BRIGHTPATH WEALTH PLANNING, LLC

BrightPath Wealth Planning, LLC Form ADV Part 2A – Disclosure Brochure Effective: March 13, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of BrightPath Wealth Planning, LLC (“BPWP” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (805) 764-0335. BPWP 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 BPWP to assist you in determining whether to retain the Advisor. Additional information about BPWP 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# 160563. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 www.brightpathwealth.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 BPWP. For convenience, the Advisor has combined these documents into a single disclosure document. BPWP 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. BPWP 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 annual amendment filing on March 7, 2025: • The Advisor now offers its services to charitable organizations. Please see Items 4 and 7 for additional information. • The Advisor now offers ERISA 3(38) services as a part of its Retirement Plan Advisory Services. Please see Item 4 for additional details. • The Advisor may introduce certain clients to non-purpose lines of credit. Please see Items 4 and 8 for additional information. 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# 160563. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (805) 764-0335. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 2 https://www.brightpathwealth.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 .......................................................................................................................................... 6 D. Wrap Fee Programs ....................................................................................................................................................... 6 E. Assets Under Management ............................................................................................................................................ 7 Item 5 – Fees and Compensation ......................................................................................................................... 7 A. Fees for Advisory Services ............................................................................................................................................. 7 C. Other Fees and Expenses ............................................................................................................................................. 8 D. Advance Payment of Fees and Termination .................................................................................................................. 9 E. Compensation for Sales of Securities ............................................................................................................................ 9 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9 Item 7 – Types of Clients ..................................................................................................................................... 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 10 A. Methods of Analysis ..................................................................................................................................................... 10 B. Risk of Loss .................................................................................................................................................................. 10 Item 9 – Disciplinary Information ....................................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 12 A. Code of Ethics .............................................................................................................................................................. 12 B. Personal Trading with Material Interest ........................................................................................................................ 12 C. Personal Trading in Same Securities as Clients .......................................................................................................... 12 D. Personal Trading at Same Time as Client ................................................................................................................... 13 Item 12 – Brokerage Practices ............................................................................................................................ 13 A. Recommendation of Custodian[s] ................................................................................................................................ 13 B. Aggregating and Allocating Trades .............................................................................................................................. 14 Item 13 – Review of Accounts ............................................................................................................................ 14 A. Frequency of Reviews .................................................................................................................................................. 14 B. Causes for Reviews ..................................................................................................................................................... 14 C. Review Reports ............................................................................................................................................................ 14 Item 14 – Client Referrals and Other Compensation ........................................................................................ 14 A. Compensation Received by BPWP .............................................................................................................................. 14 B. Compensation for Client Referrals ............................................................................................................................... 15 Item 15 – Custody ................................................................................................................................................ 15 Item 16 – Investment Discretion ......................................................................................................................... 16 Item 17 – Voting Client Securities ...................................................................................................................... 16 Item 18 – Financial Information .......................................................................................................................... 16 Privacy Policy ...................................................................................................................................................... 20 BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 3 https://www.brightpathwealth.com/  Item 4 – Advisory Services A. Firm Information BrightPath Wealth Planning, LLC (“BPWP” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under the laws of State of California. BPWP was founded in April 2012 and is owned and operated by Peter Kozak (Managing Member and Chief Compliance Officer). Beginning in 2004, Kozak owned and operated another firm (Kozak Financial Advisory) which became BPWP in 2012. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by BPWP. B. Advisory Services Offered BPWP offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, charitable organizations, 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. BPWP'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. Wealth Management Services BPWP provides wealth management services for its Clients. These services generally include discretionary investment management services in connection with a broad range of financial planning services. These services are described below. Investment Management Services – BPWP provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. BPWP 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. BPWP 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. BPWP primarily recommends mutual funds that follow a passive asset class investment philosophy with low holdings turnover. The Advisor may also utilize individual stocks, bonds or alternative investments 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. BPWP’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. BPWP 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. BPWP evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. BPWP may recommend, on occasion, redistributing investment allocations to diversify the portfolio. BPWP 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. BPWP 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. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 4 https://www.brightpathwealth.com/  Independent Managers – BPWP 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 Clients 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). At no time will BPWP 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. Financial Planning Services – BPWP typically provides a variety of financial planning and consulting services to Clients as part of their overall wealth management engagement. Financial planning is also offered as a stand- alone service. 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 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. BPWP 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. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 5 https://www.brightpathwealth.com/  Retirement Plan Advisory Services BPWP provides retirement plan advisory 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 Review Investment Oversight Services (ERISA 3(21)) ● ● ● Ongoing Investment Recommendation and Assistance Investment Management Services (ERISA 3(38)) ● These services are provided by BPWP 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 BPWP’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Retirement plan advisory services are either offered as a 3(21) or 3(38) context depending on whether or not the Advisor is also providing discretionary investment management over the Plan assets. For 3(38) services, the Advisor shall have the discretion to select the investments for the Plan and/or make investment decisions on behalf of Plan Participants. For 3(21) services, the Advisor will recommend the investments for the Plan, where the Plan Sponsor will ultimately decide whether or not to accept or reject the Advisor’s recommendation. Schwab Bank Pledged Asset Line® The Advisor may introduce certain Clients to a Pledged Asset Line®, a non-purpose revolving line of credit offered through Charles Schwab Bank, secured by eligible assets held in an account maintained at the Custodian (“Lending Program”). In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for a non-purpose revolving line of credit. The recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related to the risks involved with non-purpose loans, please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. C. Client Account Management Prior to engaging BPWP 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 – BPWP, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – BPWP 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 – BPWP will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – BPWP will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs BPWP does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by BPWP. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 6 https://www.brightpathwealth.com/  E. Assets Under Management As of December 31, 2024, BPWP manages $186,674,588 in Client assets, $180,551,813 of which are managed on a discretionary basis and $6,122,775 of which are managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid quarterly, in advance of each calendar quarterly, pursuant to the terms of the investment advisory agreement. Wealth management fees are based on the market value of assets under management at the end of the prior calendar quarter. Wealth management fees are based on the following schedule: Annual Rate (%) Assets Under Management ($) On the first $1,000,000 On the next $1,000,000 On the next $3,000,000 On the next $5,000,000 On the next $10,000,000 $20,000,000 and Above 1.00% 0.90% 0.70% 0.60% 0.50% 0.40% A minimum annual fee of $7,500 is generally required. The wealth management 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 BPWP will be independently valued by the Custodian. BPWP will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Certain legacy clients may be billed under a different fee schedule. 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. Independent Managers As noted in Item 4, the Advisor may 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 wealth management 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. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. Financial Planning Services BPWP offers project-based financial planning services either on an hourly or fixed fee basis. Hourly fees are $325 per hour. Fixed fees for project-based financial planning range from $1,500 to $5,000. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 7 https://www.brightpathwealth.com/  BPWP also offers ongoing financial planning services for a quarterly fee that ranges from $200 to $500. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 0.90% and are billed quarterly in advance pursuant to the terms of the retirement plan advisory agreement. Retirement plan advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees may be negotiable depending on the size and complexity of the Plan. B. Fee Billing Investment Management Services Investment advisory 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 quarterly rate (annual rate divided by 4) to the total assets under management with BPWP 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 review the statement provided by the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by BPWP 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. Independent Managers For Client accounts implemented through an Independent Manager, the Client’s overall fees will include BPWP’s wealth management 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]. Financial Planning Services Fees for project-based financial planning 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]. Ongoing financial planning fees are billed quarterly in advance. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than BPWP, 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 BPWP are separate and distinct from these custody and execution fees. In addition, all fees paid to BPWP 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 BPWP, but would not receive the services provided by BPWP 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 BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 8 https://www.brightpathwealth.com/  objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by BPWP 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 Investment Management Services BPWP may be compensated for its investment management services in advance of the quarter in which services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance 30 day written notice to the other party. The Client may also terminate the investment advisory 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 investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Independent Managers In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the Client and that Independent Manager. BPWP will assist the Client with the termination and transition as appropriate. Financial Planning Services BPWP 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. Retirement Plan Advisory Services BPWP is compensated for its services at the beginning of the quarter before advisory services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities BPWP 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. Item 6 – Performance-Based Fees and Side-By-Side Management BPWP does not charge performance-based fees for its investment advisory services. The fees charged by BPWP are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. BPWP 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. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 9 https://www.brightpathwealth.com/  Item 7 – Types of Clients BPWP offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, charitable organizations, and retirement plans. BPWP generally requires a minimum relationship size of $750,000 to effectively implement its investment process. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis BPWP primarily employs Modern Portfolio Theory developing investment strategies for its Clients. Research and analysis from BPWP 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. BPWP's services are based on long-term investment strategies incorporating the principles of Modern Portfolio Theory. BPWP's investment approach is firmly rooted in the belief that markets are "efficient" over periods of time and that investors' long-term returns are determined principally by asset allocation decisions, rather than market timing or stock picking. BPWP recommends diversified portfolios, principally through the use of passively managed, asset class mutual funds. BPWP selects or recommends to client’s portfolios of securities, principally broadly-traded open end mutual funds or conservative fixed income securities to implement this investment strategy. Although all investments involve risk, BPWP's investment advice seeks to limit risk through broad diversification among asset classes. BPWP's investment philosophy is designed for investors who desire a buy and hold strategy. Frequent trading of securities increases brokerage and other transaction costs that BPWP's strategy seeks to minimize. As noted above, BPWP generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. BPWP 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, BPWP 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. 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. BPWP 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 the information below 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. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 10 https://www.brightpathwealth.com/  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 approach: 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. Fixed Income Risks Fixed Income securities, such as 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 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 desired if 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. Alternative Investments The performance of alternative investments 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. Non-Purpose Loans and Lines of Credit Non-purpose loans and lines of credit carry a number of risks, including but not limited to the risk of a market downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian, may result in a reduction in the draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit additional funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral account[s]. 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. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 11 https://www.brightpathwealth.com/  Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving BPWP or its owner. BPWP 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# 160563. Item 10 – Other Financial Industry Activities and Affiliations The sole business of BPWP and its Advisor Persons is to provide investment advisory services to its Clients. Neither BPWP nor its Advisory Persons are involved in other business endeavors. BPWP does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. 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. The Advisor will only earn its investment advisory fee as described in Item 5.A. However, the Independent Manager will calculate and deduct a single, overall fee from the Client’s account[s] at the Custodian and remit the appropriate amount to the Advisor. All fees will be fully disclosed to the Client. BPWP generally selects Buckingham Strategic Partners for such fixed income management. BPWP also contracts with Buckingham Strategic Partners for back-office services and assistance with portfolio modeling. While BPWP has a contract with Buckingham Strategic Partners governing a time period for back-office services, BPWP has no such fixed commitment to the selection of Buckingham Strategic Partners for fixed income management services and may select another investment manager for clients upon reasonable notice to Buckingham Strategic Partners. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics BPWP 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 BPWP (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. BPWP and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of BPWP’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 (805) 764-0335. B. Personal Trading with Material Interest BPWP allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. BPWP 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. BPWP does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients BPWP 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 BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 12 https://www.brightpathwealth.com/  mitigated by BPWP requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. 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 BPWP 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 afterward. At no time will BPWP, or any Supervised Person of BPWP, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] BPWP 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 BPWP to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, BPWP does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. BPWP will not exercise authority to arrange client transactions in fixed income securities. Clients will provide this authority to a fixed income manager retained by BPWP on client's behalf by designating the portfolio manager with trading authority over client's brokerage account. The portfolio manager will obtain an additional authorization from the Client to trade-away from the Custodian for access to fixed income securities to achieve best execution for the Client. In such instances, the Client will complete additional authorizations with the Custodian for the discretionary authority to trade away from the Custodian. Under this brokerage arrangement, the manager may execute fixed income securities away from the Client’s Custodian [at another broker-dealer] through a prime brokerage arrangement and deliver the bond to the Client’s Account[s] for custody. The Custodian may also charge an additional trade-away fee for these transactions in addition to the normal securities transaction costs. Clients will be provided with the Disclosure Brochure (Form ADV Part 2) of the portfolio manager. Where BPWP 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 recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by BPWP. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. BPWP 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. BPWP will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), or Fidelity Clearing & Custody Solutions and related entities of Fidelity Investments, Inc. (collectively “Fidelity”). Each institution is a FINRA-registered broker-dealer and member SIPC. The designated custodian will serve as the Client’s “qualified custodian. BPWP maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. BPWP does not maintain an institutional relationship with Fidelity, but is able to utilize these custodians through the firm’s relationship with Buckingham Strategic Partners. 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. BPWP does not participate in soft dollar programs sponsored or offered by any broker- BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 13 https://www.brightpathwealth.com/  dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - BPWP 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 BPWP 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]). BPWP 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. BPWP will execute its transactions through the Custodian as authorized by the Client. BPWP 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 Peter Kozak, Chief Compliance Officer of BPWP. 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 BPWP 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 BPWP BPWP is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. BPWP does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. BPWP may refer Clients to various unaffiliated, non-advisory professionals (e.g. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 14 https://www.brightpathwealth.com/  attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, BPWP may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform BPWP has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like BPWP. As a registered investment advisor participating on the Schwab Advisor Services platform, BPWP 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 BPWP that may not benefit the Client, including: educational conferences and events, 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. BPWP believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. BPWP also receives software from DFA, which BPWP utilizes in forming assets allocation strategies and producing performance reports. DFA also provides continuing education for BPWP personnel. These services are designed to assist BPWP plan and design its services for business growth. B. Compensation for Client Referrals BPWP does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody BPWP 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 BPWP 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 BPWP 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 BPWP to ensure accuracy, as the Custodian does not perform this review. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 15 https://www.brightpathwealth.com/  Money Movement Authorization - For instances where Clients authorize BPWP to move funds between their accounts, BPWP and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Item 16 – Investment Discretion BPWP 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 BPWP. 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 BPWP will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities BPWP does not accept proxy-voting responsibility for any Client. 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. Item 18 – Financial Information Neither BPWP, nor its management, have any adverse financial situations that would reasonably impair the ability of BPWP to meet all obligations to its Clients. Neither BPWP, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. BPWP 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. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 16 https://www.brightpathwealth.com/  Form ADV Part 2B – Brochure Supplement for Peter Kozak Managing Member and Chief Compliance Officer Effective: March 13, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Peter Kozak (CRD# 2765784) in addition to the information contained in the BrightPath Wealth Planning, LLC (“BPWP” or the “Advisor”, CRD# 160563) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the BPWP Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (805) 764-0335. Additional information about Mr. Kozak is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2765784. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 17 https://www.brightpathwealth.com/  Item 2 – Educational Background and Business Experience Peter Kozak is dedicated to advising Clients of BPWP as the Managing Member and Chief Compliance Officer. Mr. Kozak earned a Bachelors of Arts in Economics from University of California Los Angeles (UCLA) in 1985. Mr. Kozak also earned a CFP designation from College for Financial Planning in 1997. Additional information regarding Mr. Kozak’s employment history is included below. Employment History: 04/2012 to Present Managing Member and Chief Compliance Officer, BrightPath Wealth Planning, LLC Principal/Owner, Kozak Financial Advisory Investment Advisor/Planner, Walpole Financial Advisors LLC Investment Advisor/Planner, Petra Financial Advisors 07/2004 to 04/2012 07/2004 to 12/2009 01/2000 to 07/2004 CERTIFIED FINANCIAL PLANNER™ (“CFP®”) The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: ● Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP® Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; ● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; ● Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and ● Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: ● Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and ● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP® Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 18 https://www.brightpathwealth.com/  Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Kozak. Mr. Kozak has never been involved in any regulatory, civil or criminal action. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Kozak. However, we do encourage you to independently view the background of Mr. Kozak on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2765784. Item 4 – Other Business Activities Mr. Kozak is dedicated to the investment advisory activities of BPWP’s Clients. Mr. Kozak does not have any other business activities. Item 5 – Additional Compensation Mr. Kozak is dedicated to the investment advisory activities of BPWP’s Clients. Mr. Kozak does not receive any additional forms of compensation. Item 6 – Supervision Mr. Kozak serves as the Managing Member and Chief Compliance Officer of BPWP. Mr. Kozak can be reached at (805) 764-0335. BPWP has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of BPWP. Further, BPWP is subject to regulatory oversight by various agencies. These agencies require registration by BPWP and its Supervised Persons. As a registered entity, BPWP is subject to examinations by regulators, which may be announced or unannounced. BPWP is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 19 https://www.brightpathwealth.com/  Privacy Policy Effective: March 13, 2025 Our Commitment to You BrightPath Wealth Planning, LLC (“BPWP” 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. BPWP (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. BPWP 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 What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents 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. We require third parties that assist in providing our services to you to protect the personal information they receive from us. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 20 https://www.brightpathwealth.com/  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. No Not Shared Marketing Purposes BPWP 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 BPWP 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 BPWP 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. 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. 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 (805) 764-0335. BrightPath Wealth Planning, LLC 5999 Ridge View Street, Suite B, Camarillo, CA 93012 Phone: (805) 764-0335 | Fax: (805) 272-9737 Page 21 https://www.brightpathwealth.com/