourly basis or a fixed engagement fee. Hourly fees range up to $250 per hour. Fixed fees range from $750 to $10,000. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. The Advisor also offers retirement plan consulting services for a percentage of AUM. The percentage charged for these services is based on the complexity of the relationship. The decision regarding which option a Client will be billed for retirement plan consulting services is memorialized in the agreement executed with the Client. The asset based fee will not exceed 1.00%. B. Fee Billing Comprehensive Portfolio Management and Asset Management Services Comprehensive portfolio management and asset management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the annual rate by the days in the quarter to the total assets under management with Balboa Wealth at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Balboa Wealth to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers For certain Client accounts implemented through an Independent Manager, the Client’s overall fees will include Balboa Wealth’s investment advisory fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager. The Independent Manager will assume the responsibility for calculating the Client’s fees and deducting all fees from the Client’s account[s]. For certain Client accounts implemented through an Independent Manager, the Client’s overall fees will include Balboa Wealth’s investment advisory fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager. The Advisor will assume the responsibility for calculating the Client’s fees and deducting all fees from the Client’s account[s]. For certain Client accounts implemented through an Independent Manager, the Advisor and the Independent Manager will each assume the responsibility for calculating and deducting their respective fees from the Client’s account[s]. Participant Account Management (Pontera) Fees are billed pursuant to the terms of the Pontera agreement. Pontera collects its fee via authorized ACH or credit card payment. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 9 https://balboawealth.com/  Financial Planning Services Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. Retirement Plan Consulting Services Retirement plan consulting services are directly invoiced to the Plan Sponsor or party identified in the Client agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Balboa Wealth, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Balboa Wealth are separate and distinct from these custody and execution fees. In addition, all fees paid to Balboa Wealth for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Balboa Wealth, but would not receive the services provided by Balboa Wealth which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Balboa Wealth to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Comprehensive Portfolio Management and Asset Management Services Balboa Wealth may be compensated for its asset management services in advance of the quarter in which services are rendered. Either party may terminate the asset management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the asset management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid asset management fees from the effective date of termination to the end of the quarter. The Client’s asset management agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers In the event that the Advisor has determined that an Independent Manager with whom the Advisor has entered into an investment management agreement is no longer in the Client’s best interest, the Advisor will have the discretion to terminate the relationship with the Independent Manager. The terms for termination are set forth in the respective agreements between the Advisor and the Independent Managers. In the event that a Client should wish to terminate their relationship with an Independent Manager with whom they have entered into an investment management agreement, the terms for the termination will be set forth in the respective agreements between the Client and that Independent Manager. Balboa Wealth will assist the Client with the termination and transition as appropriate. Participant Account Management (Pontera) Pontera is compensated in advance of the quarter in which services are rendered. The Advisor will assist the Client with terminating the relationship with Pontera upon request. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 10 https://balboawealth.com/  Financial Planning Services Balboa Wealth requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for [actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor]. Upon termination, the Advisor will refund any unearned, prepaid planning fees from the effective date of termination to the end of the quarter. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Clients engaging Balboa Wealth for ongoing financial planning services will pay an initial fee which is due upon execution of the engagement agreement. E. Compensation for Sales of Securities Balboa Wealth does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. However, certain supervised persons may receive the compensation described below: Broker-Dealer Affiliations Certain Advisory Persons of Balboa Wealth are also be registered representatives of Willow Cove Investment Group, Inc. ("Willow Cove"), a securities broker-dealer and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). In one’s separate capacity as a registered representative, an Advisory Person will implement securities transactions under their broker-dealer and not through Balboa Wealth. In such instances, an Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by an Advisory Person in one’s capacity as a registered representative is separate and in addition to Balboa Wealth’s advisory fees. This practice presents a conflict of interest because Advisory Persons who are registered representatives have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on Client needs. The Advisor mitigates this conflict in two ways. First, Clients are under no obligation, contractually or otherwise, to purchase securities products through one of Balboa Wealth’s Advisory Persons. Second, the Advisor will not charge an ongoing investment advisory fee on any assets implemented in the separate capacity of one of the Advisory Persons. Please see Item 10 – Other Financial Industry Activities and Affiliations. Insurance Agency Affiliations Certain Advisory Persons are also licensed as independent insurance professionals. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by these persons are separate and in addition to advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of the Advisor who are insurance agents have an incentive to recommend insurance products to Clients for the purpose of generating commissions. However, Clients are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with the Advisor. Please see Item 10 – Other Financial Industry Activities and Affiliations. Item 6 – Performance-Based Fees and Side-By-Side Management Balboa Wealth does not charge performance-based fees for its investment advisory services. The fees charged by Balboa Wealth are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Balboa Wealth does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 11 https://balboawealth.com/  Item 7 – Types of Clients Balboa Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, charitable organizations, and retirement plans. Balboa Wealth generally requires a minimum relationship size of $250,000 for comprehensive portfolio management and asset management services to effectively implement its investment process. Written financial plans are generally assessed a minimum fee of $1,500. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Balboa Wealth employs fundamental, technical, cyclical, and charting analysis methods in developing investment strategies for its Clients. Research and analysis from Balboa Wealth are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Balboa Wealth will be able to accurately predict such a reoccurrence. Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the health of the particular company that Balboa Wealth is recommending. The risks with cyclical analysis are similar to those of technical analysis. Charting analysis utilizes various market indicators as investment selection criteria. These criteria are generally pricing trends that may indicate movement in the markets. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the technical and charting analysis may lose value and may have negative investment performance. The Advisor monitors these market indicators to determine if adjustments to strategic allocations are appropriate. As noted above, Balboa Wealth generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Balboa Wealth will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Balboa Wealth may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 12 https://balboawealth.com/  B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Balboa Wealth will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general risks of investing. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Leveraged ETF Risks Leveraged ETFs seek to deliver multiples of the performance of the index or benchmark they track. These ETFs attempt to deliver some multiple of an index's daily returns (positive or negative). Please consider the implications to both the upside and the downside of multipliers. While it may seem that a 2x multiplier is a benefit in an up-market cycle' it is important to remember that the same multiplier applies when the ETF moves against the market. This could potentially result in significant losses, and highlights the additional risk associated with Leveraged ETFs. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 13 https://balboawealth.com/  repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Short Sales A short sale involves the sale of a security that the Client does not own in the hope of purchasing the same security at a later date at a lower price. To make delivery to the buyer, the Client must borrow the security and is obligated to return the security to the lender, which is accomplished by a later purchase of the security. The Client realizes a profit or a loss as a result of a short sale if the price of the security decreases or increases respectively between the date of the short sale and the date on which the Client covers its short position, i.e., purchases the security to replace the borrowed security. A short sale involves the theoretically unlimited risk of an increase in the market price of the security that would result in a theoretically unlimited loss. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Frequent Trading Frequent trading in securities can result in higher transaction costs in the Client’s account[s]. For taxable accounts, frequent trading can also result in taxable transactions each year that would not be present in a buy-and-hold strategy. There are no guarantees that a frequent trading strategy will correctly time purchases and sales of any particular security. Real Estate Investment Trusts (“REITs”) Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. For Example, equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self- liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may decline). Oil and Gas Interests Investing oil and gas interest whether directly or as part of a fund/ETF involves distinct risks. The price of oil and gas interests may fluctuate to a greater degree than other securities and contain additional risks based on the supply and demand for oil and gas. Some of these additional risks include, the ability to obtain reliable oil and gas Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 14 https://balboawealth.com/  supply, oil and gas reserve estimates, the ability to locate markets for oil and gas, fluctuations in prices. The values of oil and gas interests are subject to market risk by a range of variables that could cause trends to differ materially. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Balboa Wealth or its owner [OR] management persons. Balboa Wealth values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 282329. Item 10 – Other Financial Industry Activities and Affiliations Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager other than their advisory fees. In such arrangements, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. Depending on the independent manager recommended to Clients the advisory fee received will differ. The Advisor conducts due diligence to determine the appropriate independent manager to a specific Client. Balboa also reviews each manager at least annually to determine if that independent manager continues to be appropriate for existing Clients or to be recommended to new Clients. Broker-Dealer Affiliation As noted in Item 5, certain Advisory Persons of Balboa Wealth are also registered representatives of broker- dealers. In an Advisory Person’s separate capacity as a registered representative, an Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person of Balboa Wealth. Neither Balboa Wealth nor an Advisory Person will earn ongoing investment advisory fees in connection with any services implemented in the Advisory Person’s separate capacity as a registered representative. Under supervision by the Advisory Person’s broker-dealer, the broker-dealer may have access to certain confidential information of the Client, including, but not limited to financial information, investment objectives, transactions and holdings information. Please see the Advisor’s Privacy Policy, which is included with this Disclosure Brochure. Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons of Balboa Wealth are licensed insurance professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person’s role with Balboa Wealth. As insurance professionals, Advisory Persons will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending insurance products. Clients are under no obligation to implement any recommendations made the Advisor or its Advisory Persons. A representative of our firm, Michael Frager, works with FSA Integrated, LLC which is a tax, investment and consulting business. FSA Integrated, LLC is an independent entity that is not affiliated with Balboa Wealth Partners, LLC. Clients will not be solicited for these services. Mr. Frager is an enrolled agent, which involves him gathering tax documents for the CPA performing the tax return and preliminary tax consultations and preparation with these tax clients. FSA Integrated, LLC is also a do business as (“DBA”) of Balboa Wealth Partners, Inc. Michael Frager also own’s less than 25% of Willow Cove Investment Group (“Willow Cove”). Mr. Frager is also a Registered Representative of Willow Cove. Willow Cove performs the following functions: Broker or dealer retailing Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 15 https://balboawealth.com/  corporate equity securities over-the-counter; Underwriter or selling group participant (corporate securities other than mutuals funds); Mutual fund retailer; Broker or dealer selling variable life insurance or annuities; Private placements of securities; Investment banking services which include merger & acquisition services, advisory services for memorandum and document development, syndication advisory services and corporate finance due diligence. A representative of our firm, Duane Shumaker, is an owner and employee of Shumaker Wengren, LLC an accounting and tax preparation business. Shumaker Wengren, LLC is an independent entity that is not affiliated with Balboa Wealth Partners, LLC. Clients are under no obligation to engage Shumaker Wengren, LLC for these services. Mr. Shumaker’s duties include managing the business and the preparation of tax returns. A representative of our firm, Richard Brooks Brydges, is the president of Cardiff Capital Partners, LLC and Bluff City Group, LLC, which are holding companies for hotel development. Balboa Wealth Partners clients are not solicited to invest in these companies. John Vilina conducts business development for Season Two Ventures. Season Two Ventures is a private investment fund. No Clients of Balboa Wealth are recommended this private investment. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Balboa Wealth has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Balboa Wealth (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Balboa Wealth and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Balboa Wealth’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at 949-445- 1465. B. Personal Trading with Material Interest Balboa Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Balboa Wealth does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Balboa Wealth does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Balboa Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Balboa Wealth requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Balboa Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 16 https://balboawealth.com/  At no time will Balboa Wealth, or any Supervised Person of Balboa Wealth, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Balboa Wealth does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Balboa Wealth to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Balboa Wealth does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Balboa Wealth does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Balboa Wealth. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Balboa Wealth may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Balboa Wealth will recommend that Clients establish their account[s] at LPL Financial LLC (“LPL Financial”) or Charles Schwab & Co., Inc. (“Schwab”), both FINRA-registered broker-dealers and members SIPC. LPL Financial or Schwab will serve as the Client’s “qualified custodian”. Balboa Wealth maintains an institutional relationship with LPL Financial and Schwab, whereby the Advisor receives economic benefits (Please see Item 14 below.) As previously disclosed above, Supervised Persons that are registered representatives of a non-affiliated broker- dealer, the Advisor may be limited in using other broker-dealers/custodians as their broker-dealer must approve the use of any outside broker-dealer/custodian. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Balboa Wealth does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Balboa Wealth does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Balboa Wealth will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Balboa Wealth will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Balboa Wealth will execute its transactions through the Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 17 https://balboawealth.com/  Custodian as authorized by the Client. Balboa Wealth may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Jeff Gilbert, Chief Compliance Officer of Balboa Wealth. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Balboa Wealth if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Balboa Wealth Balboa Wealth is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Balboa Wealth does not receive commissions or other compensation from product sponsors, broker- dealers or any un-related third party. Balboa Wealth may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Balboa Wealth may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform – LPL Financial Balboa Wealth has established an institutional relationship with LPL Financial to assist the Advisor in managing Client account[s]. The Advisor receives access to software and related support as part of its relationship with LPL Financial. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor’s recommendation of the Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor may receive the following benefits from LPL Financial: receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 18 https://balboawealth.com/  Participation in Institutional Advisor Platform - Schwab Balboa Wealth has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Balboa Wealth. As a registered investment advisor participating on the Schwab Advisor Services platform, Balboa Wealth receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Balboa Wealth that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Balboa Wealth believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the Client. Item 15 – Custody Balboa Wealth does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Balboa Wealth exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Balboa Wealth to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Balboa Wealth to ensure accuracy, as the Custodian does not perform this review. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 19 https://balboawealth.com/  Item 16 – Investment Discretion Balboa Wealth generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Balboa Wealth. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Balboa Wealth will be in accordance with each Client's investment objectives and goals. For Client’s where Balboa Wealth does not have discretion over the selection and amount of securities to be bought or sold in Client accounts, the Advisor must obtain prior approval from the Client. The Advisor will contact the Client and obtain approval prior to executing trades or allocating investment assets. Item 17 – Voting Client Securities Balboa Wealth does not accept proxy-voting responsibility for any Client, however, third party money managers selected or recommended by our firm may vote proxies for clients. Except where third parties have taken on the authority to vote proxies, Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting where a third party has not taken on this responsibility. Item 18 – Financial Information Neither Balboa Wealth, nor its management, have any adverse financial situations that would reasonably impair the ability of Balboa Wealth to meet all obligations to its Clients. Neither Balboa Wealth, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Balboa Wealth is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 20 https://balboawealth.com/  Privacy Policy Effective: March 21, 2025 Our Commitment to You Balboa Wealth Partners, Inc. (“Balboa Wealth” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Balboa Wealth (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Balboa Wealth does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals Employer name Employer address Job title Employee phone number[s] What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Account applications and forms Investment questionnaires and suitability documents Transactional information with us or others Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 21 https://balboawealth.com/  We require third parties that assist in providing our services to you to protect the personal information they receive from us. How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Balboa Wealth shares Client information with Willow Cove due to the oversight each broker-dealer has over certain Supervised Persons of the Advisor. You may also contact us at any time for a copy of these broker-dealer’s Privacy Policy. No Not Shared Marketing Purposes Balboa Wealth does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Balboa Wealth or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients Balboa Wealth does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations California In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws. Massachusetts In response to Massachusetts law, the Client must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other written consent by the Client, as appropriate and consistent with applicable laws and regulations. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 22 https://balboawealth.com/  Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting the Advisor at 949-445-1465. Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265, Scottsdale, AZ 85250 Phone: 949-445-1465 * Fax: 949-524-8383 Page 23 https://balboawealth.com/ 

Item 1: Cover Page Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure March 21, 2025 Balboa Wealth Partners, Inc. Wrap Program Sponsored by: Balboa Wealth Partners, Inc. 6263 North Scottsdale Road, Suite 265 Scottsdale, AZ 85250 balboawealth.com Firm Contact: Jeff Gilbert Chief Compliance Officer firm is also available on This Form ADV2A – Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices of Balboa Wealth Partners, Inc (“Balboa Wealth”). If clients have any questions about the contents of this brochure, please contact us at 949-445-1465 or jgilbert@balboawealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional the SEC’s website at information about our www.adviserinfo.sec.gov by searching CRD #282329. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes Form ADV 2A - Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the Wrap Fee Program offered by the Advisor. Material Changes There have been no material changes to this Wrap Fee Program Brochure since the last annual amendment filing on 02/08/2024. Future Changes From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Wrap Fee Program Brochure (along with the complete Balboa Wealth Disclosure Brochure) or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of Balboa Wealth. At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name or CRD# 282329. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at 949-445-1465. Item 3: Table of Contents Item 1: Cover Page...................................................................................................................................................................... 1 Item 2: Material Changes ......................................................................................................................................................... 2 Item 3: Table of Contents ........................................................................................................................................................ 2 Item 4: Services, Fees & Compensation ............................................................................................................................ 3 Item 5: Account Requirements & Types of Clients....................................................................................................... 5 Item 6: Portfolio Manager Selection & Evaluation ....................................................................................................... 6 Item 7: Client Information Provided to Portfolio Manager(s) ............................................................................. 11 Item 8: Client Contact with Portfolio Manager(s) ..................................................................................................... 11 Item 9: Additional Information.......................................................................................................................................... 11 ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 2 Balboa Wealth Partners, Inc.  Item 4: Services, Fees & Compensation Our firm manages assets for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing the client. Our firm has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Our firm sponsors and offers a wrap fee program, which allows clients to pay a single fee for investment advisory services and associated custodial transaction costs. Transaction fees will be paid by our firm for individual transaction charges. Because our firm absorbs client transaction fees, an incentive exists to limit trading activities in client accounts. Custodial transaction costs, however, are not included in the advisory fee charged by our firm for non-wrap services, and are to be paid by the client to their chosen custodian. Depending on the client’s account or portfolio trading activity, clients may pay more for using our wrap fee services than they would for using our non-wrap services. Our Wrap Advisory Services Wrap Asset Management: As part of our Wrap Asset Management service, a portfolio is created, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Fee Schedule Assets Under Management Annual Percentage of Assets Charge *$0 to $249,999.99 $250,000 to $499,999.99 $500,000 to $749,999.99 $750,000 to $999,999.99 Over $1,000,000 1.5% 1.4% 1.3% 1.2% 1.1% *Accounts with assets under management less than $250,000 are assessed a $15 fee per quarter for reporting purposes. The maximum annual fee charged for this service will not exceed 2.50%. Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be deducted from client account(s). Adjustments will be made for deposits and withdrawals during the quarter. In rare cases, our firm will agree to direct bill clients. All securities held in accounts managed by Balboa Wealth will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. For the sub-advisory services rendered to our clients, our firm compensates third party investment Balboa Wealth Partners, Inc. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 3  advisory firms or individual advisors a percentage of the overall investment advisory fee charged by our firm. The advisory fee paid ranges from 0.50 to 2.00% and shall not exceed the fee published for this service. As part of this process, clients understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and c) If our firm sends a copy of our invoice to the client, legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. Wrap Comprehensive Portfolio Management: As part of our Wrap Comprehensive Portfolio Management service clients will be provided asset management and financial planning or consulting services. This service is designed to assist clients in meeting their financial goals through the use of a financial plan or consultation. Our firm conducts client meetings to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what is learned, an investment approach is presented to the client, consisting of individual stocks, bonds, ETFs, options, mutual funds and other public and private securities or investments. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Upon client request, our firm provides a summary of observations and recommendations for the planning or consulting aspects of this service. Fee Schedule Assets Under Management *$0 to $249,999.99 $250,000 to $499,999.99 $500,000 to $749,999.99 $750,000 to $999,999.99 Over $1,000,000 Annual Percentage of Assets Charge 2.3% 2.1% 1.9% 1.8% 1.7% *Accounts with assets under management less than $250,000 are assessed a $15 fee per quarter for reporting purposes. The maximum annual fee charged for this service will not exceed 2.50%. Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last of the previous quarter. Fees are negotiable and will be deducted from client account(s). Adjustments will be made for deposits and withdrawals during the quarter. In rare cases, our firm will agree to direct bill clients. For the sub-advisory services rendered to our clients, our firm compensates third party investment advisory firms or individual advisors a percentage of the overall investment advisory fee charged by our firm. The advisory fee paid ranges from 1.70 to 2.30% and shall not exceed the fee published for this service. As part of this process, clients understand the following: ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 4 Balboa Wealth Partners, Inc.  a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and c) If our firm sends a copy of our invoice to the client, legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. Other Types of Fees & Expenses: In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark- downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Termination and Refunds: Either party may terminate the advisory agreement signed with our firm for Wrap Asset Management and Wrap Comprehensive Portfolio Management services in writing at any time. Upon notice of termination our firm will process a pro-rata refund of the unearned portion of the advisory fees charged in advance. Wrap Fee Program Recommendations: Our firm does not recommend or offer the wrap program services of other providers. Item 5: Account Requirements & Types of Clients Our requirements for opening and maintaining accounts or otherwise engaging us: • Our firm requires a minimum account balance of $250,000 for our Comprehensive Portfolio Management or Asset Management service. Generally, this minimum account balance requirement is not negotiable and would be required throughout the course of the client’s relationship with our firm. • Written financial plans are generally assessed a minimum fee of $1,500. Our firm has the following types of clients: • Individuals and High Net Worth Individuals; • Trusts, Estates or Charitable Organizations; • Pension and Profit Sharing Plans; • Corporations, Limited Liability Companies and/or Other Business Types ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 Balboa Wealth Partners, Inc.  Item 6: Portfolio Manager Selection & Evaluation Selection of Portfolio Managers: Our firm selects and reviews outside portfolio managers, either individually or firm-wide, based on past performance, investment philosophy, market outlook, experience of associated portfolio managers and executive team, disciplinary, legal and regulatory histories of the firm and its associates, and/or whether compliance procedures are in place to address at a minimum, insider trading, conflicts of interest, and/or anti-money laundering. Advisory Business: Information about our wrap fee services can be found in Item 4 of this brochure. Our firm offers individualized investment advice to our Wrap Asset Management and Wrap Comprehensive Portfolio Management clients. Each Wrap Asset Management and Wrap Comprehensive Portfolio Management client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Participation in Wrap Fee Programs: Our firm does not manage wrap fee accounts in a different fashion than non-wrap fee accounts. All accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. Performance-Based Fees & Side-By-Side Management: Balboa Wealth does not charge performance-based fees for its investment advisory services. The fees charged by Balboa Wealth are as described in Item 4 above and are not based upon the capital appreciation of the funds or securities held by any Client. Balboa Wealth does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Methods of Analysis, Investment Strategies & Risk of Loss: The following methods of analysis are utilized by our firm when formulating investment advice and/or managing client assets: Charting: In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when how long the trend may last and when that trend might reverse. Cyclical Analysis: In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 Balboa Wealth Partners, Inc.  Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis: We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement. Asset Allocation: We generally focus on identifying an appropriate allocation of securities, maturities, market sectors and yield curve positioning suitable for the client’s investment goals and risk tolerance. While asset allocation is recognized by professional investment advisers as a prudent approach, a risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the allocation will change over time due to market movements in the various sectors, which, if not corrected, may no longer be appropriate for the client’s goals. Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Third-Party Money Manager Analysis: We examine the experience, expertise, investment philosophies, and past performance of independent third-party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the manager’s underlying holdings, strategies, concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of our due-diligence process, we survey the manager’s compliance and business enterprise risks. A risk of investing with a third-party manager who has been successful in the past is that he/she may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as we do not control the manager’s daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 7 Balboa Wealth Partners, Inc.  Quantitative Analysis: We use quantitative analysis that may include mathematical analysis in an attempt to identify the impact of interest rate changes on individual securities and portfolios of securities. The results of our quantitative analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions that prove to be incorrect. Qualitative Analysis: We use qualitative analysis to evaluate individual securities, focusing on nonquantifiable factors such as quality of management and others not readily subject to measurement, and incorporate that analysis into our security selection process. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. Risks for All Forms of Analysis: Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly-available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. The following investment strategies are used managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-Term Purchases: When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Typically we employ this sub-strategy when we believe the securities to be well valued; and/or we want exposure to a particular asset class over time, regardless of the current projection for this class. The potential risks associated with this investment strategy involve a lower than expected return, for many years in a row. Lower-than-expected returns that last for a long time and/or that are severe in nature would have the impact of dramatically lowering the ending value of your portfolio, and thus could significantly threaten your ability to meet financial goals. Short-Term Purchases: When utilizing this strategy, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. The potential risk associated with this investment strategy is associated with the currency or exchange rate. Currency or exchange rate risk is a form of risk that arises from the change in price of one currency against another. The constant fluctuations in the foreign currency in which an investment is denominated vis-à-vis one's home currency may add risk to the value of a security. Currency risk is greater for shorter term investments, which do not have time to level off like longer term foreign investments. Trading: We purchase securities with the idea of selling them very quickly (typically within 30 days or less). We do this in an attempt to take advantage of our predictions of brief price swings. Trading involves risk that may not be suitable for every investor, and may involve a high volume of trading activity. Each trade generates a commission and the total daily commission on such a high volume of trading can be considerable. Active trading accounts ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 8 Balboa Wealth Partners, Inc.  should be considered speculative in nature with the objective being to generate short-term profits. This activity may result in the loss of more than 100% of an investment. Short Sales: We borrow shares of a stock for your portfolio from someone who owns the stock on a promise to replace the shares on a future date at a certain price. Those borrowed shares are then sold. On the agreed-upon future date, we buy the same stock and return the shares to the original owner. We engage in short selling based on our determination that the stock will go down in price after we have borrowed the shares. If we are correct and the stock price has gone down since the shares were purchased from the original owner, the client account realizes the profit. The two primary perceived risks of short selling are that the in the long term, markets trend upward and short selling can expose investors to potentially unlimited risk. Due to the “upside gap”, sellers risk not being able to react until after a significant loss has already been incurred. Margin Transactions: We will purchase stocks for your portfolio with money borrowed from your brokerage account. This allows you to purchase more stock than you would be able to with your available cash, and allows us to purchase stock without selling other holdings. Margin accounts and transactions are risky and not necessarily for every client. The potential risks associated with these transactions are (1) You can lose more funds than are deposited into the margin account; (2) the force sale of securities or other assets in your account; (3) the sale of securities or other assets without contacting you; and (4) you may not be entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call. Option Writing: We may use options as an investment strategy. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative, because it derives its value from an underlying asset. The two types of options are calls and puts. A call gives us the right to buy an asset at a certain price within a specific period of time. We will buy a call if we have determined that the stock will increase substantially before the option expires. A put gives us the holder the right to sell an asset at a certain price within a specific period of time. We will buy a put if we have determined that the price of the stock will fall before the option expires. We will use options to "hedge" a purchase of the underlying security; in other words, we will use an option purchase to limit the potential upside and downside of a security we have purchased for your portfolio. We use "covered calls", in which we sell an option on security you own. In this strategy, you receive a fee for making the option available, and the person purchasing the option has the right to buy the security from you at an agreed-upon price. We use a "spreading strategy", in which we purchase two or more option contracts (for example, a call option that you buy and a call option that you sell) for the same underlying security. This effectively puts you on both sides of the market, but with the ability to vary price, time and other factors. The potential risks associated with these transactions are that (1) all options expire. The closer the option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move very quickly. Depending on factors such as time until expiration and the relationship of the stock price to the option’s strike price, small movements in a stock can translate into big movements in the underlying options. Fixed Income Portfolio Management Investment Strategies: We believe that a conservative, risk-averse approach to fixed income management will provide both steady incremental outperformance, and low relative volatility. The disciplined process we employ in an effort to realize this philosophy is generally grounded in four key decisions: ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 9 Balboa Wealth Partners, Inc.  1. Constraint of portfolio duration within a narrow range relative to the benchmark in order to limit exposure to market and interest rate risk. 2. Strategic allocations to key sectors to add value relative to the benchmark. 3. Proactive management of term structure to add value in different yield curve environments. 4. Security selection based on rigorous credit and relative value analysis and broad diversification of nongovernment issuers. Within our Fixed Income strategy, we use the following sub-strategies in managing client accounts, provided that such sub-strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations. Duration Constraints: We adhere to a discipline of generally maintaining duration within a narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio management team rebalances client portfolios to their current duration targets on a periodic basis. The risk of constraining duration is that the client may not participate fully in a large rally in bond prices. Sector Allocation: We allocate client assets to various sectors of the fixed income market, including US Treasury obligations, federal agency securities, corporate notes, mortgage- backed securities and others, based on our quantitative and qualitative analysis in order to manage client exposure to a given sector and to provide exposure to sectors we believe have good value. The risk of sector allocation is that clients may not participate fully in an increase in value in any specific sector. Security Selection: A proprietary credit evaluation process drives our security selection process. The system uses both internally and externally generated credit research to evaluate securities we are considering for purchase. Based on research we conduct internally, our Credit Committee selects securities for our Approved list. The ultimate decision to purchase or sell a security is based on the firm’s evaluation of the current price for the security. The risk of security selection is that the methods of analysis employed will not provide accurate measurement of the risk association with each individual security. Please Note: Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and ask any questions you may have. Please see Item 8.B of the ADV2A -Disclosure Brochure for more details around the risks of loss for the various types of assets you may be invested in. Voting Client Securities: Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Third party money managers selected or recommended by our firm may vote proxies for clients. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Balboa Wealth Partners, Inc. Page 10  Except in the event a third party money manager votes proxies, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Therefore (except for proxies that may be voted by a third party money manager), our firm and/or the client shall instruct the qualified custodian to forward to copies of all proxies and shareholder communications relating to the client’s investment assets. Item 7: Client Information Provided to Portfolio Manager(s) Our firm communicates with your portfolio manager(s) on a regular basis as needed to ensure your most current investment goals and objectives are understood by your portfolio manager(s). In most cases, our firm will communicate such information as part of our regular investment management duties. Nevertheless, our firm will also communicate information to your portfolio manager(s) when you ask us to, when market or economic conditions make it prudent to do so, etc. Item 8: Client Contact with Portfolio Manager(s) Any questions or concerns about the management of client portfolios shall be directed to our firm. Item 9: Additional Information Disciplinary Information There are no legal, regulatory or disciplinary events involving Balboa Wealth or its owner [OR] management persons. Balboa Wealth values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 282329. Financial Industry Activities & Affiliations Use of Independent Managers As noted in Item 4 and Item 10 of the ADV2A – Disclosure Brochure, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager other than their advisory fees. In such arrangements, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. Depending on the independent manager recommended to Clients the advisory fee received will differ. The Advisor conducts due diligence to determine the appropriate independent manager to a specific Client. Balboa also reviews each manager at least annually to determine if that independent manager continues to be appropriate for existing Clients or to be recommended to new Clients. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 11 Balboa Wealth Partners, Inc.  Broker-Dealer Affiliation As noted in Item 5 and Item 10 of the ADV2A – Disclosure Brochure, certain Advisory Persons of Balboa Wealth are also registered representatives of broker-dealers. In an Advisory Person’s separate capacity as a registered representative, an Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person of Balboa Wealth. Neither Balboa Wealth nor an Advisory Person will earn ongoing investment advisory fees in connection with any services implemented in the Advisory Person’s separate capacity as a registered representative. Under supervision by the Advisory Person’s broker-dealer, the broker-dealer may have access to certain confidential information of the Client, including, but not limited to financial information, investment objectives, transactions and holdings information. Please see the Advisor’s Privacy Policy, which is included with this Disclosure Brochure. Insurance Agency Affiliations As noted in Item 5 and Item 10 of the ADV2A – Disclosure Brochure, certain Advisory Persons of Balboa Wealth are licensed insurance professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person’s role with Balboa Wealth. As insurance professionals, Advisory Persons will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending insurance products. Clients are under no obligation to implement any recommendations made the Advisor or its Advisory Persons. Investment Advisor Affiliation As noted in Item 10 of the ADV2A – Disclosure Brochure Certain Advisory Persons are Investment Advisor Representatives (“IARs”) of Sortino Investment Analytics, LLC (“Sortino”) (CRD# 287491). As a financial advisor with Sortino, the Advisory Person will receive investment advisory fees for investment management services offered. The Advisory Person will provide each Client with Sortino’s Form ADV 2A or equivalent disclosure brochure, in advance of providing investment management services. At no time will the Advisory Person or the Advisor earn both ongoing investment advisory fees under the Advisor and ongoing investment advisory fees through Sortino on the same investment assets. A representative of our firm, Michael Frager, works with FSA Integrated, LLC which is a tax, investment and consulting business. FSA Integrated, LLC is an independent entity that is not affiliated with Balboa Wealth Partners, LLC. Clients will not be solicited for these services. Mr. Frager is an enrolled agent, which involves him gathering tax documents for the CPA performing the tax return and preliminary tax consultations and preparation with these tax clients. FSA Integrated, LLC is also a do business as (“DBA”) of Balboa Wealth Partners, Inc. A representative of our firm, Richard Brooks Brydges, is the president of Cardiff Capital Partners, LLC and Bluff City Group, LLC, which are holding companies for hotel development. Balboa Wealth Partners clients are not solicited to invest in these companies. A representative of our firm, Matt Beary, is an owner of Clarity Strategic Opportunities (“CSO”), a real estate operating company. Mr. Beary participates in the development of private funds offered by CSO, including the Clarity Growth and Income Fund. However, no clients of Balboa Wealth Partners, Inc., will be solicited. Jake Frankel is the CEO of Sam Financial Group. Sam Financial Group is a do business as (“DBA”). Michael Frager own’s less than 25% of Willow Cove Investment Group (“Willow Cove”). Mr. Frager ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 12 Balboa Wealth Partners, Inc.  is also a Registered Representative of Willow Cove. Willow Cove performs the following functions: Broker or dealer retailing corporate equity securities over-the-counter; Underwriter or selling group participant (corporate securities other than mutuals funds); Mutual fund retailer; Broker or dealer selling variable life insurance or annuities; Private placements of securities; Investment banking services which include merger & acquisition services, advisory services for memorandum and document development, syndication advisory services and corporate finance due diligence. John Vilinia conducts business development for Season Two Ventures. Season Two Ventures is a private investment fund. No Clients of Balboa Wealth are recommended this private investment. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities transaction and insider trading. Our firm requires all representatives to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment with our firm, and at least annually thereafter, all representatives of our firm will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Our firm recognizes that the personal investment transactions of our representatives demands the application of a Code of Ethics with high standards and requires that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, our firm also believes that if investment goals are similar for clients and for our representatives, it is logical, and even desirable, that there be common ownership of some securities. In order to prevent conflicts of interest, our firm has established procedures for transactions effected by our representatives for their personal accounts1. In order to monitor compliance with our personal trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting system for all of our representatives. Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which our firm or a related person has a material financial interest without prior disclosure to the client. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or selling the same securities prior to buying or selling for our clients in the same day. If related persons’ accounts are included in a block trade, our related persons will always trade personal accounts last. Review of Accounts Our management personnel or financial advisors review accounts on at least an annual basis for our ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 13 Balboa Wealth Partners, Inc.  Wrap Asset Management and Wrap Comprehensive Portfolio Management clients. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Our firm may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Our firm does not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when our Wrap Asset Management and Wrap Comprehensive Portfolio Management clients are contacted. Other Compensation Balboa Wealth is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Balboa Wealth does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Balboa Wealth may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Balboa Wealth may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform As disclosed under Item 12, above, the Advisor participates in TD Ameritrade’s institutional customer program and the Advisor may recommend TD Ameritrade to Clients for custody and brokerage services. There is no direct link between the Advisor’s participation in the program and the investment advice it gives to its Clients, although the Advisor receives economic benefits through its participation in the program that are typically not available to TD Ameritrade retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate Client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving the Advisor participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to Client accounts); the ability to have advisory fees deducted directly from Client accounts; access to an electronic communications network for Client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to the Advisor by third party vendors. TD Ameritrade may also have paid for business consulting and professional services received by the Advisor’s related persons. Some of the products and services made available by TD Ameritrade through the program may benefit the Advisor but may not benefit its Client accounts. These products or services may assist the Advisor in managing and administering Client accounts, including accounts not maintained at TD Ameritrade. Other services made available by TD Ameritrade are intended to help the Advisor manage and further develop its business enterprise. The benefits received by the Advisor or its personnel through participation in the program do not depend on the amount of brokerage transactions directed to TD Ameritrade. As part of its fiduciary duties to clients, the Advisor endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by the Advisor or its related persons in and of itself creates a conflict of interest and may indirectly influence the Advisor’s choice of TD Ameritrade for custody and brokerage services. Participation in Institutional Advisor Platform Balboa Wealth has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Balboa Wealth. As a registered investment advisor participating on the Schwab Advisor Services platform, Balboa Wealth receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 14 Balboa Wealth Partners, Inc.  Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Balboa Wealth that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Balboa Wealth believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Compensation for Client Referrals Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the Client. Financial Information Our firm is not required to provide financial information in this Brochure because: • Our firm does not require the prepayment of more than $1,200 in fees when services cannot be rendered within 6 months. • Our firm does not take custody of client funds or securities. • Our firm does not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. Our firm has never been the subject of a bankruptcy proceeding. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 15 Balboa Wealth Partners, Inc.