HORAN SECURITIES, INC.

Client Relationship Summary March 26. 2025 Item 1: Introduction HORAN Securities, Inc., (“HSI”, “we”, “us”, “the firm”), is registered with the U.S. Securities and Exchange Commission (“SEC”) as an Investment Adviser. Brokerage and investment advisory services and fees differ, and it is important that you understand the differences. This document gives you a summary of the types of services and fees we offer. Please visit www.investor.gov/CRS for free, simple tools to research firms and financial professionals, as well as educational materials about broker-dealers, investment advisers, and investing. Item 2: Relationships and Services What investment services and advice can you provide me? We offer investment advisory services to retail investors such as comprehensive portfolio management, Financial Planning & Consulting, Retirement Plan Consulting and Utilization of Third-Party Separately Managed Account Programs through Fidelity Brokerage Services, LLC. We will provide ongoing advice on a regular basis through our Asset Management Services. We will discuss your investment goals and work with you to design a strategy to achieve your investment goals. We will monitor your account regularly as agreed upon in your advisory agreement with us and will meet with you no less than annually to discuss your portfolio. Other services such as Financial Planning & Consulting may be offered on a one-time, ongoing or as needed basis and are generally targeted to a specific circumstance as detailed in your agreement with us. You can choose an account that allows us to buy and sell investments in your account without asking you in advance (a “discretionary account”) or we may give you advice and you decide what investments to buy and sell (a “non- discretionary account”). Our investment advice will cover a broad range of investments which may include stocks, bonds, mutual funds, exchange traded funds and brokered certificates of deposit (e.g. CDs) among others. The range of investment options available to you may be limited depending on your investment size, ability to meet account minimum requirements, your personal risk tolerances, suitability and other factors. Other firms could provide advice on a wider range of choices, some of which might have lower costs. We generally require a minimum of $100,000 in investable assets for our Asset Management Services. However, at our discretion we may negotiate or waive this minimum depending on client needs and complexity. We encourage you to ask your Professional whether any investment limitations or account requirements apply. For Additional information, please see the HORAN Securities, Inc. ADV Part 2A Firm Brochure (Items 4 and 7). Conversation Starters: Ask your financial professional: ✓ Given my financial situation, should I choose an investment advisory service? Why or why not? ✓ How will you choose investments to recommend for my account? ✓ What is your relevant experience, including education and certifications? Explain any designations that you have. Item 3: Fees, Costs, Conflicts of Interest, and Standard of Conduct We are held to a fiduciary standard that covers our entire investment advisory relationship with you. For example, we are required to monitor your portfolio, investment strategy and investments within the portfolio on an ongoing basis. While underlying securities within accounts are continuously monitored, each account will be reviewed periodically or by client request. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as client's individual circumstances, severe market fluctuations, or adverse political or economic environments. Our interests can conflict with your interests. We must eliminate these conflicts or tell you about them in a way you can understand, so that you can decide whether-or-not to agree to them. What fees will I pay? Our fees vary and are negotiable. The amount you pay will depend, for example, on the services you receive and the amount of assets in your account. Fee arrangements can be fixed or tiered depending on the services provided. For our Asset Management Services, the fee ranges from .75%-1.25% for the HCA Program and .70% - 1% for the HIS Program paid monthly in arrears. The fees for each program are generally laddered from the first $1 million to over $5 million. One-time Financial Planning and Consulting fees have a minimum fee of $2,500 and require 50% payment in advance of services with the remainder due upon delivery of a written plan or completion of services. For ongoing Financial Planning and Consulting Services you will pay our agreed upon fee quarterly in arrears by check or ACH. The more assets you have in your advisory account, including cash, the more you will pay us. We therefore have an incentive to increase the assets in your account in order to increase our fees. You pay our quarterly or monthly fee even if you do not buy or sell in your account. In addition to our advisory fees, clients may also pay customary custodian fees such as account maintenance fees and transaction fees. Additionally, clients might 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. You will pay fees and costs whether you make money or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. CRS pg. 1  Customer Relationship Summary (Form CRS) March 25, 2025 For Additional information, please see the HORAN Securities, Inc. Form ADV Part 2A Firm Brochure (Items 4 and 5) Conversation Starter: Ask your financial professional: Help me understand how fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me? What are your legal obligations to me when acting as my investment advisor? How else does your firm make money and what conflicts of interest do you have? When we act as your investment adviser, we must act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means. Some of our financial professionals are registered representatives of M Holdings Securities, Inc. (“M”), a registered broker-dealer. In addition to our services, financial professionals registered with M will earn commission-based compensation for transactions implemented through M. The commissions earned are separate from our advisory fees, which creates a financial incentive to recommend that you implement commissionable transactions through this broker-dealer relationship. Some of our financial professionals are licensed insurance agents through our affiliate, Horan Securities, Inc. and will earn commission- based compensation for insurance products and services. The commissions earned are separate from our advisory fees, which creates a financial incentive to recommend that you implement commissionable transactions through this broker-dealer relationship. All HORAN affiliated employees, in good standing and after background review, can enter into a promotor arrangement with HSI. Employees that refer business to HSI will receive a promotor fee of 10% of the first year’s revenue derived from the assets under management. For Additional information, please see the HORAN Securities, Inc. Form ADV Part 2A Firm Brochure (Items 10 and 14) Conversation Starter: Ask your financial professional ✓ How might your conflicts of interest affect me, and how will you address them? How do your financial professionals make money? Our financial professionals are compensated through advisory fees and financial planning/consulting fees. Some of our financial professionals also make money from commissionable transactions as representatives of a broker- dealer and through commissions earned as insurance agents/brokers. For additional information please also see items 4, 5 and 10 of our ADV Part 2 A Firm Disclosure Brochure. Item 4: Disciplinary History Do you or your financial professionals have legal or disciplinary history? No. Please visit www.Investor.gov/CRS for a free and simple search tool to research us and our financial professionals. Conversation Starter: Ask your financial professional: ✓ As a financial professional, do you have any disciplinary history? For what type of conduct? Item 5: Additional Information For additional information about our services, please review the HORAN Securities, Inc. ADV Part 2A Firm Brochure and the financial professionals ADV Part 2B Individual Brochure. If you would like additional, up-to-date information or a copy of the disclosure brochures, please call us at 513.745.0707 or email Connie Grosser, Chief Compliance Officer at ConnieG@horanwealth.com. Additional information about HORAN Securities, Inc. is also available by searching our firm name or CRD # on the SEC’s website at www.adviserinfo.sec.gov. HSI’s CRD number is: 40794. Conversation Starter: Ask your financial professional: ✓ Who is my primary contact person? Is he or she a representative of an investment adviser or broker-dealer? ✓ Who can I talk to if I have concerns about how this person is treating me? 2 | 2 

Form ADV - Part 2A Disclosure Brochure – March 28, 2025 This disclosure program brochure provides information about the qualifications and business practices of HORAN Wealth Management (“HWM”). If you have any questions about the contents of this document, please contact us at 513.745.0707 or by email at compliance@horanwealth.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 information about HWM is available on the SEC’s website at www.advisorinfo.sec.gov by searching HORAN Wealth Management. Registration as an Investment Adviser does not imply a certain level of skill or training. HORAN Wealth Management / 8044 Montgomery Rd, Ste 640 / Cincinnati, OH 45236 513.745.0707 / www.horanwealth.com Item 1: Cover  Form ADV Part 2A Disclosure Brochure Item 2: Table of Contents Item 1 – Cover Page ....................................................................................................................................... 1 Item 2 – Table of Contents ............................................................................................................................ 2 Item 3 – Material Changes ............................................................................................................................ 3 Item 4 – Advisory Business ............................................................................................................................ 4 Item 5 – Fees and Compensation .................................................................................................................. 8 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................ 11 Item 7 – Types of Clients ............................................................................................................................. 11 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 11 Item 9 – Disciplinary Information ................................................................................................................ 16 Item 10 – Other Financial Industry Activities and Affiliations ..................................................................... 16 Item 11 – Code of Ethics .............................................................................................................................. 18 Item 12 – Brokerage Practices ..................................................................................................................... 19 Item 13 – Review of Accounts ..................................................................................................................... 22 Item 14 – Client Referrals and Other Compensation .................................................................................. 23 Item 15 – Custody ....................................................................................................................................... 23 Item 16 – Investment Discretion ................................................................................................................. 24 Item 17 – Voting Client Securities .............................................................................................................. 25 Item 18 – Financial Information ………………………………………………………………………………………………….…….…….25 513.745.0707 | www.horanwealth.com 2  Form ADV Part 2A Disclosure Brochure Item 3: Material Changes Changes made since the February 10, 2025, annual filing include: • • • • • • • Item 4 – Advisory Business has been updated to reflect the departure of one owner. Terence Horan remains the majority shareholder. Item 4 – Advisory Business has been updated to reflect that HWM is no longer dually registered, and now transacts broker-dealer business through M Holdings Securities, Inc. Item 4 – Advisory Business has been updated to reflect the addition of Third Party Separately Managed Account Programs. Item 4 – Advisory Business has been updated to reflect the addition of a program (through Right Capital) to manage participant level 401(k) accounts. Item 5 – Fees for Asset Management Services has been updated to include an in-depth discussion on fees and conflicts associated with those fees. Item 12 – Brokerage Practices has been updated to include information on Directed Brokerage. Item 12 – Brokerage Practices has been updated to include information on soft dollars which HWM does not participate in at this time. We may update this brochure at any time. If we make any material changes relating to Item 9-Disciplinary Information, we will provide you either (i) a complete copy of our Firm Brochure that includes or is accompanied by a summary of material changes or (ii) a summary of material changes that includes an offer to provide a copy of the current HWM Brochure. We urge you to carefully review all the material summaries as they will contain information about significant changes to our advisory services, fee structure, business practices, conflicts of interest and disciplinary history. To receive a complete copy of our Firm Brochure at no charge, please visit our website at www.horanwealth.com/disclosures, or contact our Compliance Department by phone, 513.745.0707, or email at compliance@horanwealth.com. 513.745.0707 | www.horanwealth.com 3  Form ADV Part 2B Disclosure Brochure Item 4: Advisory Business Description of our Firm & Principal Owners HORAN Wealth Management (“HWM”) is an SEC Registered Investment. We offer a variety of advisory services that are made available to clients through individuals associated with us as investment advisor representatives “(IARs or IAR)”. Material ownership in HWM is held by three parties – Terence Horan, Michael Napier, and Gregory Hoernschemeyer. Mr. Terence Horan is the majority shareholder. Mr. Terence Horan is also a direct shareholder with affiliated advisor, HORAN Capital Advisory, LLC (HCA). Introduction When acting as an investment adviser, we and our IARs have a fiduciary duty to our advisory clients and must make full and fair disclosure to our advisory clients relating to our advisory relationships. As a fiduciary, we aim to always put your interest ahead of our own, identify material conflicts, and eliminate, mitigate and/or disclose these conflicts. An IAR may be registered with HWM’s partner broker-dealer, M Securities (“M”) as a broker-dealer registered representative and/or appointed as an agent with insurance companies. In these instances, an IAR may recommend fee-based investment advisory services, commission- based accounts, annuities, or other insurance products. Depending on the IAR’s licensing and affiliations with HWM, the IAR may be restricted as to the services or products they are able to offer or choose to offer a limited number of services such as financial planning and consulting. Before engaging with an IAR, you should discuss the many differences between broker-dealer and advisory relationships as well as any limitations in the services your IAR offers. It’s important to understand the associated costs and benefits of each option so that you can decide which types of accounts and services may be best suited for your unique financial goals, risk tolerance, investment objectives and time horizon. You should bear in mind that your total cost for transactions under a fee account versus a commission account can vary significantly and depend on several facts such as account size, volume of trading activity (number of transactions), type and quantity of investments purchased or sold, anticipated holding period for the investments in your account, potential risk and return, and commission rates. Description of Primary Advisory Services Our advisory services primarily consist of asset management services, financial planning, and consulting as well as retirement plan advisory services. Our services are designed to provide investment programs that are suitable for our client’s financial goals, objectives, and risk tolerances. HWM typically provides portfolio advisory services to high-net-worth individuals and institutions. In general, clients are required to have a minimum opening investment account size of $100,000. However, the decision to engage in an investment advisory relationship with a client remains the sole discretion of HWM regardless of account balance/size. Asset Management Services We offer fee-based asset management services through portfolios or custom strategies created by HWM. The types of investments that your IAR may purchase and sell for your account include, but are not 513.745.0707 | www.horanwealth.com 4  Form ADV Part 2B Disclosure Brochure limited to, mutual funds, exchange traded funds (“ETFs”), structured products, interval funds, stocks, bonds, money market funds (otherwise known as “securities”), brokered certificates of deposit (“brokered CDs”) (which may or may not be securities), and cash. Your IAR may also recommend the purchase of a fee based variable annuity or life insurance product and make recommendations on subaccounts to develop a portfolio which may be diversified or concentrated in individual securities or sectors. Your IAR, will examine your investment objectives, risk tolerance, and other factors to recommend specific investments or strategies. When developing recommendations for you, IARs compare your financial goals with your investment risk tolerance and the risk potential of a specific investment or strategy. Your account will be managed on a discretionary or non-discretionary basis. In a discretionary account, we have the authority to buy or sell investments without contacting you in advance. You may withdraw this authority at any time by providing written notice to HWM and/or your IAR. Non-discretionary accounts are accounts where your IAR provides recommendations as to the purchase or sale of specific investments, however your IAR does not place orders to buy or sell investments without first receiving your authorization. If your IAR manages your account on a non-discretionary basis, you must be willing to accept that your IAR cannot buy or sell investments in your account without your prior consent. If you are unavailable, we will not be able to buy or sell any investments (as we would for our discretionary clients) should there be a market correction or if we determine that a particular investment should be bought or sold for our client accounts. Clients can place reasonable restrictions on certain types of investments. If you own multi-share class mutual funds in a discretionary or non-discretionary account, HWM will direct the broker/dealer, clearing firm or custodian of your account to convert the mutual funds shares you own to the lowest cost share class available to us for the same funds at no cost or tax consequences to you. Conversions will be made quarterly and such conversions will be made without notice. HWM will utilize the mutual fund share classes available for the model portfolios or investment strategies we offer. This could result in client’s owning share classes where a lower cost share class is available to us. Financial Planning & Consulting We offer financial planning and ongoing consulting services on a fee basis to help you achieve your stated financial goals and objectives. Financial planning and consulting services include personal and/or business planning and can be either comprehensive or narrowly tailored to address specific areas. Personal financial planning and consulting services may include a cash flow and net worth analysis as well as risk management and insurance planning, tax planning, investment planning, education, and estate planning. Business plans may include an assessment of your business’ current and projected balance sheet, income statement and other data helpful in assessing a business’ capital and liquidity requirements; key financial ratios, tax trends, operational reserves, retirement plan options for employees; and business continuation plans such as the loss of key employees. Your IAR will ask you to provide financial information and documentation to assist them in developing a financial plan. One or more meetings may be required to gather all information necessary to develop a plan appropriate for your needs. If requested, your IAR may also work closely with your attorney, accountant, or other professionals to develop a comprehensive plan. Any consultation or coordination required will be considered when determining your fee. You are under no obligation to engage our firm for additional services or implement any financial recommendations made by your IAR. In that case you would not receive the services we provide which are 513.745.0707 | www.horanwealth.com 5  Form ADV Part 2B Disclosure Brochure designed, among other things, to assist you in determining which investments, investment strategies or programs may be most appropriate for your circumstances. Third Party Separately Managed Account Programs We offer investment advisory services and programs of third-party investment advisers where our IAR provides non-discretionary recommendations of third-party investment advisers’ programs and related client relationship services. On a limited basis, your IAR may be granted discretionary authority to select investment strategies offered through the third-party investment adviser. Through these programs, third- party investment advisers provide ongoing discretionary investment management. Assets for the programs will be held with custodians selected by the third-party investment advisers. Third-party advisory relationships offered through our firm typically impose a minimum dollar value of assets for establishing or maintaining an account. Fees charged by the third-party investment advisor are part of the fees for the HSI Program discussed in Item 5 below. If you engage in any of these programs, you should read a copy of the program agreement and any relevant disclosure documents for detailed information about services, fees, and account minimums including the ADV Part2A provided by HWM and the third-party manager. Retirement Plan Advisory Services We provide a variety of services for compensation to ERISA plan fiduciaries and plan participants. Our IARs may provide investment education to ERISA plan fiduciaries and plan participants; act as a 3(21)- investment advice fiduciary to provide ongoing non-discretionary investment advisory services, as well as non-fiduciary consulting services to plan sponsors; or act as a 3(38)-investment management fiduciary having discretionary authority over an ERISA retirement plan account. When providing services to retirement plan sponsors, HWM must enter into either a consulting and advisory services or non-fiduciary services agreement with the plan sponsor. The scope of investment education provided to participants at the request of the plan sponsor will not constitute “investment advice” within the meaning of ERISA. Participant education will relate to general principles of investing and information about the investment options currently in the plan. The IAR may also participate in initial enrollment meetings, periodic workshops, and enrollment meetings for new participants as agreed upon between HWM and plan sponsor. Retirement plan advisory services are typically offered to plan sponsors of participant directed retirement plans, including 401(k) plans that a company establishes for its employees. The IAR will generally establish the plan sponsor’s needs and objectives through an initial meeting to collect data and review plan information and assist the sponsor in developing or updating the plan’s Investment Policy Statement. Ongoing advisory services to the plan sponsor may include recommendations regarding the selection and review of investment options. If HWM is engaged to provide fiduciary investment advice, HWM will periodically review the investment options selected by the plan sponsor and make recommendations to keep or replace investment options as appropriate. Plan sponsors are under no obligation to follow the recommendations of HWM. IARs may provide general investment-related guidance, investment education and information about investment options and rollovers to a retirement plan fiduciary and to its participants without being considered a 3(21)-investment advice fiduciary. An IAR can provide investment advice to a plan while also providing investment education to plan participants. IARs can also be authorized to have discretionary authority (i.e., act as a (3(38) Investment Management Fiduciary) over an ERISA retirement plan account. 513.745.0707 | www.horanwealth.com 6  Form ADV Part 2B Disclosure Brochure Retirement Accounts Guidance from the US Department of Labor (“DOL”) under Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code (“Code”), requires HWM to inform you when we and our IARs provide non-discretionary investment advice, including recommendation of our advisory program(s) to you regarding your ERISA retirement plan or participant account or individual retirement account (which are all referred to as “retirement accounts”), that we and our financial professionals are fiduciaries within the meaning of Title I of ERISA and/or the Code as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interest, so for retirement accounts we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Regulations under ERISA and the Code define investment advice as (1) advice or recommendations, for a fee or other compensation, regarding investing in, purchasing or selling securities or other property to a plan, plan participant, or IRA owner; (2) provided on a regular basis; (3) where the advice is provided pursuant to a mutual agreement or understanding; (4) the advice serves as a primary basis for investment decisions with respect to the plan or IRA assets; and (5) the advice is individualized to the plan, participant or IRA owner. Retirement Plan Rollovers When leaving an employer, you typically have four options regarding your existing retirement plan: (1) leave the assets in the former employer’s plan, if permitted, (2) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (3) roll over the assets to an Individual Retirement Account (“IRA”), or (4) take a full withdrawal in cash, which would result in ordinary income tax and a penalty tax if you are under age 59-1/2. If your IAR recommends that you roll over your 401(k) or other qualified plan assets to an IRA, this rollover recommendation presents a conflict of interest in that we and your IAR would receive compensation (or may increase current cost) when investment advice is provided following your decision to roll over your plan assets. Your IAR will discuss your retirement plan options including retention of your 401(k) or qualified plan assets with your current plan, if allowed. Prior to making a rollover decision, you should carefully review the information regarding your rollover options and are under no obligation to roll over retirement plan assets to an account managed by us. General Disclosure Regarding ERISA Qualified Accounts If an advisory account is a retirement account subject to the provisions of Title I of ERISA (ERISA) and/or Internal Revenue Code section 4975(c)1) (IRC), we and our IARs who act as a fiduciary by providing investment advice for such retirement accounts (“Qualified Account”) are generally prohibited from receiving both an advisory fee and any transaction-based compensation unless in compliance with applicable prohibited transaction exemptions under ERISA or the IRC or authorized by the U.S. Department of Labor. You will represent that the Qualified Account and any instructions given by you regarding the Qualified Account are consistent with applicable Plan documents, including any investment policies, guidelines, or restrictions. You will provide us with a copy of all relevant documents and agree that the advisory program you have selected is consistent with those documents. You will notify us, promptly in writing, of any changes to any of the Plan’s investment policies, guidelines, or restrictions, or other Plan documents pertaining to investments by the Plan. If the assets in the Qualified Account constitute only a part of your Plan assets, you shall provide us with documentation of any of the Plan’s investment guidelines or policies that affect the Qualified Account. The compliance of any recommendation or investment your IAR makes for the Qualified Account with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. You have the 513.745.0707 | www.horanwealth.com 7  Form ADV Part 2B Disclosure Brochure responsibility to give us prompt written notice if any investments made for the Qualified Account are inconsistent with such guidelines, policies, restrictions, or instructions. You understand that the services that we perform shall have no effect on the assets of the Plan that are not in the Qualified Account, and that we shall have no responsibility for such other assets. We are not responsible for Plan administration or for performing any other duties that are not expressly set forth in the advisory agreement. You shall obtain and maintain at your own expense any insurance or bonds you deem necessary to cover yourself and any of your affiliates, officers, directors, employees, and agents in connection with the advisory services HWM provides. Participant 401(k)’s Managed Through Future Capital In some cases, HWM utilizes Future Capital, a technology platform, through which HWM provides financial advisory services to our clients for accounts such as defined contribution plan participant accounts, including 401(k)s. This platform is available to clients for no additional cost. Advisor does not have direct access to the client's login credentials; these are provided directly to Future Capital by the client. Clients are given a link to connect their accounts to the platform, enabling Advisor to access account-related data and offer investment advisory services. Fees charged by Future Capital are part of the fees for the HSI Program discussed in Item 5 below. The use of Future Capital is governed by its end user terms and privacy policy, which clients can review during the signup process. How Services are Tailored to Fit Your Needs When you open an account with us or consult one of our IARs for a financial plan, your IAR will obtain the necessary financial data from you in the form of a Client Data Sheet and/or a New Account Form. Your IAR will examine your investment objectives, risk tolerance, and other factors to recommend specific investments or advisory programs to suit your needs. If there are any changes to this information, please notify your IAR immediately. Your IAR will review your account annually or more frequently as necessary to determine whether your assets should be reallocated due to changes in your financial situation, the market, or other conditions. The investment advisory services provided largely depend on the personal information you provide. In order for your IAR to provide appropriate investment advice to, or in the case of discretionary accounts, make appropriate investment decisions for you, it is important that you provide accurate and complete responses to your IAR’s questions about your financial condition, investment objectives and needs as well as any reasonable investment restrictions you wish to apply to the investments or types of investments, to be bought, sold, or held in your account. It is also important for you to inform your IAR of any changes to your personal or financial circumstances, investment objectives or risk tolerance as well as any reasonable investment restrictions which may affect the advice provided. Assets Under Management As of December 31, 2024, HWM had $698,229,909 in assets under management, of which $696,990,101 was managed on a discretionary basis and $1,239,808 was managed on a non-discretionary basis. Item 5: Fees and Compensation Fees for Asset Management Services Fees paid to your IAR for investment advisory services (“IAR Fee”) are negotiable which may include excluding positions in your account from the IAR fee. Program fees charged by HWM or third parties for 513.745.0707 | www.horanwealth.com 8  Form ADV Part 2B Disclosure Brochure administrative services are not negotiable. IARs are permitted to offer advisory services and charge fees in accordance with the descriptions detailed in this document. However, the exact services you will receive and the fees you will be charged are dependent upon the complexity of your financial situation, the investment services to be provided, the experience and standard fees charged by your IAR, and the nature and total dollar value of assets maintained in your account. Fees are typically charged based on a percentage of your account value as determined by the custodian of your account, and include all positions in the account including cash, money market funds and brokered CDs unless specifically excluded by policy or by agreement with your IAR. It is important to note that in periods where securities outperform, holding cash, money market funds and brokered CDs in your account can significantly reduce your returns when you pay advisory fees on these types of investments. Advisory programs have additional fees such as platform fees, transaction fees, fees to third-party investment advisers and clearing and custodial fees that are separate from your IAR’s fee. A portion of your total fee may be allocated to an administrative fee which is paid to HWM and covers administrative and supervisory services. The administrative fee may be based on a sliding scale depending on the size of the assets in the account or a flat fee. Notwithstanding the foregoing, all withdrawals from your account, apart from any fees automatically deducted from your account pursuant to your advisory agreement or your brokerage account agreement, are required to be authorized by you. A discounted administrative fee is available to IARs based upon the aggregate total of account fee billings of all clients your IAR maintains in an advisory program. If your IAR receives a discounted administrative fee, your IAR’s compensation will increase by the amount of the discount received. Your total account fee and cost will remain unchanged. As such, your IAR has an incentive to utilize a program that offers discounted administrative fees to increase his or her overall compensation. These fees are outlined in more detail below. Fee arrangements can be either linear or tiered depending on the program selected. Some programs provide both linear and tiered fee options. When choosing a linear fee arrangement, you will pay a fixed percentage on the entire value of the account that cannot exceed the maximum fee for any tier. For example, if the fixed fee is 1.00%, this amount would be applied to the total account value. In a tiered fee arrangement, once the value of your account meets the next tier, the new rate will be applied to all assets above the tier up to the next tier. For example, you will pay 2.00% on the first $250,000 in assets, 1.75% on the next $250,000, and so on. The IAR Fee will be offset proportionally for mutual fund Class A and B shares or unit investment trusts (“UITs”) that were subject to a commission and sold to you by a registered representative on a commission basis and these shares are transferred to your advisory account within two years of the date of purchase. Offsets will not be applied to matured UITs and will only be applied if the amount of the offset is $100 or more. In addition, the value of any annuity, investment designated as an “alternative investment product,” or mutual fund Class C shares will be excluded from the IAR fee if you purchased it in a commission-based account through a registered representative of AIC and then transferred it to your advisory account. However, if an annuity was purchased at Net Asset Value (“NAV”) (in other words, purchased for no commission), then that annuity will be subject to the IAR Fee. Other investments including but not limited to stocks, bonds, ETFs, UITs, structured products, mutual funds, brokered CDs, money market funds, and cash transferred into your program account, purchased at AIC, or at another broker/dealer, are subject to the investment advisory fee agreed upon in your advisory agreement. At the discretion of your IAR, certain holdings may be excluded from billing as well. You should discuss fee exclusions with your IAR prior to opening an account. 513.745.0707 | www.horanwealth.com 9  Form ADV Part 2B Disclosure Brochure The following fee schedules typically apply for actively monitored discretionary advisory services provided by HWM, including cases for which a sub-advisory arrangement is considered most suitable. For HORAN Wealth Management Directly Managed Accounts: For HORAN Wealth Management Accounts Sub-Advised by HORAN Capital Advisors, LLC: For accounts shared between HWM and HCA, higher fees are applied compared to those managed directly by HWM. Under the sub-advisory arrangement, a portion of the advisory fee is paid to both entities under the terms of a Sub-Advisory Agreement between the entities. This incentivizes both entities to utilize each other’s services because of the higher fee schedule, referral opportunities, and fee sharing arrangements. Financial Planning for Non-Managed Advisory Services • $400 for a comprehensive analysis and development of formal Client Investment Plan • $200 per hour ($50 per quarter hour) for investment guidance requested Social Security Consulting • $300 for a detailed social security analysis • $100 for filing purposes (per individual) • Fees waived if client becomes an investment management client (>$50,000 of assets) Fee Payment Methods and Frequency Fees for advisory services may vary from client to client based on the type and level of service provided and under certain circumstances may be waived. Such circumstances may take into consideration management obligations, complexity of account, advisory arrangements, excluding positions in your account from the IAR fee, and/or other services required. The minimum account size requirements may be waived at our discretion. Fees for general financial planning services and consulting services are based on either an hourly fee or flat fee by specific project. We charge fees monthly in arrears. Fees are based on the month-end balance of your account and are assessed within 10 business days of month-end. Fees are deducted from your account. Fees for comparable services may be higher or lower if you obtain them from other sources. The fees charged are incorporated into the Investment Advisory Program Agreement you sign with HWM. One-time financial planning and consulting fees are typically collected as follows: 50% of the agreed upon fee is payable in advance of services, with the remaining 50% due upon delivery of the plan. In certain situations, your IAR may allow you to pay 100% of the agreed upon fee upon delivery of the plan. You also 513.745.0707 | www.horanwealth.com 10  Form ADV Part 2B Disclosure Brochure may elect to pay up to 100% of the fee prior to delivery of plan. However, an IAR may not collect more than $1,200 in fees more than six months in advance of completion of your plan. You can pay ongoing financial planning and consulting services by check or ACH. Fees will be billed quarterly. Other Fees It is important to remember that there may be fees assessed by the custodian related to the purchase, sale, or holding of securities. These fees are a “pass through expense” and documented on the confirmation statements and/or account statements. In addition, our management fees are separate and distinct from the fees and expenses charged internally by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. These fees are not paid by HWM. A client could invest in mutual funds and/or ETFs directly without the services of our HWM. In that case, the client would not receive the services provided by the HWM (unless engaging in fee-based advisory services) which are designed, among other things, to assist the client in determining which investments are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the investments and the fees charged by HWM to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. HWM Advisors are available to discuss all fee related matters. In rare situations HWM may offer advisory services for a fixed fee. In this type of relationship, the fee would be agreed upon in writing and would be deducted monthly. We maintain policies and procedures requiring that your IAR always act in your best interest and maintain a supervisory structure to monitor the advisory activities of your IAR to reduce potential conflicts of interest. Item 6: Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Nor do we engage in side-by-side management (managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees). Item 7: Types of Clients HWM provides portfolio management services to individuals, trusts, corporations, corporate pension and profit-sharing plans, estates, charitable organizations, foundations and endowments. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Our advisors manage client portfolios with a belief that asset allocation, diversification, security selection and portfolio rebalancing are the primary drivers in investment success. Some advisors of HWM sit on our Investment Committee, and this committee is responsible for determining the strategies to be 513.745.0707 | www.horanwealth.com 11  Form ADV Part 2B Disclosure Brochure employed in client portfolios. HWM specializes in managing client portfolios primarily comprised of ETFs, open-end or closed-end bond and/or equity funds and other appropriate investment products. HWM manages client accounts with strategies designed to pursue each client’s goals and objectives through an interview process and/or formal investment policy statement. Our core approach focuses on the pursuit of growth of principal by selecting what our investment committee perceives as high-quality securities that may frequently provide distributions of income. We select investments and manage risk through asset class diversification and tactical decision-making. Comprehensive research complemented with a disciplined, repeatable process is critical to our long-term investment success. Investing involves risks that investors should be sure they understand and should be prepared to bear. No investment strategy will guarantee a profit or prevent losses. As a firm, we do not favor any specific method of analysis over another, and therefore would not be considered to have one approach deemed to be a “significant strategy.” There are, however, a few common approaches that may be used while providing advice to clients as described below: • Asset Allocation: An investment strategy that aims to balance risk and reward by allocating assets among a variety of asset classes. At a high level, there are three main asset classes– equities (stocks), fixed income (bonds), and cash or cash equivalents–each of which have different risk and rewards. Asset classes are further divided into domestic and foreign investments with equities divided into small, mid, and large capitalization. Bonds have varying durations and credit quality. By diversifying a portfolio amongst a wide range of asset classes, investors seek to reduce (but not eliminate) the overall risk of a portfolio through avoiding overexposure to any one asset class during various market cycles. • Fundamental Analysis: A method of evaluating a security that involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure what is deemed to be the true value of the company’s stock compared to the current market value. The end goal of performing fundamental analysis is to produce a value that an investor can compare to the security’s current price and whether the security is over or under priced. • Technical Analysis: A method of evaluating securities by studying past price patterns and trends in the financial markets to predict the direction of the overall market, specific stocks, or both. Technical analysts do not attempt to measure a security’s intrinsic value, instead they use charts and other tools to identify patterns that suggest future activity. When looking at individual equities, a person using technical analysis generally believes that performance of the stock, rather than performance of the company itself, has more to do with a company’s future stock price. Investment Risks As mentioned above, regardless of the strategy or analysis used, all investments carry the risk of loss including the loss of principal invested. Some risks may be avoided or mitigated, while others are completely unavoidable. Some of the common risks you should consider prior to investing include, but are not limited to: • Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. 513.745.0707 | www.horanwealth.com 12  Form ADV Part 2B Disclosure Brochure • Market Risk: Investment values may fall for a variety of reasons, including economic, political, social, financial, widespread business continuity events (e. g., natural disasters, pandemics, etc.) and issuer-based factors, causing prices of stocks, bonds, and other investments to fall. • ETF Risks, including Net Asset Valuations and Tracking Error: ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track (“tracking error”) because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the future for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depositary Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange- traded equity securities, and for which market quotations or valuation may be limited or inaccurate. An ETF typically includes embedded expenses that reduce the fund’s net asset value and therefore directly affect the fund’s performance, a client’s portfolio performance and index benchmark comparison. Expenses of the fund generally include investment adviser management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses can change from time to time at the sole discretion of the ETF issuer. ETF tracking errors and expenses may vary. • Inflation Risk: If any type of inflation is present, a dollar today will not buy as much as a dollar at the same subsequent time, because purchasing power is eroded at the rate of inflation. Inflation tends to erode returns on investments, as well. • Portfolio Turnover Risk: Active and frequent trading of securities and financial instruments in a portfolio can result in increased transaction costs, including potentially substantial brokerage commissions, fees, and other transaction costs. In addition, frequent trading is likely to result in short-term capital gains tax treatment. As a result of portfolio turnover, the performance of a portfolio can be adversely impacted. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (e. g., interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it (a lengthy process) before they can generate a profit. They have a greater uncertainty of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Financial Risk: Excessive borrowing to finance a business’s operations increases the uncertainty of profitability, because the company must meet the terms of its obligations in good times and 513.745.0707 | www.horanwealth.com 13  Form ADV Part 2B Disclosure Brochure bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Liquidity Risk: When consistent with a client’s investment objectives, guidelines, restrictions, and risk tolerances, we may invest portions of client portfolios in illiquid securities, subject to applicable investment standards. Investing in an illiquid (difficult to trade) security may restrict our ability to dispose of such investments in a timely fashion or at an advantageous price, which may limit the ability to take full advantage of market opportunities and result in delays in liquidity risk. • Money Market Fund Risks: An investment in a money market mutual fund, unlike bank deposits, is not insured or guaranteed by the FDIC or any other governmental agency, and it is possible to lose money by investing in a money market mutual fund. Money market mutual funds are covered by SIPC, which protects against the custodial risk (not a decline in market value) when a brokerage firm fails by replacing missing securities and cash up to a limit of $500,000, of which $250,000 may be cash. • Fixed Income Risks: Portfolios that invest in fixed income securities are subject to several general risks, including interest rate risk, credit risk, and market risk, which could reduce the yield that an investor receives from his or her portfolio. These risks may occur from fluctuations in interest rates, a change to an issuer’s individual situation or industry, or events in the financial markets. • Brokered CD Risks: Brokered CDs differ from traditional CDs purchased directly from your bank and held as a bank deposit, in that brokered CDs may have longer holding periods, may be more complex, may have different features and fees, and carry more risk. Although most brokered CDs are bank products, some may be securities and won’t be FDIC insured. Unlike a traditional CD, brokered CDs must be sold in the secondary market which may be quite limited. If you need to liquidate your brokered CD before it matures, the CD may be worth less than your initial investment particularly if current interest rates are higher than the CD you currently own. For brokered CDs with long holding periods, any interest you might receive could be significantly reduced by the advisory fee you pay. Some brokered CDs are callable and may be called by the issuer if interest rates go down. Make sure you understand the fees, features, and risks of the brokered CD you are considering. • High Yield Fixed Income Securities Risk: Investments in high-yielding, non-investment grade bonds (often referred to as “Junk Bonds”) involve higher risk than investment grade bonds. Adverse conditions may affect the issuer’s ability to make timely interest and principal payments on these securities. • Foreign, Emerging Markets Risk: Investments in these types of securities have considerable risks. Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility because of political and economic instability in the foreign country, less public information about issuers of securities, different securities regulation, different accounting, auditing and financial reporting standards and less liquidity than in the U.S. markets. • Structured Products Risk: Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign 513.745.0707 | www.horanwealth.com 14  Form ADV Part 2B Disclosure Brochure currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income maybe taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. • Interval Fund Risks: Interval funds may expose investors to liquidity risk. While an interval fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. Moreover, if an interval fund invests in companies with smaller market capitalizations, derivatives or securities that entail significant market or credit risk, the liquidity risk may be greater. • Alternative Investment Product Risk: An investment that is not one of the three traditional asset types (stocks, bonds, and cash) and generally has low correlations to stocks and bonds. Alternative Investments may have complex term and features that are not easily understood and are not suitable for all investors. Risks that may be associated with liquid alternative investments include: (1) Leverage – Leverage may enhance a fund’s returns in up markets but exacerbate returns in a bad market. Some firms with leverage inherent in their portfolios may experience “margin call” types of actions in the event of liquidity dry-ups or if certain counterparties cannot provide the leverage needed. (2) Shorting –Certain securities may be difficult to sell short at the price that the manager would wish to execute a trade. A short position may have the possibility of an infinite loss if a security continues to go up in price and the manager does not cover. (3) Security valuation – Certain securities held in alternative mutual funds, such as derivatives or thinly traded stocks, bonds or swaps may not have a market in which the money manager may need to trade it quickly in case of fund redemptions. High Bid/Ask spreads or the lack of another buyer/seller to take the opposite position of a thinly traded security could cause inaccurate estimates in underlying security valuation by the administrator. (4) Nightly reconciliation –The use of thinly traded securities, shorting and leverage may make it difficult for some alternative funds, based on their investment strategy, to provide accurate nightly NAVs for the mutual fund. • Derivatives (Options) Risk: Options involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss, including the loss of principal. • Small/Mid Cap Risk: Stocks of small or mid-sized companies may have less liquidity than those of larger, established companies and may be subject to greater price volatility and risk than the 513.745.0707 | www.horanwealth.com 15  Form ADV Part 2B Disclosure Brochure overall stock market. • Non-Diversification Risk: Investments that are concentrated in one or few industries or sectors may involve more risk than more diversified investments, including the potential for greater volatility. • American Depository Receipts (ADRs): Positions in those securities are not necessarily denominated in the same currency as the common stocks into which they may be converted. ADRs are receipts typically issued by an American bank or trust company evidencing ownership of the underlying securities. Generally, ADRs, in registered form, are designed for the U.S. securities markets. An account may invest in sponsored or unsponsored ADRs. In the case of an unsponsored ADR, shareholders are likely to bear their proportionate share of the expenses of the depository and they may have greater difficulty in receiving shareholder communications than they would have with a sponsored ADR. The above list of risk factors does not purport to be a complete list or explanation of the risks involved in an investment strategy. You are encouraged to consult your financial advisor, legal counsel, and tax professional on an initial and continuous basis in connection with selecting and engaging in the services provided by us. In addition, due to the dynamic nature of investments and markets, strategies may be subject to additional and different risk factors not discussed above. Your investments are not bank deposits, are not insured, or guaranteed by any governmental agency, entity, or person, unless otherwise noted and, as such, may lose value. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. You understand that investing involves risk of loss that you should be prepared to bear. Item 9: Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of HWM or the integrity of HWM’s management. Neither HWM nor any of its Advisors have derogatory disciplinary information to report. Item 10: Other Financial Industry Activities and Affiliations Broker – Dealer Affiliation Certain IARs of our firm may also be registered with an unaffiliated Broker-Dealer, M Holdings Securities, Inc , member of FINRA/ SIPC. In this separate capacity as a Broker-Dealer registered representative, the IAR will receive commissions for the implementation of recommendations for commissionable transactions in variable annuities, mutual funds and variable life insurance. This separate capacity creates a conflict of interest as these commissionable sales may create an incentive to recommend products based on the compensation they may earn, and which may not necessarily be in the best interests of the client. Clients are under no obligation to implement any recommendation made by the IAR in this capacity. Insurance Agency Affiliations Certain IARs of our firm are also licensed insurance agents through Horan Securities, Inc., an affiliated insurance company. In this separate capacity, the IAR will receive customary commissions and other related revenues from the various insurance companies whose products are sold. These activities and the implementation of insurance recommendations are separate and apart from the IAR’s role with 513.745.0707 | www.horanwealth.com 16  Form ADV Part 2B Disclosure Brochure Horan Wealth. This separate capacity creates a conflict of interest as these commissionable sales may create an incentive to recommend products based on the compensation they may earn, and which may not necessarily be in the best interests of the client. Clients are under no obligation to implement any recommendation made by the IAR in this capacity. Clients should be aware that the receipt of additional compensation in the form of commissions from the affiliations mentioned above creates a conflict of interest that may impair the objectivity of these IARs when making advisory recommendations. Horan Wealth endeavors at all times to put the interest of its clients first as part of our fiduciary duty. Dually Registered Investment Adviser Representatives Certain IARs of HWM are also registered as IARs with unaffiliated registered investment adviser firms. Through such unaffiliated investment adviser firms, IARs may provide asset management services or financial planning and consulting services and earn advisory fees for providing such services on behalf of the unaffiliated firm. Therefore, you could receive advisory services from one individual who can act as an IAR on behalf of two separate registered investment advisers. This dual registration is a conflict of interest because your IAR may receive more or less compensation as a result of his or her registration with HWM and the unaffiliated investment adviser and may have access to different programs and services. If the IAR provides services to you on behalf of HWM, you will be given the Disclosure Brochure of HWM and the IAR’s Form ADV Part 2B. If the services are being provided by the IAR on behalf of the unaffiliated firm, you should receive the Disclosure Brochure of that firm and the IAR’s Form ADV Part 2B of that firm. The brochures describe the services provided, fees charged, conflicts of interest and other important information. You are encouraged to read and review the disclosure brochures for both HWM and the unaffiliated investment adviser firm as well as client agreements and other disclosure documents provided. If you have questions regarding how these conflicts of interests impact you, you should direct questions to your IAR. From time to time, we or our supervised persons donate to charitable organizations that are affiliated with clients, are supported by clients, and/ or are supported by an individual employed by one of our clients. In general, such donations are made in response to requests from clients or their personnel. Because such contributions may result in the recommendation of our firm or our services, such contributions may raise a potential conflict of interest. As a result, we maintain procedures that generally limit the dollar amount and frequency of charitable contributions and require that all contributions are made directly to the charitable organization (normally a 501(c)(3) organization). No contribution will be made if the contribution implies that continued or future business with our firm or our supervised person depends on making such contribution. We require that our supervised persons seeking to make a political contribution to or volunteer for a state or local candidate, political action committee or political party pre-clear their contributions or activity through HWM. We do not require our supervised persons to pre-clear contributions to federal candidates unless the candidate is currently a state or local government official running for federal office. However, we do require supervised persons to notify us of any contributions made to or volunteer activity done on behalf of federal candidates, political action committees or political parties. HWM and your IAR are also subject to local and state pay-to-play rules in addition to federal securities rules and regulations. 513.745.0707 | www.horanwealth.com 17  Form ADV Part 2B Disclosure Brochure As part of our fiduciary duty owed to our clients the firm takes the following steps to address the affiliation conflicts as detailed above: • HWM discloses all material conflicts of interest so that existing and prospective clients may evaluate their impact on any relationship. • The conflicts identified are addressed through the development, implementation, and monitoring of our compliance program. • We have supervisory procedures in place to monitor the suitability of client transactions, adherence to client investment objectives, transactions Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Summary We have adopted a Code of Ethics to address our fiduciary relationships with our clients; specify or prohibit certain types of transactions deemed to create conflicts of interest (or the potential for or appearance of); establish reporting requirements; and enforcement procedures under federal, state, and all other applicable securities laws. We have developed and adopted the following general principles to guide our employees, officers, and directors deemed to be Supervised Persons (“Supervised Persons”) under the Code of Ethics. Supervised Persons include all investment advisory personnel defined as key officers, home office associates, all IARs, including licensed and non-registered fingerprinted people who have direct contact with our advisory clients, as well as any person deemed a Covered Person under the Code of Ethics by the HWM Chief Compliance Officer (“CCO”) or designee. The interests of clients are paramount, and all Supervised Persons shall strive to conduct themselves in such a manner that the interests of clients take precedence over all others, and to prevent access to non- public information about securities recommendations, and client securities holdings and transactions, except to those associates that need such information to perform their duties. Supervised Persons must comply with all federal and state securities laws. Further, no Supervised Persons shall, in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by a client: • Defraud a client in any manner; • Mislead a client, including by making any statement that omits material facts; • Engage in any act, practice or course of conduct that operates or would operate as a fraud or deceit on a client; • Engage in any manipulative practice with respect to a client; • Engage in any manipulative practice with respect to securities, including price manipulation; • Favor the interests of one client over another; or • Engage in front running, and/or profit personally, directly, or indirectly, because of knowledge about a security or a transaction. All personal securities transactions by Supervised Persons must be accomplished in such a way as to avoid any conflict between the interest of our clients and the interest of any Supervised Persons. Each Supervised Person is required to provide quarterly reports of all transactions in securities in which the person has, or by reason of such transaction acquires, any direct or indirect beneficial ownership to our CCO or designee. Each Supervised Person is also required to submit appropriate holdings reports to our 513.745.0707 | www.horanwealth.com 18  Form ADV Part 2B Disclosure Brochure CCO, or his/her designee, which shall be reviewed to determine whether a violation of the Code of Ethics may have occurred. Supervised persons can have their information made available by download to HWM by the custodian and will be exempt from this requirement if all of their personal transactions were conducted at custodian for which the compliance officer has access to and may review these records independently. Our Code of Ethics includes specific provisions outlined in the Insider Trading and Gifts and Gratuity sections of our written supervisory procedure manual. Supervised Persons are required to comply with these policies and procedures. Supervised Persons are further required to report any violation of the Code of Ethics to the CCO, or his/her designee and submit written acknowledgment of receipt of the Code of Ethics and any amendments at least annually. If you want to obtain a complete copy of our Code of Ethics, we will provide it upon request. Participation or Interest in Client Transactions and Personal Trading We may buy or sell for our accounts, or individuals associated with us may buy or sell for their personal accounts, investments identical to those recommended to customers. Because we or a related person(s) may have an interest or position in a certain investment which may also be recommended to you, our client, and as these situations may present a conflict of interest, we have established the following restrictions to ensure our fiduciary responsibilities: • A Supervised Person shall not buy or sell investments for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment, unless the information is also available to the investing public on reasonable inquiry. No Supervised Person shall prefer his or her own interest to that of the advisory client. • When implementing investment recommendations, clients are fully informed that Supervised Persons may receive separate compensation. • We emphasize the unrestricted right of a client to decline to implement any advice rendered. • We emphasize the unrestricted right of a client to select and choose any broker or dealer and/or insurance company he or she wishes. • We require that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisers. Any individual not in observance of the above may be subject to termination. Item 12: Brokerage Practices Your assets must be maintained in an account at a “qualified custodian,” such as a broker/dealer or bank. HWM recommends that clients establish brokerage accounts with Fidelity Brokerage Services, LLC, a registered broker-dealer, member FINRA | SIPC, to maintain custody of their assets and to affect trades for their accounts. HWM is independently owned and operated and not affiliated with Fidelity. Clients are advised that they are under no obligation to implement our recommendations and may choose a broker- dealer at their discretion. Clients may pay commissions or fees that are higher or lower than those that may be obtained elsewhere for similar services. 513.745.0707 | www.horanwealth.com 19  Form ADV Part 2B Disclosure Brochure Clients are responsible for establishing their brokerage accounts at the qualified custodian by executing an account agreement with the Clients custodian of choice. Directed Brokerage In very rare cases, we may work with a client that wants to use a broker-dealer that has not been recommended or approved by us. In such cases, those clients must understand that we may be unable to effectively negotiate brokerage commissions on the client’s behalf and that clients may not receive the best price for securities executed through that broker/dealer. When directing brokerage business, clients should consider whether the commission expenses and execution, clearance, and settlement capabilities that they obtain through the broker-dealer they select are adequately favorable in comparison to those that we would otherwise obtain for our clients. Our recommendation of a specific custodian or broker-dealer is based in part on our existing relationships, the custodian’s financial strength, reputation, breadth of investment products, and the cost and quality of custody and brokerage services provided to you and our other clients. The determining factor in the selection of a custodian to execute transactions for your accounts is not the lowest possible transaction cost, but whether the custodian can provide what is, in our view, the best qualitative execution for investment transactions for your account. How We Select Brokers/Custodians We seek to recommend a custodian who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: • Timeliness of execution • Timeliness and accuracy of trade confirmations • Research services provided • Ability to provide investment ideas • Execution facilitation services provided • Record keeping services provided • Custody services provided Frequency and correction of trade errors • Ability to access a variety of market vendues • Expertise as it relates to specific securities • Financial condition • Business reputation • Quality of services It is HWM’s policy to not affect any principal or agency cross securities transactions for client accounts. HWM will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an advisor, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. Block Trade From time to time, HWM executes client transactions on a block or aggregate basis. That is, they enter one large trade and allocate the shares among various client accounts. This technique may allow HWM to 513.745.0707 | www.horanwealth.com 20  Form ADV Part 2B Disclosure Brochure execute transactions in a more timely, equitable and efficient manner to achieve a better overall price execution for a group of clients. HWM’s policy is to engage in this technique when it is consistent with client objectives and restrictions. Clients participating in any aggregated transactions will receive an average share price on a pro-rata basis. Adjustments or changes may be made under certain circumstances, such as to avoid odd lots or small allocations. If the order at a particular broker is filled at several different prices, through multiple trades, generally all such participating accounts will receive the average price and pay the average commission, subject to odd lots, rounding, and market practice. If a combined order is only partially filled, HWM’s procedures provide that the securities or proceeds are to be allocated in a manner deemed fair and equitable to clients. Depending on the investment strategy pursued and the type of security, this may result in a pro rata allocation to all participating clients. Soft Dollars The term “soft dollars” refers to funds which are generated by client trades “commission rebates or credits” being used by our firm to purchase products or services (such as research and enhanced brokerage services) from or through the broker-dealers whom our firm engages to execute securities transactions. Horan Wealth does not currently accept or participate in any “Soft Dollar” program sponsored or offered by any broker-dealer/custodian. However, the firm does receive certain economic benefits from Fidelity as custodian which are detailed below. Products and Services Available to Us from Fidelity We recommend the use of Fidelity Brokerage Services, LLC as custodian and broker dealer (“Fidelity”). Fidelity is an independent and unaffiliated SEC registered broker/dealer and FINRA member. Fidelity offers services to investment advisers that include custody of securities, trade execution, clearance, transaction settlement, and reporting. Services That Benefit You Fidelity’s brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Fidelity services described in this paragraph generally benefit you and your account. Services That Do Not Directly Benefit You We receive some benefits from Fidelity that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. Although we receive economic benefits that are typically not available to Fidelity retail investors, there is no direct link between our use of Fidelity and the investment advice we give to our clients. These benefits include the following products and services (provided without cost or at a discount): • Research related products and tools; consulting services; • Access to trading tools o Access to technology and software that: Provide access to client account data (such as duplicate trade confirmations and account statements) o Facilitate trade execution and allocate aggregated trade orders for multiple client accounts o Provide pricing and other market data 513.745.0707 | www.horanwealth.com 21  Form ADV Part 2B Disclosure Brochure o Facilitate payment of fees from our clients’ accounts o Assist with back-office functions, recordkeeping, and client reporting Services That Generally Benefit Only Us Fidelity also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events; • Consulting on technology, compliance, legal, and business needs; • Publications and conferences on practice management and business succession; and • Access to employee benefits providers, human capital consultants, and insurance providers. • Marketing consulting and support Fidelity may provide some of these services themselves. In other cases, they will arrange for third-party vendors to provide the services to us. They may also discount or waive their fees for some of these services or pay all or a part of a third party’s fees. They may also provide us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your accounts at Fidelity, we would be required to pay for these services from our own resources. The benefits we or our personnel receive do not depend on the amount of brokerage transactions directed to Fidelity. As part of our fiduciary duties to clients, we endeavor always to put the interests of clients first. Clients should be aware, however, that receiving economic benefits in and of itself creates a conflict of interest and may indirectly influence our choice of Fidelity for custody and brokerage services. Our Interest in Fidelity ’s Services The availability of these services from Fidelity benefits us because we do not have to produce or purchase them. We do not have to pay for their services so long as our clients collectively keep a minimum amount of their assets in accounts at Fidelity. The required minimum amount may give us an incentive to recommend that you maintain your account with Fidelity, based on our interest in receiving Fidelity’’s services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This presents a conflict of interest as it creates an incentive for the firm to recommend clients hold their accounts at either custodian. We believe, however, that our selection of Fidelity as our primary custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Fidelity’s services (see “How We Select Brokers/Custodians”) and not Fidelity’s services that benefit only us. Item 13: Review of Accounts Your IAR will request information from you regarding your financial situation, investment objectives, risk tolerance, and other factors that might be considered in the management of your account. Your IAR will assist you in setting appropriate investment objectives and recommend investments and advisory programs appropriate for your investment objectives. We make written performance reports available to you and your IAR in connection with our asset management programs which assist you and your IAR in the review of transactions and performance of your accounts. Your IAR will contact you at least annually to review the allocation of your accounts, 513.745.0707 | www.horanwealth.com 22  Form ADV Part 2B Disclosure Brochure account performance, your financial situation and investment objectives to determine if changes need to be made to the management of your account. The HWM Investment Committee conducts quarterly meetings to review the performance of investments selected in the model portfolios we make available. Through these meetings, decisions will be made as to whether investments should be replaced, held, or placed on watch lists. IARs will also discuss current market conditions and other events that may affect the ongoing management of the portfolios. We perform periodic account reviews to verify that transactions implemented in client accounts are consistent with the established investment objectives of the client. The IAR may also periodically review client accounts. Triggering factors which could cause such reviews include, but are not limited to, changes in client objectives or circumstances, world events, market movements, interest rate changes or client requests. We review and approve all financial planning and consulting agreements at the time of engagement and review fee collection and debiting of client accounts. Item 14: Client Referrals and Other Compensation HWM does engage in promoter activities with internal employees under the HORAN Wealth enterprise. External promoters are not currently utilized. Employees of HORAN Wealth are encouraged to refer potential clients as part of a holistic corporate citizenship program. Payment for solicited referrals will only be paid to those that are appropriately contracted under the HWM Promoters Agreement. Employees outside of this agreement may be recognized during performance reviews in a holistic manner, but not compensated directly by a defined fee arrangement. For internal employees of HWM that seek to engage in a promoter’s arrangement, HWM will review applicants for appropriate licensure, enter into formal agreements with solicitors, conduct criminal and financial background checks, require fingerprinting, and hold them accountable for requirements and regulations regarding promoter arrangements. Item 15: Custody Custody, as it pertains to an investment adviser, has been defined by the SEC as having access or control over client funds and/or securities but does not include the ability to execute transactions in client accounts. Custody is not limited to physically holding client funds or securities. If an investment adviser, or any of its affiliated companies, can access or control client funds or securities, the investment adviser is deemed to have custody for the purposes of Section 206(4)-2 of the Investment Advisers Act of 1940 (the “Custody Rule”) and must ensure proper procedures are implemented. Our firm is deemed to have custody of client funds and securities because you give it the authority to have fees deducted from your account. Authorization to trade in client accounts (discretion) is not deemed custody. The firm also has custody when a client has a Standing Letter of Authorization (SLOA) instructing the firm to disperse funds or securities from the client’s account to a third-party. As such, our firm has adopted the following safeguards in conjunction with the qualified custodian holding your account: • All client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. • Clients, or independent representatives of clients, will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the way the funds or securities are maintained. 513.745.0707 | www.horanwealth.com 23  Form ADV Part 2B Disclosure Brochure • Account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Fidelity will maintain actual custody of your assets. As stated above, you will receive account statements directly from the chosen custodian at least quarterly. The account statements will be sent to the email or postal mailing address you provided to the custodian. You should carefully review those statements promptly when you receive them. Consolidated reports made available from HWM and your IARs are created from data obtained from the custodians who hold the data, from technology that obtains the data from your custodians, or from account statements from product sponsors. As such, the report presentations you may see are subject to the accuracy of their source. Reports may not reflect all holdings or transactions, their costs, or proceeds received by you. We urge you to compare your custodial account statements with any of the reports or statements you may receive from us. Please note that your custodial account records are the only official records of your account. For those accounts with third party standing letters of authorization, the following additional procedures are in place: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the firm, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The firm or representative has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The firm maintains records showing that the third party is not a related party of the firm or located at the same address as the firm. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion HWM receives discretionary investment authority from its clients at the outset of an advisory relationship unless otherwise communicated through a non-discretionary relationship agreement. In all cases, such discretion will be exercised in a manner consistent with the stated investment objectives for that particular client account. If you engage us on a non-discretionary basis, you must be willing to accept that we cannot buy or sell investments in your account without your prior consent. If you are unavailable, we will not be able to buy or sell any investments (as we would for our discretionary clients) should there be a market correction or if we determine that a particular investment should be bought or sold for our client accounts. When selecting securities and determining amounts, HWM observes the investment policies, limitations, 513.745.0707 | www.horanwealth.com 24  Form ADV Part 2B Disclosure Brochure and restrictions of the clients for which it advises. For registered investment companies (Mutual Funds), HWM’s ability to trade these securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. Clients will be given the opportunity to place reasonable restrictions on certain types of investments and clients will retain individual ownership of all securities. Investment guidelines and restrictions must be provided to HWM in writing. Item 17: Voting Client Securities We do not vote proxies. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitation to vote proxies. We are available to answer questions regarding such notices. Item 18: Financial Information We will disclose any financial condition that is reasonably likely to impair our ability to meet contractual commitments to you. At this time, we have no financial conditions that would impair our ability to meet contractual commitments to you. 513.745.0707 | www.horanwealth.com 25