INTEGRATED ADVISORS NETWORK LLC

Item 1: Cover Page Integrated Advisors Network, LLC Form ADV Part 2A - Firm Brochure (CRD #171991 / SEC #801-9620) 8117 Preston Road Suite 300 Dallas TX 75225 Telephone: 855.729.4222 Fax: 310.742.0227 www.integratedavisorsnetwork.com www.linkedin.com/company/integrated-advisors-network/mycompany March 28, 2025 This Form ADV Part 2A Brochure (or "Brochure") provides information about the qualifications and business practices of Integrated Advisors Network, LLC, an investment advisory firm registered with the United States Securities and Exchange Commission ("SEC"). If you have questions about this Brochure's contents, please contact us at 855.729.4222 or by e-mail at compliance@integratedadvisorsnetwork.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; please refer to the actual investment offering and related legal documentation for complete disclosures. Registration with the SEC or any reference to or use of the terms "registered investment adviser" or "registered" does not imply that Integrated Advisors Network, LLC or any associated person has achieved a certain level of skill or training. Investments involve risk, including the possible loss of principal. An adviser's written and oral communications provide information to determine whether to retain their services. This Brochure is on file with the appropriate regulatory authorities as Federal and state regulations require. information about Integrated Advisors Network, LLC is available on the SEC's website at Additional www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in the firm name or CRD # 171991. Results will provide you with Integrated’s disclosure brochures.) 1  Item 2: Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Adviser") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. There have been no material changes since our last annual updating amendment of March 29, 2024. Assets Under Management As of December 31, 2024, the Adviser's assets under management total is $4,585,500,173.99. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $4,334,048,773 $ 251,451,401 $4,585,500,174 Disclosures Regarding ERISA & Qualified Accounts This section was updated to include further disclosure information regarding Integrated's fiduciary role when providing advisory services to retirement investors/retirement accounts and added detail regarding our fiduciary responsibilities within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, which are laws governing retirement accounts. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with our Firm. Integrated benefits financially from the rollover of such assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. As the way we are compensated conflicts with client interests, we operate under a special rule that requires us to act in their best interest and not put our interests ahead of theirs. Under the special rule's provisions, we must: → meet a professional standard of care when making investment recommendations (give prudent advice), → never put our financial interests ahead of our clients' when making recommendations (give loyal advice), → avoid misleading statements about conflicts of interest, fees, and investments, → follow policies and procedures designed to ensure that we provide advice that is in the client’s best interest, → charge no more than is reasonable for our services, and → provide basic information about conflicts of interest. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. Clients are not contractually or otherwise under any obligation to complete a rollover. Further, if they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated. Integrated will receive no compensation if a client or a prospective client receives a recommendation to leave their plan assets with their old employer. Full Brochure Availability We may, at any time, amend this document to reflect changes in Integrated's business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients - either by electronic means or hard copy with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference as it contains essential information concerning our advisory services and business. 2  You can view our current disclosure documents at or the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Adviser Representative of the Firm. You may also request a copy free of charge by contacting us directly at 855.729.4222 or by e-mail at compliance@integratedadvisorsnetwork.com. 3  Item 3: Table of Contents Item 1: Cover Page .....................................................................................................................................................1 Item 2: Material Changes ...........................................................................................................................................2 Item 3: Table of Contents ...........................................................................................................................................4 Item 4: Advisory Business ..........................................................................................................................................5 Item 5: Fees and Compensation ...............................................................................................................................18 Item 6: Performance Based Fees and Side-by-Side Managment ..............................................................................24 Item 7: Types of Clients ...........................................................................................................................................24 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................24 Item 9: Disciplinary Information ..............................................................................................................................37 Item 10: Other Financial Industry Activities and Affliliations .................................................................................37 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ................................40 Item 12: Brokerage Practices ....................................................................................................................................41 Item 13: Review of Accounts ...................................................................................................................................46 Item 14: Client Referrals and Other Compensation .................................................................................................47 Item 15: Custody ......................................................................................................................................................48 Item 16: Investment Discretion ................................................................................................................................49 Item 17: Voting Client Securities .............................................................................................................................50 Item 18: Financial Information .................................................................................................................................51 Item 19: Additional Information ..............................................................................................................................51 4  Item 4: Advisory Business Description of Firm Integrated Advisors Network, LLC is an investment advisor registered with the Securities and Exchange Commission ("SEC") pursuant to the Investment Advisers Act of 1940 (the "Advisers Act"). The Firm, located at 8117 Preston Road, Suite 300, Dallas, TX 75225, and organized as a Limited Liability Company in the state of Delaware in 2014, has been SEC-registered since May 11, 2015. Integrated’s Principal Owner is TX-HI, LLC. Jeffrey J. Groves, Co-Founder & Managing Partner, Linda M. Pix, Co- Founder & Chief Relationship Officer, and Michael A. Young, President & Managing Partner, are control persons. (Please refer to each Owner's individual Form ADV Part 2B brochure supplement for additional details on their formal education and business background.) As used in this brochure, the words "we," "our," "us," or “the Firm” refer to Integrated Advisors Network, LLC ("Integrated," " or “the Adviser”) and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. The term Associated Persons (or "Associates") refers to Integrated’s Covered Persons and Supervised Personnel, the Officers, Employees, and individuals providing investment advice or advisory services on behalf of the firm. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Advisor Representatives (“Advisor Representatives”). Each advisory relationship at Integrated is managed by one or more Advisor Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Advisor Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Advisor Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Advisor Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Advisor Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Advisor Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. "Co-Branding" Disclosures Integrated offers services through its network of Advisor Representatives. Some Advisor Representatives have other business interests, as described in their Form ADV disclosure brochures, and may have established their own legal business entities to conduct their advisory practices (a "doing business as" or "DBA" firm), whose trade names and logos are used for marketing purposes and may appear on their brochures, marketing materials or client statements. Clients should understand that these businesses are the Advisor Representatives' legal entities and not of Integrated Advisors Network, LLC, the registered investment adviser with the SEC. Advisor Representatives are under the supervision of Integrated, and the investment advisory and financial planning services they offer through their separate and independent entities are provided through Integrated. Persons engaging in any “doing business as” firm’s services 5  must know that each business is operated separately; business models and advisory services will vary among DBA entities, and the protections afforded when doing business with one legal entity may not necessarily exist if entering into a relationship with another. When engaging in the services of one DBA entity’s advisory practice, clients are not affected by the fees, practices, or activities of another. The services provided by one regulated entity will only be provided concerning that entity and are not for services provided by another. Further, the fees of one advisory practice group may be higher or lower than another. Integrated does not make any representation that any fees, products, services, or those of any referred third party are offered at the lowest available cost for similar services; clients may be able to obtain the same at a lower price from other providers. Integrated advisory clients should also be aware that any other business lines offered by DBA entity professionals, such as brokerage and insurance products and services, may be offered through unaffiliated or affiliated firms and are separate and distinct from the advisory services provided through Integrated. Other business lines offered are (1) unrelated to the client's relationship and agreements with Integrated, (2) not part of Integrated's advisory or management services, and (3) subject to separate contractual arrangements. Further, the protections afforded to a client under applicable investment advisory laws and regulations generally do not apply to those provided by any non-advisory contract. For specific details, clients and prospective clients are encouraged to carefully refer to each advisory group's disclosure brochures and ask their Advisor Representative questions about any item they may be unclear about or desire additional information. (See Item 10 - Other Financial Industry Activities & Affiliations for additional disclosures regarding Associate outside business activities.) As of the date of this Brochure, the following (co-branded/DBA) independent businesses and their registered investment professionals offer their advisory services through Integrated: Investment • Abundantia Capital Corporation • All Source Management • Andersen Capital Management, • Evoque Investments, Inc. • Financial Foundations, Inc. • JC Investment Management • Lattice Wealth Management Group, LLC Inc. • APEX Quantitative Group, LLC • Archer Bay Capital • Auctum Wealth Management. LLC • Lienart Family Asset Management • Long Course Capital, LLC • Longview Investment Advisors • MDK Private Wealth Management • Menlo Oaks Capital Group • Militello Wealth Management • Miller Pacific Financial Advisors • Mosaic Financial Solutions • Nspire Wealth • Open Network Financial Consulting • Paragon Wealth • Rama Financial, LLC • ReDefine Wealth Management • SF-IAN • Sand Creek Investment Partners, Inc. • Sawyer Capital Investment Advisors • Select Wealth Advisers • Shields Capital • Sztrom Wealth Management, LLC • Vineyard Asset Management, LLC • Vineyard Global Advisors • Vineyard Wealth Advisors • Yorkshire Wealth Management • Zimmerman Wealth Advisory • B&B Strategic Management, LLC • Burns - Blackburn Group • Candid Financial • Capital City Financial Partners • Copper Crest Capital • Echelon Investment Management • Ely Prudent Portfolios, LLC Group, LLC Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s investment professionals emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers) services, a Wrap Fee Program and educational seminars and workshop services. Clients may choose from the following specific services: • Investment Management & Supervisory Services, including: - ERISA - Retirement & Employee Benefit Plan Services - Managed Account Solutions (“MAS”) Program Services 6  • Financial Planning Services • Hourly & Fixed Fee Consulting Services • Educational Seminars & Workshops Services • Wrap Fee Program Services Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Advisor Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, Integrated may recommend the services of other professionals for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as- needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Integrated is not a party to the transaction and does not maintain the authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities Integrated's advisory services depend on and rely upon the information received from clients. The adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Advisor Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation - Integrated will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify Integrated in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. Integrated reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. 7  Following is a summary description of the specific advisory services covered by this Brochure and the nature of the services. Please consult the applicable client Agreement and fee schedules for additional information regarding each service. Investment Management & Supervisory Services Investment management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. If appropriate for the account type established, Integrated will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Integrated does not maintain physical custody of client funds or securities other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission. Integrated primarily recommends that its clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Integrated will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented ongoing as the client and Advisor Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income and Securities Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Code Standards, Integrated provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)), for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. 8  In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: follow policies and procedures designed to ensure that we provide advice that is in your best interest, charge no more than is reasonable for our services, and • meet a professional standard of care when making investment recommendations (give prudent advice), • never put our financial interests ahead of yours when making recommendations (give loyal advice), • avoid misleading statements about conflicts of interest, fees, and investments, • • • give you basic information about conflicts of interest. Integrated benefits financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with our Firm. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated. Integrated will receive no compensation if a client or a prospective client receives a recommendation to leave their plan assets with their old employer.” IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Integrated, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: → leaving the funds in the employer's/former employer's plan, → moving the funds to a new employer's retirement plan, → cashing out and taking a taxable distribution from the plan, and → rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: - Employer retirement plans generally have a more limited investment menu than IRAs, and 9  - Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 2. Consider plan fees - your current plan may have lower fees than Integrated's fees: - - if you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA, and you should understand the various products and services you might take advantage of at an IRA provider and the potential costs. Integrated's strategy may have a higher risk than your plan's option(s). 3. 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. 9. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plans assets that comprise the client's account. The plan fiduciaries will confirm the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge Integrated has no responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Advisor Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Integrated is not responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Integrated's Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) 10  Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access – after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Integrated will refer only those individuals or entities suitable for its MAS Program services. MAS Program advisers are subject to review by Integrated's standards for inclusion and subject to future change from time to time. Integrated Advisor Representatives act in a Promoter capacity when referring MAS Program clients for this service. Integrated's role is to verify that clients are appropriate to become MAS Program clients, determine if the potential referred client has assets to invest, confirm the client has a minimum understanding of financial investing, and aid in their understanding of the referred manager's services and advisory contract (the “MAS Program Services Agreement” or “Program Agreement”). Any additional solicitation information provided by Integrated to a referred investor will be prepared and supplied to Integrated for distribution by the referred third-party manager. These materials may include (1) written presentations or oral statements that do not purport to meet the objectives or needs of the specific investor, (2) statistical information containing no expressions of opinions as to the investment merits of particular securities, or (3) other general advisory services. Clients wishing to engage in this service will execute two (2) advisory account management agreements. Firstly, an Investment Management Agreement with Integrated and an additional but separate MAS Program Services Agreement with the referred manager. As such, the client, as detailed within each referred manager’s Program Agreement, will enter an investment advisory, management, or other investment-related arrangements with their selected referred manager. The client, who will sign an acknowledgment receipt, will receive copies of all material operative documentation and disclosures related to such arrangements detailing the nature of the relationship, compensation to Integrated and the TPM, and other general terms of the referred TPM’s Program. Integrated does not maintain the authority to accept any client on behalf of any referred TPM, and referred managers are not responsible for accepting any prospective investor (and possible future client) referred to them by Integrated. Each manager has the right to reject any referred client for any reason or no reason at all. In selecting a referred manager, the client is responsible for understanding the fee and Program Agreement they are executing with the TPM. Referred clients typically pay the TPM manager a fee between 0.10 and 2.95%, not including referral fees, which vary based on the executed Promoter agreement. Integrated’s referral payout is in addition to client fees. Integrated will receive revenue from any fees paid when acting in this capacity. Fees shared will not exceed any limit imposed by any regulatory agency. Clients should refer to their TPM Agreement for exact details and amounts. Integrated and referred MAS Program managers are separate, non-affiliated entities. (See Item 5: Fees & Compensation for additional details on Integrated’s advisory fees for this service, Item 14: Client Referrals & Other Compensation for further information on Promoter relationships, and the independent third-party manager’s Program Agreement and separate Program prospectus and related disclosure documents for complete information on any fees charged by the independent third- party advisers providing this service.) Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Advisor Representative and/or client. (See Item 16: Investment Discretion of the referred manager’s Form ADV 2A for additional information on this topic.) For all Programs, the client and their Advisor Representative will compile pertinent financial and demographic information to develop an investment program that strives to meet the client’s goals and objectives. Data will be compiled to complete the Program’s New Account Application and Risk Tolerance Questionnaire, and the client will timely provide other supporting documents and financial information that may be reasonably requested. A MAS Investment Strategy Proposal or Investment Policy Statement (“IPS”) will be generated based on the information provided, 11  summarizing recommended investment strategies and setting out objectives and restrictions in managing the client’s account. According to the TPM's Agreement, clients may impose reasonable investment restrictions on managing the assets in their accounts. (Note: For detailed information about Program information and the investment strategies employed in a Program account, please refer to the referred manager’s ADV 2, under Item 8 - Methods of Analysis, Investment Strategies & Risk of Loss.) Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred-manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. 12  In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes but is not limited to: assessment assistance of the client’s investment needs and objectives, investment policy planning assistance, assistance in the development of an asset allocation strategy designed to meet the client’s objectives, recommendations on appropriate style allocations, identification of appropriate managers and investment vehicles appropriate for the client’s goals, evaluation of asset managers and investment vehicles meeting style and allocation criteria, engagement of selected asset managers and investment vehicles on behalf of the client, • • • • • • • • ongoing monitoring of individual asset manager’s performance and management for “approved” investment • strategies, automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation, recommendations for account rebalancing, if necessary, • • online reporting of the client account’s performance and progress, • fully integrated back-office support systems to Advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation, and access to third-party platforms and strategies through the EPS Platform. • Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. The Programs Integrated will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and select from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - the SMA Program is an actively managed or index-ed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - this Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - for clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies 13  contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third-party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by selecting the specific, underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives, but the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategis UMA Program (“Strategist UMA”) - portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated receives compensation from third-party advisers, who we recommend that you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated can allocate assets among private funds, including funds of funds, managed by third parties. With respect to fund of funds, Integrated recommends funds on an alternative investment platform which manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents which each investor is required to receive and/or execute prior to being accepted as an 14  investor in a fund. Integrated does not invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Services Integrated offers broad-based personal financial planning services tailored to the client's needs and differentiated by the scope and depth of the areas to be addressed, analysis complexity, recommendations developed, deliverables created, and presentation. The scope of services is determined between the client and Advisor Representative. Financial planning services can take the form of one-on-one advice on investment matters or other guidance as contracted by the client and will range from comprehensive financial planning to consulting on a particular issue, including a focus on topics such as lifestyle objectives, retirement planning, planning for major purchases, long-term care needs, estate planning issues or other financial planning or consulting services needs as designated. A financial plan may include but is not limited to a net worth statement, cash flow statement, review of investment accounts - including reviewing asset allocation and providing repositioning recommendations, strategic tax planning, a review of retirement accounts and plans - including recommendations, insurance policy analysis and recommendations for changes, if necessary, one or more retirement scenarios, estate planning evaluation and recommendations, and education planning with funding guidance. Clients will execute a Financial Planning Agreement setting forth the terms and conditions of the engagement, including termination, describing the services' scope and the fixed or hourly fees due before Integrated commencing services. The final fee structure will be documented within the executed Agreement. Depending on the scope of the assignment and the complexity of the planning to be performed or advice to be given, financial planning services can take approximately one week to two months. Financial plans are based on the client's financial situation when the plan is presented and the financial information disclosed by the client to Integrated. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. If the client's case differs substantially from what was disclosed at the initial meeting, a revised fee will be provided for review and acceptance. When a fee increase is necessary, the client must approve and agree to the scope change before any additional work is performed. In such cases, we will notify the client to obtain this approval. (See Item 5: Fees & Compensation for additional details.) As with all Integrated advisory services, the expectation is that the client will promptly notify the Adviser in writing of any material changes in assets, net worth, indebtedness, or planning objectives that the Adviser would not otherwise know. The client or their successor shall also promptly notify Integrated in writing of (a) the dissolution, termination, merger, or bankruptcy of the client if the client is other than a natural person and (b) the occurrence of any other event which might affect the validity of their Financial Planning Agreement or Integrated's authority thereunder. Financial planning engagements terminate upon delivery of the written plan. Additional reviews may be conducted upon request, and written updates to the financial plan may be provided in conjunction with the review. Updates to financial plans may be subject to our then-current hourly rate, which the client must approve in writing and before the update. Financial planning services may be the only service provided to the client. Executing a Financial Planning Agreement neither constitutes an agreement for nor requires that the client use or purchase investment advisory or other services offered by Integrated, or any insurance or other products or services offered by any advisory Associate as a result of any business activities in which they may participate outside their advisory activities with the Adviser. Neither Integrated nor the Advisor Representative will have discretionary investment authority when offering financial planning or consulting services. The services do not include implementing or monitoring the Advisor Representative's recommendations to the client. If the client receives a written financial plan, the plan will not include information or analysis concerning liability risks, tax planning, or tax preparation services. If such services are necessary, the client shall be responsible for obtaining them from one or more third parties. Integrated reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in its judgment, 15  to provide proper financial advice. Clients should consult their Financial Planning Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Hourly & Fixed Fee Consulting Services Integrated provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Integrated may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's s recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Advisor Representative and placing any resulting transactions. After engagement completion, Integrated and the Advisor Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshops Services Integrated provides complimentary investment educational seminars and workshops services on various investment topics " as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Advisor Representatives will not provide personalized investment advice to attendees during such events. Integrated provides investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. (See Item 10: Other Financial Industry Activities & Affiliations.) Conflicts of Interest Please note that Integrated has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser or its Advisor Representatives an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received rather than client needs. Integrated mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to effect the transaction through Integrated, its Advisor Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in the Adviser's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is 16  available for review free of charge to any client or prospective client upon request. Types of Investments Integrated will generally provide investment and portfolio asset allocation advice and management on the following investment types: • • • • equities (stocks), corporate debt securities, exchange-traded funds investment company securities - variable life insurance, variable annuities, and mutual funds shares (no- load/ low-load), • warrants, and • U.S. government securities. Although Integrated provides advice predominately on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated avoids market timing but will increase cash holdings when necessary. Although we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. We reserve the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost – typically, institutional share class. Integrated avoids market timing but will increase cash holdings when necessary. (Please note that an investment in money market funds is not insured or guaranteed by the FDIC or other government.) Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Integrated will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. 17  In no event and regardless of the advisory service provided is the Adviser obligated to make any investment or enter any transaction it believes in good faith would violate any federal or state law or regulation. If client-imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. Wrap Fee Program As part of its services, Integrated and certain of its independent investment professional DBA entities that offer their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program, a transaction fee rebate program that differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Generally, Integrated considers its Managed Account Solutions (“MAS”) Program services a Wrap Fee Program. Integrated receives a portion of the wrap fee for the services we provide. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement and describes the scope of services to be provided and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assets Under Management As of February 29, 2024, the Adviser's assets under management total is $4,585,500,173.99. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 4,334,048,773 $ 251,451,401 $4,585,500,174 Item 5: Fees and Compensation Integrated’s advisory clients agree to pay an asset-based advisory fee calculated according to the indicated fee schedules. Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Integrated's Form ADV Part 2A Brochure and the applicable DBA Advisor Representative’s Part 2B Brochure Supplement will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. 18  (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Advisory Services Fees The following describes how Integrated is compensated for each of its advisory services. Fee Negotiation Availability Under certain circumstances, all advisory services fees are negotiable up to the maximum annual rates listed herein, subject to certain limitations and approval by Integrated. The Adviser, in its sole discretion, may charge lesser fees or choose to reduce or waive minimum fees for services based upon specific criteria such as a pre-existing financial planning client, anticipated future earning capacity, expected additional assets, the amount of client assets under management, related accounts, account composition, client negotiations, and pro bono activities, among others. At Integrated's discretion, certain accounts for members of a client's family or otherwise may be assessed fees based on the total balance of all accounts. Integrated will only accept clients with less than the minimum portfolio size if, in the Adviser’s opinion, the smaller portfolio size will not cause a substantial increase in investment risk beyond the client's identified risk tolerance. According to the selected advisory services, final fee structures will be reflected in each client's written Agreement. Integrated believes that the charges and fees offered are competitive with alternative programs available through other firms that may provide a similar range of services; however, lower fees for comparable services, at times, may be available from other sources. While the Adviser seeks to facilitate advantageous agreements for clients, to the extent fees are negotiable, some clients may pay higher (more >) or lower fees (< less) than other clients for services depending on factors such as account total assets under management, the number of related investment accounts, inception date, or other considerations, than if they had contracted directly with another provider. In all cases, clients are responsible for any tax liabilities that result from any transactions. Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management & Supervisory Services Integrated provides investment management and supervisory services on a fee-only basis based on the value of the assets to be managed, the work to be provided, and the complexity of their situation. Investment management and supervisory services require a minimum portfolio value of $50,000. If engaged, Integrated will charge an annual fee of up to 2.95%, based upon a percentage of the market value of the client’s assets under management, calculated and billed consistent with the Adviser’s disclosure documents and each client’s contracts’ compensation arrangements. Individual client account fees will vary depending on the selected Program’s investment options and the fee schedule of each Integrated advisory group’s practices. However, in all cases, the Advisor Representative's advisory practices must ensure that the advisory fees they assess clients are accurate, up-to-date, and aligned with Integrated’s disclosures, up to the maximum annual rates listed herein. Clients should refer to the individual brochure of each advisory group for specific details. (Note: Lower fees for comparable services can sometimes be available from other sources.) Each client's executed Agreement will indicate the final advisory fees and fee-payment arrangements before the delivery of any advisory services. Fee Billing & Payment Integrated’s annual investment management and supervisory services fees are prorated, billed monthly or quarterly, and payable in advance or arrears according to the client’s Agreement, based on a percentage of assets under management as of the last day of the preceding quarter. The first quarter’s fees shall be calculated on a pro-rata basis. 19  Clients will choose how they wish to be billed and indicate their fee billing and payment preference on their advisory services Agreement. Clients may have their fees directly debited from the account held at their custodian of record or billed. Integrated will not access client funds for fees without written client consent. Clients who wish to have their fees directly debited will authorize Integrated in writing to deduct any advisory fees due from their custodial account directly and provide their custodian with authorization to deduct such amounts when due and remit them straight to Integrated. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing, a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Clients who wish to be billed by Integrated for their advisory services fees will authorize this form of payment in writing on their advisory Agreement and request that Integrated invoice them directly monthly or quarterly for any fees due. Clients will then make fee payments to Integrated by separate check or credit card within 45 days of invoice receipt. Under no circumstance will any Integrated advisory fees be deducted from amounts they hold within their custodial account(s). (See Item: 15: Custody for additional details.) Additions, Withdrawals & Terminations Additions, withdrawals, and terminations to investment management and supervisory services client accounts are governed by the Agreement the client signs directly with Integrated. Clients may make cash or securities additions to their accounts at any time. Integrated reserves the right to liquidate any transferred securities or decline to accept particular securities into the client's account. If Integrated liquidates transferred securities, clients may be subject to additional fees such as transaction fees, other fees assessed at the mutual funds level such as contingent deferred sales charges, and tax ramifications. Clients may withdraw from their accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures. Additionally, if the client transfers their account to another firm, they may pay an outgoing account transfer fee. Terminations can be made to Integrated Agreements by written notice without penalty within five (5) business days after the Agreement execution date. After that, the contracts between Integrated and the client will continue according to the Agreement’s provisions, which state either party may terminate the Agreement without penalty upon 30 days written notice to the other party, following the Agreement’s provisions. (A "business day" shall be any day when the New York Stock Exchange is open for trading.) Terminations become effective on receipt of such notice and will not affect: the validity of any action previously taken by the Adviser under the Agreement, liabilities or obligations of the parties from transactions initiated before termination of the Agreement, or the client's responsibility to pay management and other fees due, pro-rated through the termination date. • • • 20  The annual services fee will be pro-rated through the termination date. At termination, after the prior full billing period, the portfolio value will be used as the basis for the fee computation, adjusted for the number of days during the billing period before termination. Based on the termination date, any pre-paid, unearned fees will be promptly refunded to the client on this pro-rata basis. If the client is a natural person, the client's death, disability, or incompetency will not terminate or change the terms of an Agreement. However, the client's executor, guardian, attorney-in-fact, or another authorized representative may terminate the client's Agreement by providing written notice to Integrated. Before termination, all directions given or actions taken or omitted by Integrated before the effective Agreement termination shall be binding upon the client and any successor or legal representative. Upon the termination of an Agreement, Integrated will not possess any obligation to recommend or take any action with regard to the securities, cash, or other investments in a client's account and will no longer be entitled to receive fees from the termination date. Clients should refer to their Investment Management Agreement for complete details. ERISA - Retirement & Employee Benefit Plan Services ERISA - retirement and employee benefit plan services fees are billed and payable according to the preceding investment management and supervisory services schedules. Account additions, withdrawals and terminations also follow the same procedures. Clients should refer to their Agreement for complete details. Managed Account Solutions (“MAS”) Program Services Integrated fees for managed account solutions (“MAS”) program services investment portfolios are based on a percentage of assets managed within the client’s referred Program account. Integrated’s fees, as indicated above, are charged in addition to each third-party manager's fee. As disclosed herein, the fees shared will not exceed the limits imposed by any regulatory agency. Integrated’s portion of the total management fee represents the maximum fee it may earn under its referral Program. Fee Billing & Payment According to the managed account solutions (“MAS”) program services Program Agreement, clients enter with the referred manager; fees are billed and payable quarterly in advance or arrears. At the account's inception(s), the first pay period's fees will be calculated pro-rata. Integrated does not participate in the referred manager’s advisory fee calculation. Final fee structures will be designated within the client’s executed Program Agreement, with fee billing/payment following the Program Agreement’s terms. TPM Program clients should review all applicable disclosure brochures before participating in any TPM Program. It is important to note that the client's referred managers can charge fees in addition to the above fee schedule and will typically reserve the right to reduce or waive the fee at their sole discretion. Added fees and expenses can be charged by investments in the portfolio's model(s). Such fees will be paid out of the client's account assets and are in addition to the fees clients pay to Integrated and any third-party referred managers. Integrated does not receive any portion of the separate commission fees or costs associated with Program client accounts. As the services from Integrated and the Program are available through other companies at differing prices, Integrated encourages the client to review the components that determine charges and service calculations. Factors for consideration should include but are not limited to account size, type(s) of account(s), transaction charges, the range of advisory services, and each service's ancillary charges. Integrated urges Program clients to discuss any questions or concerns with their Advisor Representative and referred manager. Additions, Withdrawals & Terminations Additions, withdrawals, and terminations to Managed Account Solutions (“MAS”) Program services client accounts will also be governed by the separate Program Agreement the client signs directly with the referred manager. Program Agreements will continue until the client or third-party manager terminates the relationship by written notice to the other. The TPM is responsible for refunding unearned Program fees per the Program Agreement's terms. If the total value of the client's account or aggregated accounts falls below the TPM’s minimum account size for a withdrawal or other reason, the TPM may terminate their Program Agreement. Before participating in any referred manager Program, clients should review all applicable disclosure brochures, investor profiles, and TPM Program Agreements for complete details. (Please 21  refer to the Wrap Fee Program’s Form ADV Part 2A - Appendix I for a complete description of the Program, fees, and services.) Financial Planning Services Fees Financial planning services fees are predicated upon the facts known at the start of the engagement. The minimum annual flat-rate fee for financial planning is $500 (or $125 each quarter if paid four times a year vs. annually). Based on the client's services, fees can range higher to engage with Integrated as defined in each client's written and executed Financial Planning Agreement. At Integrated's discretion, limited services are offered at a discounted rate. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. If the client's situation differs substantially from what was disclosed at the initial meeting, a revised fee will be provided for a mutual agreement. Agreements may be amended only by the client and Integrated's mutual written consent. Ultimately, fees will be determined at the discretion of the Advisor Representative assigned to the account based on the required resources and plan complexity. If a financial planning services fee increase is necessary, the client must approve the scope change before any additional work is performed. Financial planning fees are billed in advance when the Financial Planning Agreement is executed and payable within ten (10) days of invoice presentation. Clients may directly authorize deducting these fees from their custodial account or pay them via check or credit card. After plan delivery, future fact-to-face meetings and follow-up implementation work may be scheduled as necessary free of charge for up to 3 months. The client will receive a fee refund upon delivery of the completed financial plan. Alternatively, Integrated may require the client to pay an initial retainer of 50% of the estimated financial planning fee before any services are rendered. The remaining balance is payable upon completion of the contracted services. Integrated is not responsible for any additional fees, commissions, expenses, or charges related to the transfer of assets from any other investment manager or advisor, real estate transactions or other expenses associated with real property transactions, or fees related to any major purchases or other transactions the client effects. The client's responsibility is to remit payment for the administrative expenses and fees due to the TPMs by Integrated for the financial plan and timely resolve such additional fees, commissions, expenses, or charges. Hourly & Fixed Fee Consulting Services Fees Hourly and fixed fee consulting services are provided for either a flat, fixed fee computed on a project basis or a (negotiable) hourly fee of $500, as defined in each client's written contract. Fees are paid in arrears, due upon completion of the consulting service and can be paid by direct debit from the account held at their custodian of record or billed and paid by check within fifteen (15) days of invoice receipt. Clients should refer to their Agreement for more detail. If a fixed-fee project terminates before project completion, Integrated will determine the project's percentage based on the hourly rate and the number of hours already expended. If less than one-half of the project is finished, a refund will be made for any unearned fees. If more than one-half of the project is complete, the client will be invoiced for the additional time expended over fees already paid. Integrated will invoice the client for any work finalized through the termination date if an hourly agreement is terminated before completing agreed-upon services. Clients should refer to their Consulting Services Agreement for more detail. Wrap Fee Program Services Integrated’s Wrap Fee Program services fees are assessed according to the fee schedule reflected in the wrap fee brochure. Based upon a percentage of the market value of the client’s assets under management, fees calculated and billed consistent with the Adviser’s disclosure documents and each client’s contracts’ compensation arrangements will not exceed 2.95%. Account additions, withdrawals and terminations will also follow the (Please refer to the Wrap Fee Program’s Form ADV Part 2A - Appendix I for a complete description of the Program, fees, and services.) Educational Seminars & Workshop Fees Educational seminars and workshops are provided free of charge. 22  Conflicts of Interest Please note that most Integrated advisory clients will pay a fee based on a percentage of the assets under advisement. This compensation method can sometimes lead to conflicts of interest between our firm and the client regarding our advice. As the services available from Integrated can be found through other companies at differing prices, we recommend clients review the components that determine charges and service calculations. Factors for consideration should include but are not limited to account size, type(s) of account(s), transaction charges, the range of advisory services, and each service's ancillary charges. Integrated urges clients to discuss any questions or concerns with their Advisor Representative. Other Fees & Expenses Clients should note that Integrated’s fees are exclusive of bank or custodial fees, brokerage commissions, transaction fees, and other related costs and expenses a client may incur. Some examples of these fees can include but are not limited to custodial fees, trading charges for odd-lot differentials, fixed income, or other transactional costs, including mark-ups, mark-downs, commissions, and dealer profits, charges imposed directly by exchange-traded funds in the account - which will be disclosed in the applicable fund's prospectus, wire transfer and electronic fund fees, or other costs and taxes on brokerage accounts and securities transactions. A third party can also impose fees for services elected by their clients, such as certificate delivery, American Depositary Receipts ("ADRs"), and transfer taxes mandated by law. Specific portfolios can also include transactions in foreign securities and execution on foreign stock exchanges, resulting in other transaction expenses. ETFs and other managed products or partnerships can also be in clients' portfolios. Clients can be charged for the services by the providers/managers of these products, and the advisory management fee paid to Integrated. Charges can be imposed directly by mutual funds, and mutual fund shares held in client accounts may be subject to 12b- 1 fees, short-term redemption fees, and other annual fund expenses. No-load or load-waived mutual funds used in client portfolios would not have initial or deferred sales charges; however, if a fund that imposes sales charges is selected, the client may pay an initial or deferred sales charge. Mutual funds pay advisory fees to their managers, which are indirectly charged to all mutual fund shareholders. Clients with mutual funds in their portfolio effectively pay the adviser and any third-party manager, custodian, and mutual fund manager to manage their assets. Each fund's prospectus fully describes fees and costs, which clients must carefully consider. The fees paid to Integrated are separate from the fees and expenses charged by mutual funds. As a client could invest in a mutual fund or investment partnership directly, without the services of Integrated, they should review both the fees charged by the funds and the applicable program fee charged by the adviser to evaluate the advisory services being provided fully and understand the total amount of fees to be paid by them. (Please note Integrated does not accept commission-based compensation nor receive mutual fund 12b-1 fees.) Clients may also incur "account termination fees" upon transferring an account from one brokerage firm (broker- dealer/custodian) to another. These account termination fees can range significantly from a nominal fee to several hundred dollars but can be much higher. Clients should contact their account custodians to determine the amount of account termination fees charged and deducted from their accounts for any accounts that may be transferred. (Please also see Item 12 - Brokerage Practices for additional details.) Integrated believes that the charges and fees offered within its program are competitive with alternative programs available through other firms offering similar services; however, lower fees for comparable services may be available from other sources. For example, a client could invest in mutual funds directly. In that case, the client would not receive the services provided by Integrated, which are designed, among other things, to assist them in determining which investments are most appropriate for their financial condition and objectives, the ability to undertake a disciplined approach to portfolio rebalancing while taking into account the tax ramifications of same and the avoidance of ad hoc emotional reactions to shorter-term market events. Further, some of the funds may not be available to the client directly without the use of an investment adviser granted access to such investments. Integrated encourages clients to speak with their Advisor Representative directly about any questions about our fees and compensation. 23  Item 6: Performance Based Fees and Side-by-Side Managment Performance-based fees are fees based on a client's account's share of capital gains or appreciation. Side-by-side management refers to managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Integrated provides its services for an advisory fee based upon a percentage of a client's assets under management by state and federal requirements. Fees are not based on a share of managed securities' capital gains or capital appreciation. However, the Adviser may employ certain investments with a performance fee in which Integrated does not participate. These investments' offering or private placement memorandum explains and provides the amounts of such performance fees. Further, as discussed in each entity’s disclosure brochure, certain Integrated Advisor Representatives who offer advisory services through DBAs can charge performance fees, as disclosed within the advisory entity’s Form ADV disclosure documents. Item 7: Types of Clients Client Types Integrated typically provides discretionary and non-discretionary investment advice and management supervisory services to high-net-worth individuals, trusts, estates, charitable organizations, pension & profit-sharing plans, corporations and business entities. Client relationships vary in scope and length of service. Minimum Account Size Investment management and supervisory services and ERISA - retirement and employee benefit plan service clients require a minimum account size of $50,000. The minimum account size for separate advisory group Wrap Fee Program services clients will vary, as reflected in each group’s Form ADV Part 2A - Appendix I disclosure brochure. At their sole discretion, Advisor Representatives may negotiate to waive stated account minimums or charge a lesser management fee based upon specific criteria such as a pre-existing financial planning client, anticipated future earning capacity, expected future additional assets, the dollar amount of assets to be managed, related accounts, account composition, negotiations with the client, and pro bono activities, among others. Smaller portfolio accounts will only be accepted if, in the sole opinion of Integrated, the lesser account size will not cause a substantial increase in investment risk beyond the client's identified risk tolerance. The portfolios of family members may also be aggregated to meet minimum account requirements. (See Item 5 - Fees & Compensation, Fee Negotiation Availability for additional details.) The minimum account size required by third-party managers under Integrated’s Managed Account (“MAS”) Program services may be higher than Integrated’s, as disclosed in each TPM’s Program Agreement. (Note: In selecting a referred manager, the client is responsible for understanding the account minimums, requirements, and fee agreement they are executing with the referred manager.) Clients do not require account establishment or minimums to participate in hourly fixed-fee and financial planning consulting services. Educational seminars and workshop services are provided free of charge. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Integrated provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis 24  for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include but are not limited to cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. And existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Advisor Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Investment Strategies We use one or more of the following methods of analysis or investment strategies when providing investment advice to you: technical analysis involving evaluating recurring price patterns and Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. trends. Cyclical Analysis - a Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including; shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - 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 and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. 25  Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Advisor Representatives may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Advisor Representatives will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your 26  tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Adviser's Investment Activities - the Adviser's investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of the firm and its Associates. 27  Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage-backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often 28  lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each 29  underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short- term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will 30  have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open- end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private 31  placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities FuturesContracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. 32  Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading 33  activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non- diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. 34  The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. 35  Integrated does not represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods, and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision- making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Advisor Representative. 36  Item 9: Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. Neither Integrated nor its management has any disciplinary or legal proceedings to disclose material to a client’s evaluation of this advisory practice. Integrated has no outstanding issues and is registered as an investment adviser without restriction. Certain of Integrated’s Advisor Representatives may have disciplinary actions against them for alleged violations of certain securities regulations, rules, and/or statutory provisions by Federal or state regulatory agencies. Clients may view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at www.adviserinfo.sec.gov by searching our firm name or CRD #171991. The SEC's website also provides information about any affiliated person registered or required to be registered as an Investment Adviser Representative of the firm, including their disclosure items (if any). Copies are also available by contacting us directly at 855.729.4222 or viewing our website at www.integratedadvisorsnetwork.com. Item 10: Other Financial Industry Activities and Affliliations Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Associates are Registered Representatives (“RRs”) of non-affiliated broker-dealers, Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. If your Advisor Representative offers brokerage products as an RR through their unaffiliated broker-dealer, they are not acting in a brokerage capacity or on behalf of Integrated concerning the services provided under our Agreement(s). Integrated is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not 37  related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. This practice presents a conflict of interest because the objectivity of the advice rendered to clients could be biased. The Advisor Representatives providing investment advice on behalf of our firm, who are also RRs of outside and separate broker-dealers, can be incentivized to effect securities transactions to generate commissions rather than solely based on a client’s needs. Integrated addresses this conflict of interest by requiring Associates to disclose this type of relationship to clients. Associates satisfy this requirement by advising their clients of the nature of and their role in the transaction or relationship and any compensation - including commissions or otherwise, to be paid to them by the brokerage firms with which they are affiliated at the time of any recommendation is made and/or product transactions occur. Integrated further mitigates conflicts through its procedures to review client accounts relative to the client or investor's financial situation to ensure appropriate investment management services. The Adviser is committed to ensuring that Associates adhere to the Firm's Code of Ethics and that the Firm and all associated persons fulfill their fiduciary duty to clients/investors. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with the Adviser. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Associates' recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Insurance Services Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Advisor Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Advisor Representatives. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Advisor receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Integrated can also serve as Promoter to the third-party money managers it engages for its Managed Account Solutions (“MAS”) Program services for advisory, administrative, and/or technological services. In this capacity, the Adviser will introduce clients for whom the referred manager's services are suitable and appropriate. In connection with such relationships, Promoter fees can range from 0% to 50% and vary based on the executed Solicitor Agreement. Fees shared 38  will not exceed any limit imposed by any regulatory agency. Clients should refer to their TPM Agreement for exact details and amounts. (Please see Item 14: Client Referrals & Other Compensation for additional details.) Apart from our clients' fees, we do not receive any other economic benefits, including sales awards or prizes. Tax Preparation Services Advisory clients may choose to use non-affiliated independent tax preparation services. And clients of the tax preparation providers may decide to use Integrated for financial planning and/or investment advisory services. Although Associates will make clients aware of the availability of tax preparation services, advisory clients are not required to utilize such services. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct - and sometimes act as a Promoter while referring prospective clients or clients to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Referred clients will enter a separate Program Agreement with the referred manager and receive the manager's disclosure documents, which they are encouraged to read. The relationship - including any conflicts of interest involving providing advice, service, or account management style, will be disclosed in each contract between the Integrated, the third-party money managers, and the client. Integrated reserves the right to add or delete managers as deemed necessary. Clients should contact Integrated directly for a current list of referred managers under this service. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Advisory Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. 39  Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Code of Ethics Rule 204A-1 of the Investment Advisers Act of 1940 requires all investment advisors registered with the Securities and Exchange Commission to adopt codes of ethics that set forth standards of conduct and comply with federal securities laws. Integrated takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of the supervised personnel who act on its behalf. The adviser believes each of its advisory clients is owed the highest level of trust and fair dealing and holds Associates to a very high standard of business practices and integrity. To that end, Integrated has adopted a Code of Ethics that sets forth the firm's conduct standards in keeping with its fiduciary obligation. Integrated's Code imposes upon Associates the duty to deal fairly and: → render disinterested and impartial advice, → make suitable recommendations to clients within the context of the total portfolio, given their needs, financial circumstances, and investment objectives, → exercise a high degree of care to ensure that all material facts are disclosed to clients, → provide adequate and accurate representations of its business and other information about Integrated's services and investment recommendations, → disclose any conflicts of interest, and → promote fair, ethical, and equitable practices. The Adviser's Code requires all Associates to exercise a fiduciary duty by acting in each client’s best interest while consistently placing client interests first and foremost. The Code applies to all Integrated Associates, including individuals registered with the adviser as Advisor Representatives or considered 'Supervised Persons' under the Advisers Act Rules. The Code may also be applied to any other person the Chief Compliance Officer designates. Integrated's Code outlines and prohibits certain activities deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict) and specifies reporting requirements and enforcement procedures. Associates must abide fully by all applicable industry regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code, including any updates. The Code requires an affirmative commitment by Associates they will abide by all state and federal securities laws and provisions relating to client information confidentiality, a prohibition on insider trading, restrictions on the acceptance of significant gifts, outside activities reporting, and personal securities trading procedures for Covered Persons, among others. Upon employment or affiliation and at least annually after that, Associates are required to attest to their understanding of, and compliance with, the Adviser’s Code of Ethics, including confirmation and acknowledgment by every licensed Advisor Representative, of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required of them. And execute an affirmation stating they will conduct business honestly, ethically, and fairly, avoiding all circumstances that might negatively affect or appear to affect its duty of complete loyalty to all clients. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Or combine our securities orders with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, 40  or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12: Brokerage Practices Preferred Custodians & Brokers-Dealers Integrated does not maintain custody of the assets we manage on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Advisory Agreement execution and enter into a separate broker-dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), and TD Ameritrade (TD Ameritrade Institutional, a division of TD Ameritrade, Inc. or “TDA”), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, Fidelity, and TD Ameritrade as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: 41  • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some of which the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, • • • publications and conferences on practice management and business succession, and 42  access to employee benefits providers, human capital consultants, and insurance providers. • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research-related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no- transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest may exist in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which did not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. 43  In some cases, Integrated may receive non-research - administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non-research and research portion of the services received and pay Integrated money ("hard dollars") for the non-research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place-specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Advisory Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the 44  complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Integrated in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; Integrated will not seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account that would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our firm or persons associated with our firm may buy or sell securities for you while we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Integrated makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. 45  Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13: Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed account solutions program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly and provide Integrated duplicate copies of all periodic statements and other reports for the account the custodian sends to the client. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the account value at the period beginning and ending. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. 46  According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Advisor Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Integrated directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14: Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Advisor Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including 47  a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, Integrated does not compensate any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates, as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15: Custody Custodial Practices Integrated's policy does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Integrated is not authorized to withdraw any money, securities, or other property from any client custodial account in the client's name or otherwise. While Integrated prohibits the firm or its Associates from obtaining, accepting, or maintaining control of client funds, securities, or assets, with a client's consent, the Adviser may be provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. 48  The Adviser will require: 1. 2. 3. 4. 5. 6. 7. the client provides an instruction to the qualified custodian in writing, which 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 Integrated, 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 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 can terminate or change the instruction to the client's custodian, Integrated has no authority or power 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, Integrated maintains records showing that the third party is not a related party of the Adviser or located at the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16: Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Integrated will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Integrated complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Advisor Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Integrated will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. 49  In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Advisor Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Advisor Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Integrated reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Integrated engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistent with the jointly agreed upon investment objectives, Integrated reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Integrated will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17: Voting Client Securities Proxy Voting Integrated will not ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Integrated may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. 50  Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class- action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Integrated will not advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Integrated does not provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18: Financial Information Balance Sheet Integrated does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated nor its management has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self-regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. Disciplinary Disclosures Certain of Integrated's financial professionals have legal or disciplinary histories to disclose. Please visit the United States Securities and Exchange Commission's ("SEC") website at www.adviserinfo.sec.gov for a free and simple search tool to research Integrated and its financial professionals, management members, officers, and firm principals. Item 19: Additional Information Business Continuity Plan Overview Securities industry regulations require that investment advisers inform their clients of their plans to address the possibility of significant business disruption ("SBD") from unexpected events such as power outages, natural disasters, or other such occurrences. Firms must be able to provide continuous and uninterrupted services to their clients, and critical systems 51  must function during such incidents so that the firm can resume operations as quickly as possible, given the SBD's scope and severity. In addition, they must meet their obligations to clients, counterparties, and others during any emergency or SBD. Since the timing and impact of disasters and disruptions are unpredictable, firms must be flexible in acting. Well thought out, advanced preparations and effective procedures can significantly minimize downtime in the face of a disaster or outage. To satisfy this requirement, Integrated has developed a comprehensive Business Continuity Plan ("BCP" or "Plan") to detail how it will react when faced with such conditions. While no contingency plan can eliminate all service interruption risks, Integrated's BCP strives to set forth the firm's policies and practices under various SBD situations and mitigate all credible threats while keeping up with changes to the Adviser's business, structure, operations, and location. Firm Policy Integrated's guiding principle is that protecting clients, employees/Associates and family members always take precedence over preserving business assets. Accordingly, Integrated's policy is to respond to an SBD by first safeguarding the lives of its clients, employees/Associates, family members, and others, and then firm property, making a quick financial and operational assessment, protecting and preserving all advisory books and records, and promptly recovering and resuming operations to allow clients to continue to transact business as rapidly as possible. Recovery times may vary depending on the nature and severity of the disruption; however, the objective of restoring mission-critical operations is 0-72 hours. BCP Summary Integrated's BCP - reviewed, tested regularly, and updated no less than annually, anticipates two kinds of SBDs, internal and external. Internal SBDs affect only the firm's ability to communicate and do business, such as a fire in the building. External SBDs prevent the operation of the securities markets for several firms and may include terrorist attacks, floods, or wide-scale regional disruptions. Integrated's BCP addresses all mission-critical systems, office closing and relocation procedures, and employee alternative physical locations. In addition, regulatory reporting and alternate communications between the Adviser and its clients, employees, critical business constituents, banks, counterparties, regulators, and others are detailed to preserve uninterrupted communication. The Plan also defines data backup and recovery procedures (hard copy and electronic) and succession planning in the event of crucial personnel absence. Further, Integrated requires its primary internal and external vendor systems providers to periodically verify and test their backup capabilities to promptly provide the necessary information and applications to continue or resume business in an emergency or SBD situation. Integrated carries out its BCP under the direction of the Disaster Recovery Executive Coordinator (the "DREC"). The DREC is responsible for making an immediate preliminary assessment of the nature and extent of any disruption and communicating the firm's BCP to employees, clients, critical business constituents, and regulators. When an internal or external event, either minor or significant, occurs or appears to be developing, Integrated's DREC will be notified. Upon notification or becoming aware of an SBD event, the DREC will implement BCP emergency procedures, secure the headquarters as much as possible, and advise all employees to call the firm's emergency line directly @ 855.729.4222. The Adviser will transfer its operations to a local worksite if a business disruption affects only Integrated or a specific area within the firm. If a disruption affects the firm's business district, city, or region, operations will be transferred to an alternate worksite outside the affected area. Telephone service will continue, and regular work processes will resume at its alternate location(s). Integrated will continue conducting business in either situation and notify its clients about maintaining contact through a message recorded on its main phone number and website posting. Integrated does not maintain custody of client funds or securities; clients maintain all account assets at an independent qualified custodian with whom they can always communicate and access assets directly, with or without the Adviser's intervention. In the event of an SBD, Integrated will help facilitate client access to these external accounts by resolving their questions, providing status updates, and offering up-to-date contact information to assist them in reaching their custodians and – if applicable, for the type of account opened, any third-party managers ("TPMs") directly. 52  If a client's custodian or TPM is also impacted by an SBD or cannot otherwise be reached, Integrated will generate a bulk email via the firm's then-current Internet-based communications platform to inform the situation and safeguard clients' awareness of developments. Integrated will also relay communications to custodians and TPMs on the client's behalf. If an SBD is so severe that it prevents the firm from conducting advisory business, Integrated will promptly update its voice message and website. If it is determined that the firm cannot continue its advisory business, clients will be assured swift access to their funds, securities, and prepaid fees, by direct contact with their respective custodians and TPMs (as applicable). Additional Information Integrated's BCP is designed to allow the firm to continue to provide the quality service its clients have come to expect. Please contact us directly with any questions about the firm's practices or to request a complete copy of our Plan: INTEGRATED ADVISORS NETWORK, LLC P.O. Box 25523 Dallas TX 75225 Telephone: 855.729.4222 Fax: 310.742.0227 www.integratedavisorsnetwork.com Information Security Program Integrated maintains an Information Security Program to reduce the risk of clients' personal and confidential information breaches. Please contact us directly at 855.729.4222 with any questions regarding this topic. Privacy Practices Your relationship with us is based on trust and confidence. This privacy policy ("Privacy Policy" or “Policy”) describes the ways Integrated Advisors Networks, LLC collects, stores, uses, discloses, and protects the privacy of the personally identifiable and non-personally identifiable information we may collect from you or that you may provide. Our goal is to treat the information you furnish us with the utmost respect following this Policy and safeguard and protect the information you have provided securely and professionally. We remain committed to this objective. What is Personally Identifiable Information? Personally identifiable information ("PII") describes the information associated with you. It can be used to identify you and includes your name, address, phone number, zip code, e-mail address, and other similar data. Non-personally identifiable information (“non-PII”) is information that does not identify a specific person or is publicly available. Non- PII may include, for example, your IP address, browser type, domain names, access dates, and similar information. Categories of Information We Collect The personal information we collect and share will depend on the product or service. Confidential personal data collected about you can include but not be limited to: • • • information we receive from you via applications or other forms, such as your name, address, phone or social security number, occupation, assets, income, investment experience and other financial and family information, and information about your transactions with us or the brokerages, banks, and custodians with whom you hold investment or cash accounts, including account numbers, holdings, balances, transaction history, and other financial and investment activities. How We Collect Your Information We collect your personal information; for example, when you seek investment advice, tell us about your investment portfolio(s), open an account, make account deposits or withdrawals, or provide your income details. We also collect your personal information from others, such as other companies. 53  We do not knowingly solicit information from or market our products or services to children. How We Use Your Information We may use information that we collect about you or that you provide to us, including any personal information, for any purpose, including but not limited to: • • • • • • • • • • personalize our contact with you, or verify your identity when accessing our services, compare information for accuracy and record verification, provide information, materials, products, or the services you request, improve, modify, customize, and measure our services, develop new products and services, send you administrative messages, content, and other services and features in which we believe you may be interested, provide you with information about our products and services, including while you are on our website online services or after you visit such online services, contact you for the potential purchase of insurance or other financial products, operate, provide, improve, and maintain our website to prevent abusive and fraudulent use of our website or enforce our Terms of Use and any other agreements between you and our firm, and for any other administrative and internal business purposes permitted by law. Sharing Non-Public Personal & Financial Information Financial companies must share customers' personal information to run their everyday business and provide services. Even when required to do this, we are committed to the protection and privacy of your personal and financial information. We will share your personal information with only those non-affiliated third-party service providers authorized to use your data as necessary to support our business operations, such as: for marketing services, to our attorneys, accountants, or compliance consultants, to provide customer service or resolve customer disputes, to provide data storage, payment, or technology support and services, or for risk solution provisions, analytics, or fraud prevention, in connection with a sale or merger of our business, or in any circumstance that has your instruction or consent. • when necessary to complete an account transaction, such as with the clearing firm or account custodians, • when required to maintain or service an account, • • when requested by a fiduciary or beneficiary on the account, • when required by a regulatory agency or for other reasons required or permitted by law, • • • • • • The personal information we share for business purposes may include any categories of personal information identified in this Privacy Policy that we may collect. Protection of Personal Information We maintain various security measures to protect against the loss, misuse, and alteration of the information under our control. We restrict access to personal and account information to only those employees who need to know the information to provide products or services to you. Physical, electronic, and procedural safeguards are in place to guard client data using security measures that comply with federal law, such as computer protection, secured files, and buildings. Finally, although no business can wholly guarantee that information will remain free from unauthorized access, use, disclosure, or alteration, we make consistent, diligent, and good-faith efforts to maintain information security, utilizing safety measures designed to prevent unauthorized access or usage. Internet Use You can visit us on the Internet at www.integratedavisorsnetwork.com without telling us who you are or revealing any information about yourself, including your e-mail address. In this case, our web servers may collect the domain name 54  you used to access the Internet, such as www.aol.com, the website you came from and visited next, and other data. We use this data to monitor site performance and make the site more accessible and convenient. (Please visit us at www.integratedavisorsnetwork.com to review our website "Terms of Service.") Sharing Information & Consumer Choice When you provide information to us, we may share your information, to the extent provided by applicable law, with our affiliated companies and third parties to fulfill your requests and offer you other services that may interest you. Your information is not shared with any third party unless requested by you or permitted by law. Under no circumstance will we sell or transfer your information to any ad network, ad exchange, data broker, or other advertising or monetization- related service. We may also aggregate statistics about our customers, sales, traffic patterns, and services and provide these statistics to third parties; however, when we do, the statistics will exclude any personal information that identifies individuals. We will not provide your personal information to mailing list vendors or Promoters. We require strict confidentiality in our agreements with unaffiliated third parties that require access to your personal data, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and your records as the law permits. Federal law allows you to limit sharing information about your creditworthiness for affiliates' everyday business purposes, affiliates from using your information to market to you, and sharing for non-affiliates to market to you. State and international laws and individual companies may provide additional rights to limit sharing. (Please contact us directly for specific state and residence privacy requirements.) Notification In the Event of A Data Breach Although we make reasonable faith efforts to maintain your information securely, no firm or individual can guarantee that shared information will remain free from unauthorized access, use, disclosure, or alteration. If an unauthorized party breaches your personally identifiable information, we will comply with applicable state laws in notifying you of the breach. Former Customers Personally identifiable information about you will be maintained while you are a client and for the crucial period after that, as federal and state securities laws require if you close your account(s) or become an inactive customer. After that time, information may be destroyed. Accessing or Correcting Your Information You may access your data collected by us by sending a request to the below address. If you believe that an error has been made in the accuracy of the information collected from you, we will correct such error upon adequate verification of the error and the person's identity seeking the correction. If you wish to access, remove, or correct any personally identifying information you have supplied to us or have any questions about this Privacy Policy, you may contact us by sending a letter to the address on the cover of this Brochure. Changes to Our Privacy Policy We reserve the right to modify or supplement Integrated's Privacy Policy statement at any time. If we make any material changes, we will notify our existing clients and update our website to reflect such changes, including disclosing the Policy's last revised date. Questions Please contact us as follows if you have any questions or concerns regarding our privacy or business practices: INTEGRATED ADVISORS NETWORK, LLC P.O. Box 25523 Dallas TX 75225 Telephone: 855.729.4222 Fax: 310.742.0227 www.integratedavisorsnetwork.com 55 

Item 1 – Cover Sheet Vineyard Asset Management, LLC Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 3812 S. Fremont Ave. Springfield, MO 65804 (417) 881-7100 www.vineyardasset.com March 28, 2025 This brochure provides information about the qualifications and business practices of Vineyard Asset Management, LLC. If you have any questions about the contents of this brochure, please contact us at by telephone at (417) 881-7100, or by email at info@vineyardasset.com . Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222. The information in this Brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Please note that registration as an investment adviser does not imply a certain level of skill or training. An adviser's written and oral communications provide information to determine whether to retain the adviser's services. This Brochure is on file with the appropriate regulatory authorities as Federal and state regulations require. Additional information about Vineyard Asset Management, LLC and Integrated Advisors Network, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in our firm name or CRD #171991. Results will provide you with all firm disclosure brochures.) 1  Item 2 – Material Changes Annual Update In this item, Vineyard Asset Management, LLC is required to summarize only those material changes made to this Brochure since the Adviser’s last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since the initial filing on June 21, 2024, changes have been made to the following Brochure sections: Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients - either by electronic means or hard copy with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at www.adviserinfo.sec.gov by searching either our name or CRD #171991. The SEC's website also provides information about any advisory-affiliated person registered or required to be registered as an Investment Adviser Representative of the firm. You may also request a copy free of charge by contacting us directly at the number(s) located on this Brochure's cover page. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ..............................................................................................................................11 Item 6 – Performance Fees .......................................................................................................................................15 Item 7 – Types of Clients .........................................................................................................................................15 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................16 Item 9 – Disciplinary Information ............................................................................................................................28 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................29 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................31 Item 12 – Brokerage Practices ..................................................................................................................................33 Item 13 – Review of Accounts .................................................................................................................................38 Item 14 – Client Referrals and Other Compensation ...............................................................................................39 Item 15 - Custody .....................................................................................................................................................40 Item 16 – Investment Discretion ..............................................................................................................................41 Item 17 – Voting Client Securities ...........................................................................................................................43 Item 18 – Financial Information ...............................................................................................................................43 3  Item 4 – Advisory Business Vineyard Asset Management, LLC is a dba of Integrated Advisors Network LLC, hereinafter “the Adviser”, “VAM” or “Vineyard Asset”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser (such registration does not imply that the Adviser has attained a certain level of skill or training). The Adviser provides investment management services to individuals and wealthy individuals on a separate account management basis. Integrated is a fee-only investment management firm. Neither Integrated nor the Adviser sells securities on a commission basis. The Firm is not affiliated with any entities that sell financial products or securities. The Adviser does not act as a custodian of client assets and the client always maintains asset control. The Adviser does have discretion over client accounts but if non-discretionary assets are accepted the Adviser will seek client approval prior to placing a trade on behalf of the client. The Adviser does have discretion over which brokerage firms to trade with and the resulting commissions to be paid and/or where the account is held in custody and the resulting expenses related to that custodianship. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network, LLC are as follows: Integrated’s Principal Owner is TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Types of Advisory Services Vineyard Asset Management is a dba of Integrated Advisors Network, LLC. All advisory services are offered through Integrated Advisors Network LLC. Ben Newhouse, Albert “Bert” Demicell, Jennifer Newhouse, Scott Hall and John Newhouse are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s investment professionals emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers) services, a Wrap Fee Program and educational seminars and workshop services. Clients may choose from the following specific services: • Investment Management & Supervisory Services, including: - ERISA - Retirement & Employee Benefit Plan Services - Managed Account Solutions (“MAS”) Program Services • Financial Planning Services • Hourly & Fixed Fee Consulting Services • Educational Seminars & Workshops Services • Wrap Fee Program Services Advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Client Services Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre- paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures are documented within the client’s written Agreement. Advisor Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any 4  time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, Integrated and the Adviser may recommend the services of other professionals for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Integrated is not a party to the transaction and does not maintain the authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated or the Adviser. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities Advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Advisor Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither Integrated nor the Adviser will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify VAM in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. Integrated reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Following is a summary description of the specific advisory services covered by this Brochure and the nature of the services. Please consult the applicable client Agreement and fee schedules for additional information regarding each service. Investment management and supervisory services Clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 5  If appropriate for the account type established, an Investment Policy Statement ("IPS") will also be created to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Integrated does not maintain physical custody of client funds or securities other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission. The Adviser recommends that its clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. The Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented ongoing as the client and Advisor Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated/the Adviser also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under these services, Integrated/the IARs can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income and Securities Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Code Standards, the Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)), for such advice. Integrated/the Adviser makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, 6  as applicable, laws governing retirement accounts. The way Integrated/the Adviser is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: avoid misleading statements about conflicts of interest, fees, and investments, follow policies and procedures designed to ensure that we provide advice that is in your best interest, charge no more than is reasonable for our services, and • meet a professional standard of care when making investment recommendations (give prudent advice), • never put our financial interests ahead of yours when making recommendations (give loyal advice), • • • • give you basic information about conflicts of interest. Integrated/the Adviser benefits financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated/the Adviser’s policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with our Firm. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated/the Adviser. Integrated/the Adviser will receive no compensation if a client or a prospective client receives a recommendation to leave their plan assets with their old employer.” IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated/the Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Integrated/the Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: leaving the funds in the employer's/former employer's plan, cashing out and taking a taxable distribution from the plan, and rolling the funds into an IRA rollover account. • • moving the funds to a new employer's retirement plan, • • Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: • Employer retirement plans generally have a more limited investment menu than IRAs, and • Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 7  2. Consider plan fees - your current plan may have lower fees than Integrated/the Adviser’s, fees: • if you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA, and • you should understand the various products and services you might take advantage of at an IRA provider and the potential costs. 3. Integrated/the Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated/the Adviser as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plans assets that comprise the client's account. The plan fiduciaries will confirm the services described in the Client Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge Integrated has no responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment made with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Integrated is not responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Integrated's Client Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide 8  appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Financial Planning Services Vineyard Asset offers broad-based personal financial planning services tailored to the client's needs and differentiated by the scope and depth of the areas to be addressed, analysis complexity, recommendations developed, deliverables created, and presentation. The scope of services is determined between the client and Advisor Representative. Financial planning services can take the form of one-on-one advice on investment matters or other guidance as contracted by the client and will range from comprehensive financial planning to consulting on a particular issue, including a focus on topics such as lifestyle objectives, retirement planning, planning for major purchases, long- term care needs, estate planning issues or other financial planning or consulting services needs as designated. A financial plan may include but is not limited to a net worth statement, cash flow statement, review of investment accounts - including reviewing asset allocation and providing repositioning recommendations, strategic tax planning, a review of retirement accounts and plans - including recommendations, insurance policy analysis and recommendations for changes, if necessary, one or more retirement scenarios, estate planning evaluation and recommendations, and education planning with funding guidance. Clients will execute a Financial Planning Agreement setting forth the terms and conditions of the engagement, including termination, describing the services' scope and the fixed or hourly fees due before commencing services. The final fee structure will be documented within the executed Agreement. Depending on the scope of the assignment and the complexity of the planning to be performed or advice to be given, financial planning services can take approximately one week to two months. Financial plans are based on the client's financial situation when the plan is presented, and the financial information disclosed by the client to Integrated/the Adviser. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. If the client's case differs substantially from what was disclosed at the initial meeting, a revised fee will be provided for review and acceptance. When a fee increase is necessary, the client must approve and agree to the scope change before any additional work is performed. In such cases, we will notify the client to obtain this approval. (See Item 5: Fees & Compensation for additional details.) As with all advisory services, the expectation is that the client will promptly notify the Adviser in writing of any material changes in assets, net worth, indebtedness, or planning objectives that the Adviser would not otherwise know. The client or their successor shall also promptly notify Integrated/the Adviser in writing of (a) the dissolution, termination, merger, or bankruptcy of the client if the client is other than a natural person and (b) the occurrence of any other event which might affect the validity of their Financial Planning Agreement or Integrated/the Adviser’s authority thereunder. Financial planning engagements terminate upon delivery of the written plan. Additional reviews may be conducted upon request, and written updates to the financial plan may be provided in conjunction with the review. Updates to financial plans may be subject to our then-current hourly rate, which the client must approve in writing and before the update. Financial planning services may be the only service provided to the client. Executing a Financial Planning Agreement neither constitutes an agreement for nor requires that the client use or purchase investment advisory or other services offered, or any insurance or other products or services offered by any advisory Associate as a result of any business activities in which they may participate outside their advisory activities with the Adviser. Neither Integrated nor the Advisor Representative will have discretionary investment authority when offering financial planning or consulting services. The services do not include implementing or monitoring the Advisor Representative's recommendations to the client. If the client receives a written financial plan, the plan will not 9  include information or analysis concerning liability risks, tax planning, or tax preparation services. If such services are necessary, the client shall be responsible for obtaining them from one or more third parties. Integrated/the Adviser reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. Clients should consult their Financial Planning Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Tailored Relationships The goals and objectives for each client are documented in our client relationship management system. Investment policy statements are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Client Agreements Agreements may not be assigned without client consent. Asset Management Investments may also include equities (stocks), warrants, options, corporate debt securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), and U. S. government securities. Assets are invested primarily in no-load or low-load mutual funds and exchange-traded funds, usually through brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Brokerages may charge a transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. The Adviser does not receive any compensation, in any form, from fund companies. Initial public offerings (IPOs) are not available through Integrated/VAM. VAM can allocate assets among private funds, including funds of funds, managed by third parties. With respect to fund of funds, VAM recommends funds on an alternative investment platform which manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents which each investor is required to receive and/or execute prior to being accepted as an investor in a fund. VAM does not invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Separate Account Management Platforms As part of the Adviser’s Asset Management Services, the Adviser offers access to multiple managers and allocation services through Separate Account Management Platforms. Based on the client’s needs and suitability, the Adviser may recommend or select a Separate Account Management Platform, to manage all, or a portion of, the client’s assets. Each platform includes access to sub-managers. WRAP Fee Programs Generally, the Adviser considers the Separate Account Management Platform to be a WRAP fee program through which investment advisory services and execution of the client’s transactions are provided for specified fees that are not based directly upon transactions in the client’s account. The Adviser receives a portion of the WRAP fee for investment management services provided. The Adviser and the representative do not manage WRAP fee accounts differently from other programs. For a complete description of the WRAP program, the WRAP fee and what services are included in the WRAP fee, refer to ADV Part 2A, Appendix 1, the WRAP Fee Program Brochure specific to the program that is being utilized. 10  Termination of Agreements A Client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated/VAM would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded. Assets Under Management As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Item 5 – Fees and Compensation Integrated/the Adviser’s advisory clients agree to pay an asset-based advisory fee calculated according to the indicated fee schedules. Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of the Form ADV Part 2A Brochure and the applicable Part 2B Brochure Supplement will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Advisory Services Fees The following describes how the Adviser is compensated for each of its advisory services. Fee Negotiation Availability Under certain circumstances, advisory services fees are negotiable up to the maximum annual rates listed herein, subject to certain limitations and approval by the Adviser. The Adviser, in its sole discretion, may charge lesser fees or choose to reduce or waive minimum fees for services based upon specific criteria such as a pre-existing financial planning client, anticipated future earning capacity, expected additional assets, the amount of client assets under management, related accounts, account composition, client negotiations, and pro bono activities, among others. At the Adviser’s discretion, certain accounts for members of a client's family or otherwise may be assessed fees based on the total balance of all accounts. Integrated/VAM will only accept clients with less than the minimum portfolio size if, in the Adviser’s opinion, the smaller portfolio size will not cause a substantial increase in investment risk beyond the client's identified risk tolerance. According to the selected advisory services, final fee structures will be reflected in each client's written Agreement. Integrated/the Adviser believes that the charges and fees offered are competitive with alternative programs available through other firms that may provide a similar range of services; however, lower fees for comparable services, at times, may be available from other sources. While the Adviser seeks to facilitate advantageous agreements for clients, to the extent fees are negotiable, some clients may pay higher (more >) or lower fees (< less) than other clients for services depending on factors such as account total assets under management, the number of related investment accounts, inception date, or other considerations, than if they had contracted directly with another provider. In all cases, clients are responsible for any tax liabilities that result from any transactions. 11  Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management & Supervisory Services Integrated/the Adviser provides investment management and supervisory services on a fee-only basis based on the value of the assets to be managed, the work to be provided, and the complexity of their situation. Investment management and supervisory services require a minimum portfolio value of $50,000. If engaged, fees range from 1.5% to 2.5% based on household asset holdings, calculated and billed consistent with the Adviser’s disclosure documents and each client’s contracts’ compensation arrangements. Individual client account fees will vary depending on the selected Program’s investment options and the fee schedule of each Integrated advisory group’s practices. However, in all cases, the Advisor Representative's advisory practices must ensure that the advisory fees they assess clients are accurate, up-to-date, and aligned with disclosures, up to the maximum annual rates. (Note: Lower fees for comparable services can sometimes be available from other sources.) Each client's executed Agreement will indicate the final advisory fees and fee-payment arrangements before the delivery of any advisory services. Fee Billing & Payment Integrated’s annual investment management and supervisory services fees are billed quarterly in advance according to the client’s Agreement. Clients may have their fees directly debited from the account held at their custodian of record or billed. Integrated will not access client funds for fees without written client consent. Clients who wish to have their fees directly debited will authorize Integrated in writing to deduct any advisory fees due from their custodial account directly and provide their custodian with authorization to deduct such amounts when due and remit them straight to Integrated. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing, a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Clients who wish to be billed by Integrated for their advisory services fees will authorize this form of payment in writing on their advisory Agreement and request that Integrated invoice them directly monthly or quarterly for any fees due. Clients will then make fee payments to Integrated by separate check or credit card within 45 days of 12  invoice receipt. Under no circumstance will any Integrated advisory fees be deducted from amounts they hold within their custodial account(s). (See Item: 15: Custody for additional details.) Additions, Withdrawals & Terminations Additions, withdrawals, and terminations to investment management and supervisory services client accounts are governed by the Agreement the client signs directly with Integrated. Clients may make cash or securities additions to their accounts at any time. Integrated reserves the right to liquidate any transferred securities or decline to accept particular securities into the client's account. If Integrated/VAM liquidates transferred securities, clients may be subject to additional fees such as transaction fees, other fees assessed at the mutual funds level such as contingent deferred sales charges, and tax ramifications. Clients may withdraw from their accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures. Additionally, if the client transfers their account to another firm, they may pay an outgoing account transfer fee. Terminations can be made to Integrated/VAM Agreements by written notice without penalty within five (5) business days after the Agreement execution date. After that, the contracts between Integrated/VAM and the client will continue according to the Agreement’s provisions, which state either party may terminate the Agreement without penalty upon 30 days written notice to the other party, following the Agreement’s provisions. (A "business day" shall be any day when the New York Stock Exchange is open for trading.) Terminations become effective on receipt of such notice and will not affect: the validity of any action previously taken by the Adviser under the Agreement, liabilities or obligations of the parties from transactions initiated before termination of the Agreement, or the client's responsibility to pay management and other fees due, pro-rated through the termination date. • • • The services fee will be pro-rated through the termination date. At termination, after the prior full billing period, the portfolio value will be used as the basis for the fee computation, adjusted for the number of days during the billing period before termination. Based on the termination date, any pre-paid, unearned fees will be promptly refunded to the client on this pro-rata basis. If the client is a natural person, the client's death, disability, or incompetency will not terminate or change the terms of an Agreement. However, the client's executor, guardian, attorney-in-fact, or another authorized representative may terminate the client's Agreement by providing written notice to Integrated/VAM. Before termination, all directions given or actions taken or omitted by Integrated/VAM before the effective Agreement termination shall be binding upon the client and any successor or legal representative. Upon the termination of an Agreement, Integrated/VAM will not possess any obligation to recommend or take any action with regard to the securities, cash, or other investments in a client's account and will no longer be entitled to receive fees from the termination date. Clients should refer to their Client Agreement for complete details. ERISA - Retirement & Employee Benefit Plan Services ERISA - retirement and employee benefit plan services fees are billed and payable according to the preceding investment management and supervisory services schedules. Account additions, withdrawals and terminations also follow the same procedures. Clients should refer to their Agreement for complete details. Financial Planning Services Fees Financial planning services fees are predicated upon the facts known at the start of the engagement. The minimum annual flat-rate fee for financial planning is $500 (or $125 each quarter if paid four times a year vs. annually). Based 13  on the client's services, fees can range higher to engage with Integrated as defined in each client's written and executed Financial Planning Agreement. At Integrated/the Adviser’s discretion, limited services are offered at a discounted rate. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. If the client's situation differs substantially from what was disclosed at the initial meeting, a revised fee will be provided for a mutual agreement. Agreements may be amended only by the client and Integrated/the Adviser’s mutual written consent. Ultimately, fees will be determined at the discretion of the advisor assigned to the account based on the required resources and plan complexity. If a financial planning services fee increase is necessary, the client must approve the scope change before any additional work is performed. Financial planning fees are billed in advance when the Financial Planning Agreement is executed and payable within ten (10) days of invoice presentation. Clients may directly authorize deducting these fees from their custodial account or pay them via check or credit card. After plan delivery, future fact-to-face meetings and follow-up implementation work may be scheduled as necessary free of charge for up to 3 months. The client will receive a fee refund upon delivery of the completed financial plan. Alternatively, Integrated/the Adviser may require the client to pay an initial retainer of 50% of the estimated financial planning fee before any services are rendered. The remaining balance is payable upon completion of the contracted services. Integrated/the Adviser are not responsible for any additional fees, commissions, expenses, or charges related to the transfer of assets from any other investment manager or advisor, real estate transactions or other expenses associated with real property transactions, or fees related to any major purchases or other transactions the client effects. The client's responsibility is to remit payment for the administrative expenses and fees due to the TPMs by Integrated/VAM for the financial plan and timely resolve such additional fees, commissions, expenses, or charges. Conflicts of Interest Please note that most Integrated/VAM advisory clients will pay a fee based on a percentage of the assets under advisement. This compensation method can sometimes lead to conflicts of interest between our firm and the client regarding our advice. As the services available from Integrated/VAM can be found through other companies at differing prices, we recommend clients review the components that determine charges and service calculations. Factors for consideration should include but are not limited to account size, type(s) of account(s), transaction charges, the range of advisory services, and each service's ancillary charges. Clients are urged to discuss any questions or concerns with their advisor. Other Fees & Expenses Clients should note that Integrated/VAM’s fees are exclusive of bank or custodial fees, brokerage commissions, transaction fees, and other related costs and expenses a client may incur. Some examples of these fees can include but are not limited to custodial fees, trading charges for odd-lot differentials, fixed income, or other transactional costs, including mark-ups, mark-downs, commissions, and dealer profits, charges imposed directly by exchange- traded funds in the account - which will be disclosed in the applicable fund's prospectus, wire transfer and electronic fund fees, or other costs and taxes on brokerage accounts and securities transactions. A third party can also impose fees for services elected by their clients, such as certificate delivery, American Depositary Receipts ("ADRs"), and transfer taxes mandated by law. Specific portfolios can also include transactions in foreign securities and execution on foreign stock exchanges, resulting in other transaction expenses. ETFs and other managed products or partnerships can also be in clients' portfolios. Clients can be charged for the services by the providers/managers of these products, and the advisory management fee paid to Integrated. Charges can be imposed directly by mutual funds, and mutual fund shares held in client accounts may be subject to 12b-1 fees, short-term redemption fees, and other annual fund expenses. No-load or load-waived mutual funds used 14  in client portfolios would not have initial or deferred sales charges; however, if a fund that imposes sales charges is selected, the client may pay an initial or deferred sales charge. Mutual funds pay advisory fees to their managers, which are indirectly charged to all mutual fund shareholders. Clients with mutual funds in their portfolio effectively pay the adviser and any third-party manager, custodian, and mutual fund manager to manage their assets. Each fund's prospectus fully describes fees and costs, which clients must carefully consider. The fees paid to Integrated are separate from the fees and expenses charged by mutual funds. As a client could invest in a mutual fund or investment partnership directly, without the services of Integrated/VAM, they should review both the fees charged by the funds and the applicable program fee charged by the adviser to evaluate the advisory services being provided fully and understand the total amount of fees to be paid by them. (Please note Integrated does not accept commission-based compensation nor receive mutual fund 12b-1 fees.) Clients may also incur "account termination fees" upon transferring an account from one brokerage firm (broker- dealer/custodian) to another. These account termination fees can range significantly from a nominal fee to several hundred dollars but can be much higher. Clients should contact their account custodians to determine the amount of account termination fees charged and deducted from their accounts for any accounts that may be transferred. (Please also see Item 12 - Brokerage Practices for additional details.) Integrated/VAM believes that the charges and fees offered within its program are competitive with alternative programs available through other firms offering similar services; however, lower fees for comparable services may be available from other sources. For example, a client could invest in mutual funds directly. In that case, the client would not receive the services provided by Integrated/VAM, which are designed, among other things, to assist them in determining which investments are most appropriate for their financial condition and objectives, the ability to undertake a disciplined approach to portfolio rebalancing while taking into account the tax ramifications of same and the avoidance of ad hoc emotional reactions to shorter-term market events. Further, some of the funds may not be available to the client directly without the use of an investment adviser granted access to such investments. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients The Adviser generally provides investment advice to individuals, pension and profit-sharing plans, trusts, estates, or charitable organizations, corporations or business entities. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. 15  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis The Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include but are not limited to cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. And existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s adviser will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Investment Strategies We use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Charting Analysis- involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis- a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis- 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 and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Long-Term Purchases- securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment 16  of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking- up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory- a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing- a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases- securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading- we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While the adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, the Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated/VAM will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: 17  Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Neither Integrated nor the Adviser can guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Adviser's Investment Activities - the Adviser's investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated/the Adviser. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Investment decisions will not always be profitable. Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. 18  Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of the firm and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time before a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage-backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations 19  to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. 20  Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that they otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that 21  "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. The final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short- term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the fund’s management costs.. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S. Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls 22  are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks - a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting 23  harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. 24  Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre-packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non- diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. 25  Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality. Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Risks of Specific Securities Utilized While the Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types 26  of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: • Risk of losing your entire investment in a relatively short period of time. • The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). • European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. • Specific exercise provisions of a specific option contract may create risks. • Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: • Options sold may be exercised at any time before expiration. • Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. • Writers of Naked Calls risk unlimited losses if the underlying stock rises. • Writers of Naked Puts risk substantial losses if the underlying stock drops. • Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. • Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. • Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. • Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. • Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. • The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: • The complexity of some option strategies is a significant risk on its own. • Option trading exchanges or markets and options contracts are always open to changes. • Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. • Risk of erroneous reporting of exercise value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. • 27  Internationally traded options have special risks due to timing across borders. • Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Integrated/the Adviser do not represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Advisor Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated/VAM are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. Neither Integrated/VAM nor its management has any disciplinary or legal proceedings to disclose material to a client’s evaluation of this advisory practice. Integrated/VAM has no outstanding issues and is registered as an investment adviser without restriction. The Adviser and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Certain of Integrated’s Advisor Representatives may have disciplinary actions against them for alleged violations of certain securities regulations, rules, and/or statutory provisions by Federal or state regulatory agencies. Clients may view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at www.adviserinfo.sec.gov by searching our firm name or CRD #171991. The SEC's website also provides information about any affiliated person registered or required to be registered as an Investment 28  Adviser Representative of the firm, including their disclosure items (if any). Copies are also available by contacting us directly at 855.729.4222 or viewing our website at www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations VAM is a DBA of Integrated, an independent registered investment adviser that provides only investment advisory services. Integrated does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Integrated and VAM Associates can be Registered Representatives (“RRs”) of non-affiliated broker-dealers and Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. Associates of Vineyard Asset offer brokerage products through their unaffiliated broker-dealer. They are not acting in a brokerage capacity or on behalf of Integrated concerning the services provided under our Agreement(s). Integrated is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. This practice presents a conflict of interest because the objectivity of the advice rendered to clients could be biased. The Advisor Representatives providing investment advice on behalf of our firm, who are also RRs of outside and separate broker-dealers, can be incentivized to effect securities transactions to generate commissions rather than solely based on a client’s needs. The Adviser addresses this conflict of interest by requiring Associates to disclose this type of relationship to clients. Associates satisfy this requirement by advising their clients of the nature of and 29  their role in the transaction or relationship and any compensation - including commissions or otherwise, to be paid to them by the brokerage firms with which they are affiliated at the time of any recommendation is made and/or product transactions occur. The Adviser further mitigates conflicts through its procedures to review client accounts relative to the client or investor's financial situation to ensure appropriate investment management services. Integrated is committed to ensuring that Associates adhere to the Firm's Code of Ethics and that the Adviser and all Associates fulfill their fiduciary duty to clients/investors. Designations VAM Associates can hold various other designations in connection with the approved outside business activities, separate from their role with the Adviser. VAM does not solicit clients to utilize any services offered by Associates in this capacity. Associates' recommendations or compensation for such designation services are separate from VAM’s advisory services and fees. Insurance Services Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use VAM for investment advisory services. In these capacities, Advisor Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from the Adviser. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents or Advisor Representatives. Promoter Relationships Integrated/VAM has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated/VAM ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Advisor receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Integrated/VAM can also serve as Promoter to the third-party money managers it engages for its Managed Account Solutions (“MAS”) Program services for advisory, administrative, and/or technological services. In this capacity, the Adviser will introduce clients for whom the referred manager's services are suitable and appropriate. In connection with such relationships, Promoter fees can range from 0% to 50% and vary based on the executed Solicitor Agreement. Fees shared will not exceed any limit imposed by any regulatory agency. Clients should refer to their TPM Agreement for exact details and amounts. (Please see Item 14: Client Referrals & Other Compensation for additional details.) Apart from our clients' fees, we do not receive any other economic benefits, including sales awards or prizes. 30  Tax Preparation Services Advisory clients may choose to use non-affiliated independent tax preparation services. And clients of the tax preparation providers may decide to use Integrated/VAM for financial planning and/or investment advisory services. Although Associates will make clients aware of the availability of tax preparation services, advisory clients are not required to utilize such services. Other Business Relationships VAM uses third-party resources to help run its business and provide services to its clients, mostly back-office related. The Adviser sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-added providers to service clients. While VAM has developed a network of professionals - accountants, lawyers, and otherwise, neither the Adviser nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since VAM’s Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. VAM addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of the firm, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, VAM’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of VAM, the investment adviser or under any VAM Advisory Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how VAM mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics (“Code”). A copy of our Code is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Rule 204A-1 of the Investment Advisers Act of 1940 requires all investment advisors registered with the Securities and Exchange Commission to adopt codes of ethics that set forth standards of conduct and comply with federal securities laws. Integrated takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of the supervised personnel who act on its behalf. The adviser believes each of its advisory clients is owed the highest level of trust and fair dealing and holds Associates to a very high standard of business practices and integrity. To that end, Integrated has adopted a Code of Ethics that sets forth the firm's conduct standards in keeping with its fiduciary obligation. Integrated's Code imposes upon Associates the duty to deal fairly and: render disinterested and impartial advice, • • make suitable recommendations to clients within the context of the total portfolio, given their needs, financial circumstances, and investment objectives, 31  exercise a high degree of care to ensure that all material facts are disclosed to clients, • • provide adequate and accurate representations of its business and other information about services and investment recommendations, • disclose any conflicts of interest, and • promote fair, ethical, and equitable practices. The Adviser's Code requires all Associates to exercise a fiduciary duty by acting in each client’s best interest while consistently placing client interests first and foremost. The Code applies to all Associates, including individuals registered with the adviser as Advisor Representatives or considered 'Supervised Persons' under the Advisers Act Rules. The Code may also be applied to any other person the Chief Compliance Officer designates. Integrated's Code outlines and prohibits certain activities deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict) and specifies reporting requirements and enforcement procedures. VAM Associates must abide fully by all applicable industry regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code, including any updates. The Code requires an affirmative commitment by Associates they will abide by all state and federal securities laws and provisions relating to client information confidentiality, a prohibition on insider trading, restrictions on the acceptance of significant gifts, outside activities reporting, and personal securities trading procedures for Covered Persons, among others. Upon employment or affiliation and at least annually after that, VAM Associates are required to attest to their understanding of, and compliance with, the Adviser’s Code of Ethics, including confirmation and acknowledgment by every licensed Advisor Representative, of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required of them. And execute an affirmation stating they will conduct business honestly, ethically, and fairly, avoiding all circumstances that might negatively affect or appear to affect its duty of complete loyalty to all clients. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities in which clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Or combine our securities orders with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. VAM Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. 32  Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Integrated does not maintain custody of the assets we manage on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Advisory Agreement execution and enter into a separate broker-dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), and Raymond James, each an unaffiliated, SEC- registered broker-dealer, Members FINRA/SIPC. • • • Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, Fidelity, and Raymond James as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment 33  • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some of which the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • 34  Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest may exist in making a reasonable good-faith allocation between research services and non- research services because Integrated/VAM allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which did not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated/VAM’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated/VAM and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated/VAM an incentive to 35  recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated/VAM may receive non-research - administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non-research and research portion of the services received and pay Integrated money ("hard dollars") for the non-research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place-specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) 36  Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Advisory Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Integrated in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; Integrated will not seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account that would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our firm or persons associated with our firm may buy or sell securities for you while we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Integrated makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) 37  Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated trade error. Gains from the trade error will be donated to a charity. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. VAM’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. VAM recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the account value at the period beginning and ending. Statements may also include performance, other pertinent, appropriate 38  information, and documents necessary for tax preparation. Statements and reports are sent to the mailing or email address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, VAM financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Advisor Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Integrated directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals VAM receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals VAM has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated/VAM will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the 39  applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated/VAM will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. VAM is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, the Adviser will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. VAM does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated/VAM. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although VAM is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated/VAM is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, Integrated does not compensate any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by VAM and its Associates, as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize VAM or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated/VAM addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated/VAM makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices The Adviser does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the 40  custodian of the record. Integrated is not authorized to withdraw any money, securities, or other property from any client custodial account in the client's name or otherwise. While Integrated prohibits the firm or its Associates from obtaining, accepting, or maintaining control of client funds, securities, or assets, with a client's consent, the Adviser may be provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If the Adviser is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. VAM requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated/VAM’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. To do this, the Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which 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 Integrated/VAM, 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 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 can terminate or change the instruction to the client's custodian, 4. 5. VAM has no authority or power 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, 6. VAM maintains records showing that the third party is not a related party of the Adviser or located at the 7. same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, the Adviser is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Our advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, the Adviser will execute securities transactions for clients 41  without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Integrated complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Advisor Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Integrated will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Advisor Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Advisor Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until the Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Integrated engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistent with the jointly agreed upon investment objectives, Integrated reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Integrated will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake 42  minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives if applicable. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to, and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 43 

Item 1 – Cover Page Lattice Wealth Management Group, Inc. Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 84 W Santa Clara St Suite 734 San Jose, CA 95113 5401 Business Park South, Suite 208 Bakersfield, CA 93309 201 Spear St., Suite 1100 San Francisco, CA 94105 mylatticewealth.com March 28, 2025 This Brochure provides information about the qualifications and business practices of Lattice Wealth Management Group Inc. If you have any questions about the contents of this Brochure, please contact us at 708-948-7092 or call the Chief Compliance Officer at 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration as an investment adviser with the SEC does not imply a certain level of skill or training. Additional information about the Advisor also is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training . 1  Item 2 – Material Changes Annual Update This section describes material changes to Lattice Wealth Management Group, Inc.’s Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. through the SEC’s Investment Adviser Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Lattice Wealth Management Group’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC at disclosure adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on October 28, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Page ........................................................................................................................................... 1 Item 2 – Material Changes ................................................................................................................................. 2 Item 3 – Table of Contents ................................................................................................................................. 3 Item 4 – Advisory Business ............................................................................................................................... 4 Item 5 – Fees and Compensation........................................................................................................................ 5 Item 6 – Performance Fees ................................................................................................................................. 6 Item 7 – Types of Clients ................................................................................................................................... 6 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................... 7 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 ....................... 13 Item 12 – Brokerage Practices.......................................................................................................................... 13 Item 13 – Review of Accounts ......................................................................................................................... 17 Item 14 – Client Referrals and Other Compensation ......................................................................................... 17 Item 15 – Custody ........................................................................................................................................... 18 Item 16 – Investment Discretion ...................................................................................................................... 18 Item 17 – Voting Client Securities ................................................................................................................... 18 Item 18 – Financial Information ....................................................................................................................... 19 3  Item 4 – Advisory Business Description of the Advisory Firm Lattice Wealth Management Group Inc. is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Advisor” or “Lattice Wealth”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Advisor provides personalized investment advice and portfolio management services to individuals, families, non-profit organizations and small businesses. The Advisor nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Principal Owners of Integrated Advisors Network, LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor will provide ongoing portfolio management services based on the risk profile of the client. The risk profile includes the client’s investment objectives, time horizon and risk tolerance. Investment portfolios are customized to meet the needs of each client. The investment process works through the Advisor and the client having a series of conversations to determine targeted portfolio constraints. Portfolio constraints provide a range of investment that can take place in the three asset classes considered by the Advisor. These are equities, fixed income, and cash. At times, the Advisor may override the constraints of the portfolio. The investment vehicles used to provide exposure to equities, fixed income and cash consist of common and preferred stock, corporate, government and municipal bonds and cash. There are occasions, usually dictated by account size, when the Advisor will utilize exchange-traded funds (ETFs) to manage portfolios. Smaller accounts sometime require ETFs because companies share prices are too high for those accounts to get an adequate percentage. This is also the case occasionally with corporate and municipal bonds, so the Advisor will use fixed income ETFs. The Advisor prefers to use common stock (over actively managed mutual funds and index funds) due to the direct ownership of companies, the tax benefits thereof and cost benefits. The weight of each position within the context of the client’s overall portfolio will depend on several factors including, but not limited to, the size of the investment, client risk profile, and other factors such as the cost basis of positions that are transferred from a previous broker. Money market funds will be the main investment vehicles used to provide exposure to the third asset class, cash. The Advisor also utilizes an income generating covered call program when warranted. This is used with client’s who have a risk level high enough and account sizes large enough to utilize it. The Advisor utilizes an approach where the client sells call options against portfolio companies at prices higher than the company stock price. This approach does not seek to buy call options for speculation on stock appreciation, rather to sell call options to generate income. There are occasions when, using this, approach that the stock is called away (sold). Financial Planning Services The Advisor will typically provide a variety of financial planning to individuals, families and other clients based on an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning will involve preparing a short, concise financial plan document or rendering a financial consultation for clients. The Advisor does not assume any responsibility for the accuracy of the information provided by the client and is not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant 4  or other such professional). The Advisor also offers client services ancillary to financial planning, which relate to addressing the needs required elder care and estate management. Services could be as simple as engaging with the clients’ senior living facility service or long-term care provider or as complex as assisting a successor trustee in tasks related to closing an estate. The Advisor will charge an hourly fee competitive with other providers in the area for these services. The Advisor will only service requests authorized by the client or power of attorney. Wrap Fee Programs The Advisor does not participate in wrap fee programs. Client Tailored Services and Client Imposed Restrictions Advisory services are tailored to achieve the investment objectives of individual Clients. Generally, the Advisor has the authority to select which and how many securities and other instruments to buy or sell without consultation with the Clients or their Investors. Clients may impose restrictions on investing in certain securities or types of securities. Amounts Under Management As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Michael Ross and Arnell Land are Investment Advisor Representatives of Integrated Advisors Network. Item 5 – Fees and Compensation Fee Schedule The fees and compensation payable to the Advisor are negotiable and vary among its clients. Management Fee Increasingly, the Advisor has clients’ accounts billed on a flat quarterly fee. This fee reflects the type of work done for the client and adjusted annually based on pre-determined measures of success. In legacy accounts, the client will pay the Advisor a fee for its investment advisory services. The specific manner in which fees are charged by the Advisor is established in a client’s written agreement with the Advisor. The fee will be calculated on a monthly basis and collected in advance. There is a fee range between 0.10% and 1.50% and based on a range of factors unique to each client. The fee will be calculated in the same manner for all clients; however, the fee is negotiable. Upon termination of the Investment Advisory Agreement, the Advisor shall refund any of the unused portion. The client has the right to terminate the contract without penalty within five (5) business days after entering into the Investment Advisory Agreement with the Advisor. After the five (5) business days, the client may terminate the Investment Advisory Agreement at any time by giving written notice to the advisor. The Advisor may terminate the Agreement at any time by giving the client at least 30 days written notice. The Advisor does not receive compensation for the purchase or the sale of securities or other investment products. The Advisor’s fee for portfolio management is exclusive of commissions, transaction fees, and other related costs and expenses in connection with trading and custody. These fees and expenses shall be incurred by the client. Additionally, clients may incur certain charges imposed by mutual fund and exchange traded funds such as internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to the Advisor’s fee, and the Advisor shall not receive any portion of these commissions, fees, and costs. 5  When the client seeks to have the Advisor to provide more administrative roles that do not constitute financial advice, the Advisor will charge an hourly fee for service. Such hourly rate will be competitive with similar providers in that geographical area. Performance Fee The Advisor does not charge a performance-based fee (fees based on a share of capital gains on or capital appreciation of the assets of a client). Fee Billing Investment management fees and fixed fees are deducted monthly in advance. Account values are based upon pricing information supplied by the client’s 3rd party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the Investment Advisory Agreement. Hourly billed fees are invoiced and deducted from the clients’ account monthly in arrears. Integrated Fee Disclosure The clients of Lattice Wealth will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Lattice Wealth’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Lattice Wealth’s fees are the lowest available for similar services. Financial Planning/Tangible Property Fees The Financial Planning fee will be determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. As our fee is based on each client’s personal situation, the complexity of the service, and time commitment required, we will provide an estimate of the total fee at the start of the advisory relationship. Financial planning fees are negotiable but generally fees are charged at the rate of $200 to $300 an hour or for a fixed fee that generally ranges from $1,000 to $25,000. The Advisor may also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. This is considered an integral part of the financial planning process and does not generate a separate fee. On occasion, the Advisor may enter into an agreement to offer financial consultation at a similar hourly rate as the financial planning rate. Item 6 – Performance Fees The Advisor does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients The Advisor provides portfolio management services to individuals, high net worth individuals, non-profit organizations, trusts, corporate and small business profit-sharing plans, and plan participants of corporate and small business retirement plans. 6  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investment Strategy The Advisor first ascertains the client’s risk profile – age, investment objectives, time horizon, risk tolerance and liquidity needs. The investment strategy undertaken by the Advisor is to create and monitor an investment portfolio that is consistent with the risk profile of each client. The Advisor normally considers three asset classes for the investment of client funds— equities, fixed income, and cash. For each asset class, the following are the primary investment vehicles: • Equities—common stock • Fixed Income—primarily corporate, US Government and municipal bonds. • Cash—primarily money market funds and CDs. Based on the client’s risk profile, the Advisor creates portfolio constraints for each client. Portfolio constraints provide a general range (the minimum to the maximum) of investment that can take place in the three asset classes that are considered by the Advisor. The weight of each investment vehicle within the context of the client’s overall portfolio will depend on several factors including, but not limited to, the size of the investment, client risk profile (risk tolerance, investment objectives, time horizon, etc.), and other factors such as the cost basis of positions that are transferred from a previous broker. The Advisor generally follows these risk management guidelines: • Adhere, with portfolio constraints set for each client. • Raise cash levels in declining and volatile equity markets. Methods of Analysis Common stocks are evaluated using technical analysis techniques as well as review of third- party research. Investment in any security always involves risk of loss that clients should be prepared to bear. Market fluctuations, interest rates, inflation, economic downturns, and individual business performance are some of the possible exposures. The Advisor will do its best to tailor the portfolio so that it meets both the client’s return expectations and risk tolerance, but this is not guaranteed. In addition, the client’s return expectations are subject to the realities of the financial markets and dependent on the risk the client is willing to assume. While the Advisor’s investment strategy is designed to mitigate exposure to various risks, the client needs to understand that the risks are there and to be prepared to bear losses that may result. At any point in time, a client’s investments will be worth more or less than originally invested. Here is some more on principal investment risks: Stock Market Volatility. The value of equity securities fluctuates in response to issuer, political, market, and economic developments. Fluctuations can be dramatic over the short as well as long term, and different parts of the market and different types of equity securities can react differently to these developments. Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in the financial condition of a single issuer can impact the market as a whole. Terrorism and related geo-political risks have led, and may in the future lead, to increased short- term market volatility and may have adverse long-term effects on world economies and markets generally. Interest Rate Changes. Debt securities have varying levels of sensitivity to changes in interest rates. In general, the price of a debt security can fall when interest rates rise and can rise when interest rates fall. Securities with longer maturities and mortgage securities can be more sensitive to interest rate changes. Foreign Exposure. Foreign securities, foreign currencies, and securities issued by U.S. entities with substantial foreign operations can involve additional risks relating to political, economic, or regulatory conditions in foreign 7  countries. These risks include fluctuations in foreign currencies; withholding or other taxes; trading, settlement, custodial, and other operational risks; and the less stringent investor protection and disclosure standards of some foreign markets. All of these factors can make foreign investments, especially those in emerging markets, more volatile and potentially less liquid than U.S. investments. In addition, foreign markets can perform differently from the U.S. market. In response to market, economic, political, or other conditions, the Advisor may temporarily use a different investment strategy for defensive purposes. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. 8  Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize 9  a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. 10  To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partner (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. 11  Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations The Advisor offers services through an Investment Advisor Representative of Integrated Advisors Network. The client should understand that Lattice Wealth Management Group is the legal entity of the IAR and not of the Firm, Integrated Advisors Network. The advisory services of the IAR are provided through Integrated Advisors Network. Brokerage Affiliations Associated persons of Integrated Advisors Network are registered representatives of a broker-dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated Advisors Network are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors Network. Integrated Advisors Network does not make any representation that the brokerage services are at the lowest cost available and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated Advisors Network. Integrated Advisors Network mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Insurance Affiliations Lattice Wealth and /or certain associated persons of Lattice Wealth sell insurance products to advisory clients. The clients who purchase insurance-related products are informed that Lattice Wealth or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that Lattice Wealth and/or the associated persons may sell insurance products to clients of Lattice Wealth and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. Lattice Wealth makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from Lattice Wealth or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Lattice Wealth . Our Firm offers services through our network of investment advisor representatives (“Investment Adviser Representatives” or “IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of our Firm, Integrated Advisors Network. The IARs are under the supervision of our Firm, Integrated Advisors Network, and the advisory services of the IAR are provided through our Firm, Integrated Advisors Network. 12  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Advisor may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Advisor on behalf of any client or is being considered for purchase or sale. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer reviews employee trades each quarter. The personal trading reviews ensure that the personal trading of employees does not affect the markets, and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies, or sectors; market, financial and economic studies, and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction, and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups 13  or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Best Execution As a fiduciary, the Advisor owes a fiduciary duty to its clients to obtain best execution of their transactions. That duty puts forth that an investment adviser generally must execute securities transactions in such a manner that the total cost or proceeds in each transaction is the most favorable under the circumstances. However, clients must understand that best execution does not necessarily mean the lowest available price. Instead, the totality of the arrangement and services provided by a broker-dealer must be examined to determine a qualitative measure of best execution. Based on these principles, commission and fee structures of various broker-dealers are periodically reviewed by the Best Execution Committee in order to evaluate the execution services provided by Cambridge and all of the unaffiliated broker-dealers and custodians used by the Advisor. Accordingly, while the Advisor does consider competitive rates, it does not necessarily obtain the lowest possible commission rates for client account transactions. Therefore, the overall services provided by the Advisor and all of the unaffiliated broker-dealers and custodians are evaluated to determine best execution. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. 14  Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third- party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific 15  custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts, or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account, or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. • In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. 16  Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and its registered Investment Advisor Representatives who review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive statements from custodian and reports from the advisor. The statements from the custodian should be available on a monthly basis and include portfolio holdings, associated market values, monthly account activity and month-end account balance. Additionally, the custodian produces trade confirmations as transactions occur. Reports from the Advisor are sent on a periodic basis and address such topics as the Advisor’s investment strategies, views of the current and historical market, and economic conditions. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or 17  client is referred to them. Item 15 – Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the advisor submit instructions to the custodian to remit a specific Advisor amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisors to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for discretionary authority to transact portfolio securities accounts on behalf of clients with no specific limitations as to type, amount, concentration, or leverage. Further, the Advisor may enter into any type of investment transaction and employ any investment methodology or strategy it deems appropriate. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. The Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor will not vote or advise clients how to vote proxies for securities held in client accounts. The client keeps 18  the authority and responsibility for the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to, and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet Long Course Capital Form ADV Part 2A – Firm Brochure 2121 Avenue of the Stars, Suite 1400 Los Angeles, CA 90067 310-612-3331 www.longcoursecapital.com March 28, 2025 This brochure provides information about the qualifications and business practices of Long Course Capital LLC. If you have any questions about the contents of this brochure, please contact us at: (310) 612-3331, or by email at: audra@longcoursecapital.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Long Course Capital Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Long Course Capital’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update Business Change of Location Long Course has moved its business location to 2121 Avenue of the Stars, Suite 1400, Los Angeles, CA 90067. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes ........................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................3 Item 4 – Advisory Business ......................................................................................................................................4 Item 5 – Fees and Compensation ..............................................................................................................................5 Item 6 – Performance Fees .......................................................................................................................................6 Item 7 – Types of Clients..........................................................................................................................................6 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................7 Item 9 – Disciplinary Information ..........................................................................................................................10 Item 10 – Other Financial Industry Activities and Affiliations ..............................................................................11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .........................11 Item 12 – Brokerage Practices ................................................................................................................................12 Item 13 – Review of Accounts ...............................................................................................................................15 Item 14 – Client Referrals and Other Compensation ..............................................................................................16 Item 15 – Custody ...................................................................................................................................................16 Item 16 – Investment Discretion .............................................................................................................................16 Item 17 – Voting Client Securities .........................................................................................................................17 Item 18 – Financial Information .............................................................................................................................17 3  Item 4 – Advisory Business Firm Description Long Course Capital, LLC is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter (“the Advisor” or “Long Course”). Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides personalized investment advice primarily to high-net-worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, and corporations and other business entities. The Firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has some associated persons who are in other fields where they receive commissions as compensation. The Advisor is not affiliated with entities that sell financial products or securities. The Advisor nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor, Integrated’s, or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Long Course Capital LLC is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network, LLC. Audra Mallow is an Investment Adviser Representative (“IAR” or “IARs”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing the Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, all aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s financial 4  situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided and the fees for the service. The agreement may be terminated by either party in writing at any time. Asset Management Investments may include equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), U.S. government securities, options contracts, futures contracts, and interests in partnerships. Assets in mutual funds and exchange-traded funds are invested in no-load or low-load, usually through brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Initial public offerings (IPOs) are not available through Integrated. WRAP Program The Advisor does not sponsor or provide investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor bases its fees on a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. The investment management fee is generally 1.00% of assets under management. Fee Billing Investment management fees are billed quarterly, in arrears based on the average daily account balance of the previous quarter of the assets held in the Account(s). Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. 5  Integrated Fee Disclosure The clients of Long Course will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Long Course’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Long Course’s fees are the lowest available for similar services. Other Fees If a client invests in investments not managed by the Advisor, such as private equity the client will likely incur fees from brokerages, custodians, administrators, and other service providers. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees are based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e., commission) including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisers selected by the Advisor may include mutual funds variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Advisor is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Advisor does not act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to high-net-worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Client relationships vary in scope and length of 6  service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $1,000,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Long Course Capital’s Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. 7  Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls, and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs, policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because 8  the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards. There may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. 9  To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or LP (“Limited Partnership”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. 10  Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations There are no affiliations or activities to disclose specific to Long Course Capital, but associated persons of Integrated are registered representatives of a broker dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated Advisors Network are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors Network. Integrated Advisors Network does not make any representation that the brokerage services are at the lowest cost available, and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated Advisors Network. Integrated Advisors Network mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Advisor may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Advisor on behalf of any client or is being considered for purchase or sale. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. 11  Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction, and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. 12  Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: Provide access to client account data (such as duplicate trade confirmations and account statements) Facilitate trade execution and allocate aggregated trade orders for multiple client accounts Provide pricing and other market data Facilitate payment of our fees from our clients' accounts Assist with back-office functions, recordkeeping, and client reporting • • • • • Educational conferences and events Consulting on technology and business needs Consulting on legal and compliance related needs Publications and conferences on practice management and business succession Access to employee benefits providers, human capital consultants, and insurance providers Marketing consulting and support Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • • • • • • The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business 13  entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. 14  • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly 15  from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Advisor has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 – Custody The Advisor does not accept or permit the Firm or its associated persons to obtain custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity, or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Advisor submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Advisor has the authority to determine, 16  without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The client may delegate to the Advisor the responsibility for voting proxies for securities held in client accounts. If the client elects to retain proxy voting responsibility, the client may ask the Advisor for advice regarding such votes. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for secure ties held in plan accounts. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 17 

Item 1 – Cover Sheet Abundantia Capital Corp Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 990 Stevens Lane McGregor, TX 76657 (254) 242-4571 March 28, 2025 This brochure provides information about the qualifications and business practices of Abundantia Capital Corp. If you have any questions about the contents of this brochure, please contact us at (254) 242-4571, or by email at hugh@abufinance.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Investment Adviser Public Disclosure website Annual Update This section describes material changes to Abundantia Capital Corp Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Abundantia Capital Corp’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s at www.adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update in March 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................8 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................8 Item 9 – Disciplinaary Information ..........................................................................................................................12 Item 10 – Other Financial Idustry Activites and Affiliations ...................................................................................12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................13 Item 13 – Review of Accounts .................................................................................................................................17 Item 14 – Client Referrals and Other Compensation ...............................................................................................18 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................18 Item 17 – Voting Client Securities ...........................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisory Business Firm Description Abundantia Capital Corp is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Advisor” or “Abundantia”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is a SEC registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. The Firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has some associated persons who are in other fields where they receive commissions as compensation. The Advisor is not affiliated by ownership with entities that sell financial products or securities. The Advisor nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Abundantia is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Hugh Stout is an Investment Advisor Representative (“IAR”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the Investment Adviser Representative utilizing the Advisor’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. 4  Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Abundantia through Integrated provides investment advisory services to Clients that are tailored to the Clients’ needs based on their financial situation and investment objectives. Abundantia is mindful of each Client’s financial situation, endeavoring to ensure that the Client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of Clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Abundantia. For some Clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no- load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Abundantia may offer/manage a more active options strategy that is based on the fundamental and/or technical evaluation of each company to determine attractive prices to buy or sell options. Initial public offerings (IPOs) are not available through Integrated. Financial Planning Abundantia through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Abundantia may also refer clients to an accountant, attorney or other specialist. For planning engagements, Advisor will provide a summary of client’s financial situation, observations, and recommendations. For consulting engagements, Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Abundantia whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Abundantia or its associated persons may receive compensation for financial planning and the provision of 5  investment management services and/or the sale of insurance and other products and services. Abundantia nor Integrated do not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Abundantia or use the services of Abundantia in particular. Wealth Coaching, Second Opinions & Financial Analysis Fees Abundantia may provide coaching services that typically do not include investment advisory or management services, financial planning services, nor the review or monitoring of a client's investment portfolio. The Advisor may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Advisor. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Advisor if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Advisor’s previous recommendations and/or services. WRAP Program The Advisor does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s Fee can range from .50% through 2.00%, depending upon the passive or active nature of the portfolio. Financial Planning Fees Financial Planning for clients without $300,000+ under management and for complex situations is provided under a fixed fee arrangement agreed upon at the first meeting and based on an hourly rate ranging between, $125 - $250. Fifty percent of the fee is payable in advance before the financial planning process is started. The remaining fifty percent is payable at the end of the engagement. Wealth Coaching, Second Opinions & Financial Analysis Fees 6  Abundantia provides a range of education, coaching and analysis services including "second opinions" on existing investment portfolios. These services are provided based on an hourly rate ranging between, $125 -$250. An estimate of project cost is made before the project is started. Fifty percent of the fee is payable in advance, and the balance is payable at the end of the engagement. Fee Billing Investment management fees are billed monthly, in arrears based on the total market value of the account as shown on the Firm’s provided portfolio statement on the last business day of the month. Account values are based upon pricing information supplied by the client’s 3rd party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Integrated Fee Disclosure The clients of Abundantia will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Abundantia’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Abundantia fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisors selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The Advisor, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Advisor will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. 7  The Advisor is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client The Advisor does not act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Conflict of Interest Between Different Fee Structures The Advisor offers several different services detailed in this brochure that compensate the Advisor differently depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Advisor mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Advisor is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. 8  Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Abundantia’s Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full 9  benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cashflow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes special problems enforcing claims against foreign governments. 10  • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. 11  Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partner (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information Abundantia and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations Some associated persons of Integrated are registered representatives of a broker dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors Network. Integrated does not make any representation that the brokerage services are at the lowest cost available, and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated. 12  Integrated mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear in marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Abundantia. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer, and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Advisor, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Advisor, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Advisor and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. 13  In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While we a certain custodian may be recommended, the client will decide whether to do so and will open your account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. 14  Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of 15  business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each Client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many Clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded 16  from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. 17  Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Solicitor Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Advisor submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or 18  sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities, and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet B&B Strategic Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 225 N Bennett St Suite F Southern Pines NC 28387 www.bbstrategic.com March 28, 2025 This brochure provides information about the qualifications and business practices of B&B Strategic Management. If you have any questions about the contents of this brochure, please contact us at (910) 751- 0848, or by email at jgalloway@bbstrategic.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, LLC, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. B&B Strategic Management’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update There have been no material changes since the last update in March 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................8 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................8 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 ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................13 Item 13 – Review of Accounts .................................................................................................................................17 Item 14 – Client Referrals and Other Compensation ...............................................................................................17 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................18 Item 17 – Voting Client Securities ...........................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisory Business Firm Description B&B Strategic Management is a dba of the registered entity Integrated Advisors Network. LLC, collectively hereinafter “the Advisor” or “B&B”. Integrated Advisors Network. LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. The Firm does not sell securities on a commission basis as part of its advisory services. However, Integrated may have associated persons who are in other fields where they receive commissions as compensation. The Advisor is not affiliated by ownership with entities that sell financial products or securities. The Advisor not Integrated do not act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. B&B Strategic Management is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Janet Galloway is an Investment Adviser Representative of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment policy statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s 4  financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management B&B Strategic Management through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. B&B Strategic Management is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by B&B Strategic Management for some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. B&B Strategic Management may offer/manage a more active options strategy that is based on the fundamental and/or technical evaluation of each company to determine attractive prices to buy or sell options. Initial public offerings (IPOs) are not available through Integrated. Financial Planning B&B Strategic Management will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. B&B Strategic Management may also refer clients to an accountant, attorney or other specialist. For planning engagements, the Advisor will provide a summary of client’s financial situation, observations, and recommendations. For consulting engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for B&B Strategic Management whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. B&B Strategic Management or its associated persons receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. B&B Strategic Management nor Integrated do not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from 5  other providers. However, the client is under no obligation to accept any of the recommendations of B&B Strategic Management or use the services of B&B Strategic Management in particular. Wealth Coaching, Second Opinions & Financial Analysis Fees B&B Strategic Management may provide coaching services that typically do not include investment advisory or management services, financial planning services, nor the review or monitoring of a client's investment portfolio. The Advisor may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Advisor. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Advisor if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Advisor’s previous recommendations and/or services. WRAP Program The Advisor does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client makes an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client makes an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s Fee can range from .75% through 2.0%, depending upon the passive or active nature of the portfolio. Financial Planning Fees Financial Planning for clients under management and for complex situations is provided under a fixed fee arrangement agreed upon at the first meeting. Fifty percent of the fee is payable in advance, before the financial planning process is started. The remaining fifty percent is payable at the end of the engagement. Wealth Coaching, Second Opinions & Financial Analysis Fees B&B Strategic Management provides a range of education, coaching and analysis services including "second opinions" on existing investment portfolios. These services are provided based on an hourly rate ranging between 6  $125 - $250. An estimate of project cost is made before the project is started. Fifty percent of the fee is payable in advance, and the balance is payable at the end of the engagement. Fee Billing Investment management fees will be billed quarterly in advance. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Integrated Fee Disclosure The clients of B&B will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. B&B’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that B&B’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e., commission) including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisers selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The Advisor, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Advisor will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases, there may be fees charged which are a result of brokered trading activity by associated personnel of the Advisor that is outside of the constructs of the Advisor’s investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client the fees may vary in size depending on the nature of the client’s requests. 7  Conflict of Interest Between Different Fee Structures The Advisor offers several different services detailed in this brochure that compensate the Advisor differently depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Advisor mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Advisor is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum account size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: 8  Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. B&B Strategic Management' Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly 9  volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rates the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. 10  Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities, and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own Advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts 11  through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information B&B Strategic Management has not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Insurance Affiliations B&B Strategic Management and/or certain associated persons of B&B Strategic Management sell insurance products to advisory clients through B&B Strategic Insurance. The clients who purchase insurance-related products are informed that B&B Strategic Insurance or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that B&B Strategic Insurance and/or the associated persons sell insurance products to clients of B&B Strategic Management and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. B&B Strategic Insurance makes no assurance that the insurance products are offered at the lowest available cost, and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from B&B Strategic Insurance or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by B&B Strategic Insurance. 12  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Advisor may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Advisor on behalf of any client or is being considered for purchase or sale. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction, and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of 13  compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available 14  include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. 15  If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/Investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/Investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs 16  brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. 17  Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Advisor submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and the Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. 18  Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet Sand Creek Investment Partners Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) P.O. Box 2240 Bend, OR 97709 (541) 330-5508 www.sandcreekinvestmentpartners.com March 28, 2025 This brochure provides information about the qualifications and business practices of Sand Creek Investment Partners, Inc. If you have any questions about the contents of this brochure, please contact us at (541) 330-5508, or by email at wendiehohman@sandcreekinvestmentpartners.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Sand Creek Investment Partners Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. SEC’s Investment Adviser Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Sand Creek Investment Partners’ current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update Item 4 Long Term Growth Description has been updated since the last brochure in March 2024. - 2  Item 3 – Table of Contents Item 1 – Cover Sheet ........................................................................................................................................... 1 Item 2 – Material Changes ................................................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................... 3 Item 4 – Advisory Business ................................................................................................................................. 4 Item 5 – Fees and Compensation .......................................................................................................................... 7 Item 6 – Performance Fees ................................................................................................................................... 8 Item 7 – Types of Clients ..................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................. 9 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 ......................... 13 Item 12 – Brokerage Practices............................................................................................................................ 13 Item 13 – Review of Accounts ........................................................................................................................... 17 Item 14 – Client Referrals and Other Compensation ........................................................................................... 17 Item 15 - Custody .............................................................................................................................................. 18 Item 16 – Investment Discretion ........................................................................................................................ 18 Item 17 – Voting Client Securities ..................................................................................................................... 19 Item 18 – Financial Information ......................................................................................................................... 19 3  Item 4 – Advisory Business Firm Description Sand Creek Investment Partners, Inc. is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser” or “Sand Creek”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides personalized investment advice primarily to other investment advisers or Investment Adviser Representatives. However, occasionally the Adviser will work with individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. The Firm does not sell securities on a commission basis. The Firm is not affiliated with entities that sell financial products or securities. The Adviser nor Integrated does not act as a custodian of Client assets and the Client always maintains asset control. The Adviser has discretion of Client accounts and places trades for Clients under a limited power of attorney. The Adviser does not act as a sponsor and does not provide investment advice to a wrap program through Integrated Advisors Network LLC. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the Client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated’s Principal Owner is TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services, for separately managed accounts of its Clients. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Sand Creek Investment Partners, Inc., is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. William Berner and Wendie Hohman are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each Client are documented in our Client relationship management system by the IAR utilizing Integrated’s programs. Investment Policy Statements are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without Client consent. Types of Services Investment Management As part of the investment management service, all aspects of the Client’s financial affairs are reviewed, and realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a Client’s 4  financial situation and portfolio through regular contact with the Client which often includes an annual meeting with the Client. The Adviser makes use of portfolio rebalancing software to maintain Client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the Client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Investments may include: equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (mutual funds shares), U. S. government securities, options contracts, futures contracts, and interests in partnerships. Assets in mutual funds and exchange-traded funds are invested in no-load or low-load, usually through brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Brokerages may charge a transaction fee for the purchase of some funds which the Client will pay. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades which the Client will pay. The Adviser does not receive any compensation, in any form, from fund companies. Initial public offerings (IPOs) are not available through Integrated. The Adviser offers several investment models described below: Conservative Compounding Growth These portfolios will usually own a combination of equities, fixed income, and cash. On occasion they may own other asset classes. Assets will tend to be owned as ETFs and mutual funds. The maximum equity exposure has an approximate guideline of 60 % of the portfolio value. During certain periods these portfolios could experience high turnover as a result of risk-management strategies. This will result in realized capital gains & losses. The goal is to provide lower volatility portfolios (average beta below the S&P 500) that exhibit some stability, some current income, and, over time, a return that exceeds inflation. These portfolios will be guided by a model account that is an actual family portfolio. This portfolio is often used in combination with other portfolios that utilize different investment strategies and goals. Diversified Growth This portfolio strategy has two primary objectives – minimize portfolio losses on a realized basis and grow the value of the portfolios, using a variety of technical indicators and strategies. The assets owned will be primarily ETF’s and common stocks. Other assets may be occasionally owned. It is likely there may be considerable turnover, and numerous short term realized gains and losses. For tax purposes, a tax-deferred account could be beneficial. Portfolios will range from fully-invested in equities to very large percentages of US Treasury bills and cash, depending on the investment environment, and the opportunities and risks offered by the markets. The strategy utilizes a variety of technical identifiers that suggest a positive risk/reward opportunity that could occur in the near future. The portfolio employs active risk-management. The portfolios will be guided by a model account that is an actual family portfolio. This portfolio is often used in combination with other portfolios that utilize different investment strategies and goals. 5  Long Term Growth These portfolios are usually fully-invested in equities, but may, from time to time, go to “cash”, T-Bills, or other alternatives to equities/stocks. The portfolios will primarily own ETF’s (Exchange Traded Funds), which mostly will be invested in US common stocks, but occasionally in foreign stocks, fixed income, or other alternatives. The portfolios are monitored regularly, and reviewed monthly or quarterly for re-balancing, which may or may not result in portfolio changes. The LTG portfolios are guided by a model portfolio that is an actual family portfolio. LTG portfolios are often used in combination with other portfolios that utilize different investment goals & strategies. Long Term Growth – SRI/ESG These portfolios have a long-term growth objective, with little or no market timing involved. They are comprised of ETFs and mutual funds; whose purpose is to offer the Client(s) a venue and placeholder to meet their desires to have socially responsible investments, of which may be a combination of environmental, social and governance business models. This model focuses on carefully selected holdings that have been through a variety of ESG screens and scoring based on ESG values aggregated held away data. The portfolios may have the opportunity to participate in the long term up trends of equity markets. The assets owned reflect the wishes of the Clients and the guidance of Sand Creek partners. These portfolios are reviewed every six months, or if major events occur in the Client's situation or the financial markets, or companies held within the ETFs or mutual funds have fallen out of favor within the ESG scoring parameters. They are then re-balanced if appropriate. While these portfolios are monitored daily, the portfolios have a long-term perspective. Because of the history of financial markets, Clients are encouraged to build an "investment cash reserve fund" separate from the equity portfolio in order to take advantage of the inevitable bear markets that occur, and often provide excellent investment opportunities when many investors are in panic. These portfolios are constructed based on each Client's wishes but are guided by similar portfolios for family members. Pure Fixed Income These portfolios may own fixed income assets: US Treasury bonds, notes, and bills, foreign sovereign bonds, US agency bonds, municipal bonds, corporate bonds, certificates of deposit, preferred stocks, money market funds, TIPS, zero coupon bonds, and other assets considered to be fixed income in nature. Portfolios may own these assets individually, in mutual funds, in ETFs, closed-end funds, or other vehicles that own fixed income assets. This strategy tends toward a conservative approach. The primary goal is preservation of capital, followed by current cash flow appropriate to the Client's risk tolerance and our outlook for that particular fixed income sector. A sub-set of this category would be an "investment cash reserve fund", which is similar, but usually owns shorter duration/maturities and will tend toward higher quality. Third Party Managers When appropriate to a Client's situation, we will use outside portfolio managers to manage a Client portfolio. With rare exceptions, these will be managers who also manage portfolios for our families. While we monitor these portfolios daily, the investment decisions are made by the outside managers. These tend to be long term portfolios, similar in objective to our Long-Term Growth portfolios. Consequently, we again encourage an "investment cash reserve fund" to build up cash reserves for future investment opportunities. WRAP Program The Adviser does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. 6  Termination of Agreements A Client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the Client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the Client in writing. If the Client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any financial planning engagement where a Client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded. Item 5 – Fees and Compensation Investment Management The Adviser bases its fees on a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the Client is at the Client’s discretion. The Client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. Sand Creek’s Client management fees range from 0.05% - 1.15%. The exact fee is based on the strategy(ies) the Client of the IAR selects. At the sole discretion of the Adviser, fees are negotiable for the different program service levels and lower fees may be charged to Clients affiliated with the Adviser. In addition, the Adviser may have arrangements in place with other management personnel and affiliates through which profits are split per agreed upon terms. Fee Billing Investment management fees are billed quarterly, in advance. For advance fee billing accounts, we invoice you - the client - before the three-month billing period has begun, based on the asset value of the client account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Fees are deducted from the Client account to facilitate billing as authorized by the investment management agreement. Integrated Fee Disclosure The clients of Sand Creek will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Sand Creek’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Sand Creek’s fees are the lowest available for similar services. Other Fees The Client will likely incur fees from brokerages, custodians, administrators, and other service providers. These fees are incurred as a result of managing a Client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the third-party manager selected by the Adviser may include mutual funds, variable annuity 7  products, ETFs, and other managed products or partnerships in Clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in Client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a Client may pay an initial or deferred sales charge. A Client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the Client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the Client and to thereby evaluate the advisory services being provided. If it is determined that a Client portfolio shall contain corporate debt or other types of over the counter securities, the Client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Adviser is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each Client. The Adviser does not act as a custodian of Client assets, and the Client always maintains asset control. The Adviser has discretion of Client accounts and places trades for Clients under a limited power of attorney. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review Client accounts relative to the Client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to Clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates, or charitable organizations, and corporations or business entities. Client relationships vary in scope and 8  length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the Client represents and warrants that the value of their account initially is at least $50,000. At the Adviser’s discretion, we may accept Clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Investment Strategies Strategies may include long-term purchases, short-term purchases, trading, short sales, margin transactions, and option writing (including covered options, uncovered options or spreading strategies). Strategies may include long- term purchases, short-term purchases, short sales and margin transactions. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Sand Creek Investment Partners, Inc.’ Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through 9  sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of 10  dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards. There may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of Client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts 11  through its Code of Ethics which provides that the Client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and Client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Depending on the nature of the investment management service selected by a Client and the securities used to implement the investment strategy, Clients will be exposed to risks that are specific to the securities in their particular investment portfolio. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment Clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations No members of Sand Creek are registered representatives of a broker dealer. Insurance Affiliations Sand Creek and /or certain associated persons of Sand Creek sell insurance products to advisory clients. The clients who purchase insurance-related products are informed that Sand Creek or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that Sand Creek and/or the associated persons may sell insurance products to clients of Sand Creek and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. Sand Creek makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from Sand Creek or its 12  affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Sand Creek . Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Sand Creek. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to Clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of Client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective Clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for Clients and may own securities of the issuers whose securities are subsequently purchased for Clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any Client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for Clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific Client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the Client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included 13  in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the Client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, 14  custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits 15  from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each Client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many Clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each Client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to Clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All Client/Investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among Client/Investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/Investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each Client/Investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each Client/Investor's, account's, or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each Client/Investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No Client/Investor, account or fund will be favored over any other Client/Investor, account, or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating Client/Investor accounts and the proposed method to allocate the order among the Client/Investors, accounts, or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the Client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the Client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. 16  Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive Client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for Client accounts. Directed Brokerage The Adviser allows Clients to direct brokerage, but the Adviser does not require Clients to direct brokerage. In the event that a Client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to Clients who direct the Adviser to use a particular broker or dealer and other Clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the Client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other Clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a Client's account, the Adviser may be precluded from aggregating that Client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the Client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the Client. Client accounts reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a Client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives Client referrals which may come from current Clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. 17  Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or Client is referred to them. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of Client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling Client assets. All checks or wire transfer to fund Client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of Clients’ funds or securities when Clients have standing authorizations with their custodian to move money from a Client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the Client. These SLOAs have been put in place upon the Client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a Client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect Client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to Clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge Clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of Clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the Client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade 18  in order to obtain client approval for the transaction(s). The Client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the Client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise Clients how to vote proxies for securities held in Client accounts. The Client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the Clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to Clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for Client funds or securities. 19 

Item 1 – Cover Sheet ReDefine Wealth Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 2970 Cherry Creek South Drive, Suite 4 Denver, CO 80209 (303) 495-5540 www.redefinewealthmanagement.com March 28, 2025 This brochure provides information about the qualifications and business practices of Redefine Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at: (303) 495- 5540, or by email at info@redefine-wm.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Redefine Wealth Management Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Redefine Wealth Management’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on March 28, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................8 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................9 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 ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................14 Item 13 – Review of Accounts .................................................................................................................................17 Item 14 – Client Referrals and Other Compensation ...............................................................................................18 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................19 Item 17 – Voting Client Securities ...........................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisory Business Firm Description ReDefine Wealth Management LLC is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser” or “ReDefine Wealth Management”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides ongoing investment advisory and management services, with respect to investments in securities, financial instruments and/or other assets, to individuals, families, trusts, estates, conservatorships, foundations, endowments, corporations or business entities and pension and profit-sharing plans, charitable organizations, public funds, investment limited partnerships, 401(k) self-directed accounts, IRAs and retirement plans, based on their individual needs. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Adviser does have discretion of client accounts and does not require the consent of each client for all security trades. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. ReDefine Wealth Management LLC is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Jeffrey Nuttall is an Investment Adviser Representatives (“IAR” of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. 4  Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management ReDefine Wealth Management through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. ReDefine Wealth Management is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, leveraged ETF’s, exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by ReDefine Wealth Management. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Initial public offerings (IPOs) are not available through Integrated. Financial Planning ReDefine Wealth Management through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning, charitable planning, education planning, and business planning. In certain circumstances, ReDefine Wealth Management will conduct financial and wealth planning for clients at no extra charge or fee. Even if a formal plan is not developed, ReDefine Wealth Management tailors and manages investment portfolios according to the specific financial objectives, taxability, and risk tolerance of the client, gathered through discussions in which goals and objectives based on a client's particular circumstances are established. Client accounts will be managed by ReDefine Wealth Management in accordance with the investment objectives, strategies, guidelines, restrictions, and limitations set forth in the investment advisory agreement and/or other applicable account documents. ReDefine Wealth Management does not assume any responsibility for the accuracy of the information provided by the client and is not obligated to verify any information received from the client or from the client’s other professionals (e.g. attorney, accountant, or other such professional). Under all circumstances, clients are responsible for promptly notifying ReDefine Wealth Management in writing of any material changes to the client’s financial 5  and investment objectives, taxability, time horizon, or risk tolerance. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. ReDefine Wealth Management may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for ReDefine Wealth Management whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. ReDefine Wealth Management or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. ReDefine Wealth Management does not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of ReDefine Wealth Management or use the services of ReDefine Wealth Management in particular. WRAP Program The Adviser does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. 6  WRAP Program Fee Schedule Annualized Investment Management Fees Incremental Account Value From $0 $1,000,001 $2,000,001 $5,000,001 $10,000,001 Over Incremental Account Value To $1,000,000 $2,000,000 $5,000,000 $10,000,000 $15,000,000 $15,000,001 Annual Percentage Fee 1.45% 1.30% 1.15% 1.00% 0.85% 0.70% Investment management fees will be billed quarterly in advance. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the Investment Management Agreement. Integrated Fee Disclosure The clients of ReDefine will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. ReDefine’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that ReDefine’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership 7  directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Adviser is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums The Adviser generally pursues clients with $10 million or more in net worth and $2 million in investment advisory assets. However, at its sole discretion, The Adviser may charge a lesser annual advisory fee or waive the stated client minimums based upon various factors, including, for example, anticipated future earning capacity, anticipated future assets, historical relationship, client investment experience, related accounts, account composition, negotiations with client, accounts referred to adviser by another professional, etc. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. 8  Clients will be required to sign investment advisory agreements (and/or other contractual arrangements) that, among other things, set forth the nature and scope of our investment advisory and management authority, specific services, and the investment objectives, guidelines, and restrictions applicable to the management of client accounts. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. ReDefine Wealth Management’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. 9  Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies, or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs, policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. 10  Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. 11  Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel, and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client 12  statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of ReDefine. Insurance Affiliations ReDefine Wealth Management and/or certain associated persons of ReDefine Wealth Management may sell insurance products to advisory clients. The clients who purchase insurance related products are informed that ReDefine Wealth Management or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that ReDefine Wealth Management and/or the associated persons may sell insurance products to clients of ReDefine Wealth Management and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. ReDefine Wealth Management makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from ReDefine Wealth Management or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by ReDefine. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. 13  Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark- downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. 14  Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting • Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business 15  entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional 16  compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage, but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. 17  Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity, or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. 18  Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1- Cover Sheet Auctum Wealth Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 41 Elderwood Lane Sharpsburg, GA 30277 (770) 783-6663 www.auctumwealth.com March 28, 2025 This brochure provides information about the qualifications and business practices of Auctum Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at (770) 783-6663, or by email at tom.king@auctumwealth.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Auctum Wealth Management Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Auctum Wealth Management’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update There have been no material changes since the last update in March 2024. 2  Item 3 – Table of Contents Item 1- Cover Sheet ....................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................7 Item 6 – Performance Fees .........................................................................................................................................9 Item 7 – Types of Clients ...........................................................................................................................................9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................9 Item 9 – Disciplinary Information ............................................................................................................................13 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................14 Item 12 – Brokerage Practices ..................................................................................................................................14 Item 13 – Review of Accounts .................................................................................................................................18 Item 14 – Client Referrals and Other Compensation ...............................................................................................18 Item 15 - Custody .....................................................................................................................................................19 Item 16 – Investment Discretion ..............................................................................................................................19 Item 17 – Voting Client Securities ...........................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................20 3  Item 4 – Advisory Business Firm Description Auctum Wealth Management LLC is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser” or “Auctum Wealth Management”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides ongoing investment advisory and management services, with respect to investments in securities, financial instruments, and/or other assets, to individuals, families, and high net worth individuals, based on their individual needs. The Firm does not sell securities on a commission basis. However, Integrated has some associated persons who are in other fields where they receive commissions as compensation. The Adviser is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Adviser does have discretion of client accounts and does not require the consent of each client for all security trades. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisers Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Auctum Wealth Management, LLC, is a dba of Integrated Advisors Network, LLC. All advisory services are offered through Integrated Advisors Network LLC. Thomas King is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment policy statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. 4  Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Auctum Wealth Management through Integrated offer discretionary portfolio management services. Investment advice is tailored to meet the clients' needs and investment objectives. If you retain our Firm for portfolio management services, Auctum Wealth Management will meet with you to determine your investment objectives, risk tolerance, and other relevant information at the beginning of our advisory relationship. If you participate in our discretionary portfolio management services, Auctum Wealth Management will require you to grant our Firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our Firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing Auctum Wealth Management with your restrictions and guidelines in writing. The Adviser may offer complimentary financial planning services as part of our portfolio management services. In limited circumstances and in our sole discretion, we may also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements with Auctum Wealth Management, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by Auctum Wealth Management on a non-discretionary basis. As part of our portfolio management services, in addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by our Firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our Firm. Our portfolio management services are provided as part of a WRAP fee program, which is a type of investment program that provides clients with access to asset allocation models for a single fee that includes administrative fees, management fees, and commissions. If you participate in our WRAP fee program, you will pay our Firm a single fee, which includes our money management fees, certain transaction costs, and custodial and administrative costs. We receive a portion of the WRAP fee for our services. The overall cost you will incur if you participate in our WRAP fee program may be higher or lower than you might incur by separately purchasing the types of securities available in the program. Initial public offerings (IPOs) are not available through Integrated. 5  Financial Planning Auctum Wealth Management through Integrated offers financial planning services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad-based financial planning to consultative or single subject planning. If you retain our Firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our Firm and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our Firm if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage Firm. There is an inherent conflict of interest for Auctum Wealth Management whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Auctum Wealth Management or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Auctum Wealth Management does not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Auctum Wealth Management or use the services of Auctum Wealth Management in particular. WRAP Program The Adviser does sponsor or provides investment management services to a WRAP program. The Adviser may offer clients of a group of services for one all-inclusive fee, known as a “WRAP fee.” For more information, please refer to the Adviser’s separate WRAP Fee Program Brochure. Other IARs under other group names at Integrated also offer wrap programs. Termination of Agreements A client may terminate any of the agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client makes an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the agreements at any time by notifying the client in writing. If the client makes an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. 6  Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected quarterly in arrears. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. WRAP Program Fee Schedule Annualized Investment Management Fees Incremental Account Value From $0 $500,001 $1,000,001 $2,000,001 $5,000,001 Incremental Account Value To $500,000 $1,000,000 $2,000,000 $5,000,000 over Annual Percentage Fee 1.80% 1.50% 1.25% 1.00% 0.85% Investment management fees will be billed quarterly in arrears, based on an average daily balance. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s 3rd party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. Financial Planning Fees We charge a fixed fee for financial planning services, which generally ranges between $1500 - $3000. The fee is negotiable depending upon the complexity and scope of the plan, your financial situation, and your objectives. We do not require you to pay fees six or more months in advance and more than $500. Should the engagement last longer than six months between acceptance of financial planning agreement and delivery of the financial plan, any prepaid unearned fees will be promptly returned to you less a pro rata charge for bona fide financial planning services rendered to date. At our discretion, we may offset our financial planning fees to the extent you implement the financial plan through our Portfolio Management Service. You may terminate the financial planning agreement upon 30 days written notice to our Firm. If you have pre- paid financial planning fees that we have not yet earned, you will receive a prorated refund of those fees. If financial planning fees are payable in arrears, you will be responsible for a prorated fee based on services performed prior to termination of the financial planning agreement. 7  Integrated Fee Disclosure The clients of Auctum Wealth Management will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Auctum Wealth Management’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Auctum Wealth Management’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred because of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Adviser is a fee-only investment management and financial planning Firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service 8  provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to individuals and high net worth individuals. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums The Adviser in general, does not require a minimum dollar amount to open and maintain an advisory account; however, we have the right to terminate your Account if it falls below a minimum size which, in our sole opinion, is too small to manage effectively. Other advisory groups of Integrated have minimums or may not have any minimum size account. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. Clients will be required to sign investment advisory agreements (and/or other contractual arrangements) that, among other things, set forth the nature and scope of our investment advisory and management authority, specific services, and the investment objectives, guidelines, and restrictions applicable to the management of client accounts. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of 9  the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Auctum Wealth Management’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, based on information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies, or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and 10  international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rates the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. 11  • Non-U.S. securities, commodities and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel, and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. 12  Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Auctum Wealth Management. Insurance Affiliations Auctum Wealth Management and/or certain associated persons of Auctum Wealth Management may sell insurance products to advisory clients. The clients who purchase insurance related products are informed that Auctum Wealth Management or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that Auctum Wealth Management and/or the associated persons may sell insurance products to clients of Auctum Wealth Management and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. Auctum Wealth Management makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from Auctum Wealth Management or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Auctum. 13  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation 14  that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: 15  Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. 16  If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account, or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account, or fund because of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage, but the Adviser does not require clients to direct brokerage. If a client directs the Adviser to use a broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker 17  or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and its registered Investment Adviser Representatives who review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. 18  Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice 19  or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 20 

Item 1 – Cover Sheet LIENART FAMILY ASSET MANAGEMENT Form ADV Part 2A – Firm Brochure 42158 Sand Dune Drive Palm Desert, CA 92211 (707) 280-5172 March 28, 2025 This brochure provides information about the qualifications and business practices of Lienart Family Asset Management. If you have any questions about the contents of this brochure, please contact us at (707) 280- 5172, or by email at lance@lienartfamilyassetmanagement.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Lienart Family Asset Management Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Lienart Family Asset Management’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on March 27, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................3 Item 4 – Advisory Business......................................................................................................................................4 Item 5 – Fees and Compensation .............................................................................................................................6 Item 6 – Performance Fees .......................................................................................................................................7 Item 7 – Types of Clients .........................................................................................................................................7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................7 Item 9 – Disciplinary Information ..........................................................................................................................11 Item 10 – Other Financial Industry Activities and Affiliations ..............................................................................11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .........................11 Item 12 – Brokerage Practices ................................................................................................................................12 Item 13 – Review of Accounts ...............................................................................................................................16 Item 14 – Client Referrals and Other Compensation .............................................................................................16 Item 15 - Custody ...................................................................................................................................................16 Item 16 – Investment Discretion ............................................................................................................................17 Item 17 – Voting Client Securities .........................................................................................................................17 Item 18 – Financial Information .............................................................................................................................17 3  Item 4 – Advisory Business Firm Description Lienart Family Asset Management is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser” or “Lienart”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides personalized investment advice primarily to high net worth individuals and institutional clients such as pension and profit-sharing plans. The Firm does not sell securities on a commission basis as an investment adviser. However, Integrated has some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated acts as a custodian of client assets and the client always maintains asset control. The Adviser may have discretion of client accounts and places trades for clients with their approval. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning and consulting matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Lienart is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Lance Lienart is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IAR’s utilizing Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. 4  Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. The Adviser may provide limited financial planning or other consulting services as part of its investment management services. To the extent specifically requested by a client, the Adviser may provide limited consultation services to its investment management clients on investment and non-investment related matters. Any such consultation services, to the extent rendered, shall be rendered exclusively on an unsolicited basis, for which the Adviser will not receive additional compensation. The client is under no obligation to act upon the Advisers recommendation. On occasion the Adviser will also provide free seminars related to financial planning, small business ownership, college savings, and other financial issues. These programs are designed to educate the public regarding their finances and the service offerings by the Adviser. Lienart provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Lienart is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Lienart or a third-party manager. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds and ETFs is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Initial public offerings (IPOs) are not available through Integrated. WRAP Program The Adviser does sponsor and/or provide investment management services to a WRAP program. Please see WRAP Fee brochure provided. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. 5  Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the month completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. Wrap Program Fee Schedule Annualized Investment Management Fees Incremental Account Value From $0 $1,000,001 $2,000,001 $5,000,001 $10,000,001 Over Incremental Account Value To $1,000,000 $2,000,000 $5,000,000 $10,000,000 $15,000,000 $15,000,001 Annual Percentage Fee 1.00% .95% .90% .85% .80% .75% Investment management fees will be billed and deducted quarterly. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Integrated Fee Disclosure The clients of Lienart will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Lienart’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Lienart’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, 6  ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases, there may be fees charged which are a result of brokered trading activity by associated personnel of the Adviser that is outside of the constructs of the Adviser’s investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client the fees may vary in size depending on the nature of the client’s requests. Item 6 – Performance Fees The Adviser does not charge performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser does not have an account minimum. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. 7  Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Lienart’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies, or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs, policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies, or other assets may be more expensive than options on other investments. 8  Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the client. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, 9  auditing, and financial reporting standards. There may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel, and accountants to determine what restrictions may apply and whether an investment managed by the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby exposes the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. 10  Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information Integrated is required to disclose information regarding any legal or disciplinary events material to a client’s evaluation of Lance Lienart. Mr. Lienart has a disciplinary history that requires disclosure pursuant to this item, the details which can be found on the SEC’s website at www.adviserinfo.sec.gov by searching Lance Lienart and CRD number 2623132. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Financial Affiliations Lance Lienart is also independently licensed as an insurance agent and may sell insurance products to clients and receive commissions when doing so. This is a potential conflict of interest, since commissions earned could be in addition to advisory fees earned in his capacity as an investment adviser representative. Clients are never obligated or required to purchase insurance products. Mr. Lienart may select any insurance company to purchase insurance products. Regardless of the insurance company selected, the insurance agent or agency will receive normal commissions from the sale. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Lienart Family Asset Management. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Lienart. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to 11  clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage/Custodian Selection and Soft Dollars The Adviser has the authority over the selection of the broker/custodian to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark- downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. 12  Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While we a certain custodian may be recommended, the client will decide whether to do so and will open your account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: 13  • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. 14  • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage, but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating 15  that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity, or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be 16  on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser does not contract for limited discretionary authority to transact portfolio securities accounts on behalf of clients. The Adviser does not have the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Advisers authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 17 

Item 1 – Cover Sheet Nspire Wealth Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 67 South Garfield St. Denver, CO 80209 (720)813-6856 www.nspire-wealth.net March 28, 2025 Officer of Integrated Advisors Network, Danielle Tyler This brochure provides information about the qualifications and business practices of Nspire Wealth, LLC. If you have any questions about the contents of this brochure, please contact us at (303) 618-9061, or by email at: brenda@nspire-wealth.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. Alternatively, contact the Chief Compliance at compliance@integratedadvisorsnetwork.com or call (855) 729-4222. 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Nspire Wealth Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729- 4222 or by email at compliance@integratedadvisorsnetwork.com. Nspire Wealth’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser www.adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx SEC#801-96203 or upon request through the client’s IAR. Material Changes since the Last Update Business Change of Location Nspire Wealth has moved its business location to 67 South Garfield St, Denver CO 80209. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................8 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................9 Item 9 – Disciplinary Information ............................................................................................................................13 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................14 Item 13 – Review of Accounts .................................................................................................................................17 Item 14 – Client Referrals and Other Compensation ...............................................................................................18 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................18 Item 17 - Voting Client Securities ............................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisory Business Firm Description Nspire Wealth, LLC is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser” or “Nspire Wealth”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC- registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides ongoing investment advisory, asset management, financial planning, and consulting services with respect to investments in securities, financial instruments and/or other assets, to individuals, families, trusts, estates, conservatorships, foundations, endowments, corporations, family offices, or business entities and pension and profit-sharing plans, charitable organizations, public funds, investment limited partnerships, 401(k) self-directed accounts, IRAs and retirement plans, based on their individual needs. The Adviser does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Adviser is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Adviser does have discretion of client accounts and does not require the consent of each client for all security trades. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Nspire Wealth LLC is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Brenda Cox is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. 4  Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client, which often includes an annual meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and they may be terminated by either party in writing at any time. Asset Management Nspire Wealth through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Nspire Wealth is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, exchange- traded funds (“ETFs”), leveraged ETF’s, alternative investments, and other securities as chosen by Nspire Wealth. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Initial public offerings (IPOs) are not available through Integrated. Financial Planning Nspire Wealth through Integrated will typically provide a variety of financial planning services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning, and charitable planning, education planning, and business planning. In certain circumstances, Nspire Wealth will conduct financial and wealth planning for clients at no extra charge or fee. Even if a formal plan is not developed, Nspire Wealth tailors and manages investment portfolios according to the specific financial objectives, taxability, and risk tolerance of the client, gathered through discussions in which goals and objectives based on a client's particular circumstances are established. Client accounts will be managed by Nspire Wealth in accordance with the investment objectives, strategies, guidelines, restrictions, and limitations set forth in the investment advisory agreement and/or other applicable account documents. Nspire Wealth does not assume any responsibility for the accuracy of the information provided by the client and is not obligated to verify any information received from the client or from the client’s other professionals (e.g. attorney, accountant, or other such professional). Under all circumstances, clients are responsible for promptly notifying Nspire Wealth in writing of any material changes to the client’s financial and investment objectives, taxability, time horizon, or risk tolerance. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable 5  giving programs. Nspire Wealth may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, Adviser may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Nspire Wealth whenever a financial plan recommends the use of professional investment management services or the purchase of insurance products or other financial products or services. Nspire Wealth or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Nspire Wealth nor Integrated do not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Nspire Wealth or use the services of Nspire Wealth in particular. WRAP Program The Advisor does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro-rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance; therefore, at termination, any unearned fees as determined on a pro-rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. Annualized Investment Management Fees Incremental Account Value From $0 $2,500,001 $5,000,001 $10,000,001 $25,000,001 $50,000,001 Over Incremental Account Value To $2,500,000 $5,000,000 $10,000,000 $25,000,000 $50,000,000 $100,000,000 $100,000,001 Annual Percentage Fee 2.00% 1.50% 1.25% 1.00% 0.80% 0.50% 0.40% 6  Investment management fees will be billed quarterly in advance. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Financial Planning Services The Adviser’s fees for planning services are strictly for planning services. Therefore, clients will pay fees and/or commissions for additional services obtained such as asset management or products purchased such as securities. Fees are negotiable. Client fees will be dependent on several factors, including time spent with Nspire Wealth, the number of meetings, the complexity of client situation, amount of research, services requested and resources. Fee Type Maximum Fee Payable The maximum hourly fee is $1,000 per hour. A payment schedule will be negotiated and customized to the client. The Adviser and client will agree on a fee payment schedule and outline the terms in the advisory agreement between the Adviser and client. A client will not be charged more than $500 in fees six months or more in advance. Consulting Services Nspire Wealth will bill clients Consulting Services at a pre-determined fee based upon a percentage of the assets. The exact fee is negotiated in advance of services rendered and is disclosed in the executed written agreement that we sign with the client. Fees will be billed quarterly in advance. In special circumstances, other fee-paying arrangements are negotiated. Termination Provisions A client may terminate advisory services obtained from Nspire Wealth, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with Nspire Wealth. Thereafter, the client may terminate investment advisory services with written notice to Nspire Wealth. Client will be responsible for any time spent by Nspire Wealth. If fees were paid in advance, the client will be refunded a prorated portion of the advisory fee. Integrated Fee Disclosure The clients of Nspire Wealth will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Nspire Wealth’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Nspire Wealth’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee-only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. 7  The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent, the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Adviser is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client's or investor's personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and firm plans, trusts, foundations, estates or charitable organizations, family offices, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. 8  Account Minimums The Adviser generally pursues clients with $10 million or more in net worth and $2 million in investment advisory assets. However, at its sole discretion, the Adviser may charge a lesser annual advisory fee or waive the stated client minimums based upon various factors, including, for example, anticipated future earning capacity, anticipated future assets, historical relationship, client investment experience, related accounts, account composition, negotiations with client, accounts referred to adviser by another professional, etc. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Clients will be required to sign investment advisory agreements (and/or other contractual arrangements) that, among other things, set forth the nature and scope of our investment advisory and management authority, specific services, and the investment objectives, guidelines, and restrictions applicable to the management of client accounts. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital, and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staff. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Nspire Wealth’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks 9  independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies, or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below 10  the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flow from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities, and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or 11  personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel, and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities, where there is a ready market that is traded through an exchange, are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in the price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. 12  Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Our Firm offers services through our network of Investment Adviser Representatives (“IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of our Firm, Integrated Advisors Network. The IARs are under the supervision of our Firm, Integrated Advisors Network, and the advisory services of the IAR are provided through our Firm Integrated Advisors Network. Our Firm, Integrated Advisors Network, has the arrangement described above with the following Adviser Representatives of: Nspire Wealth LLC. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. 13  Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. The Adviser is not required to negotiate "execution-only" commission rates; thus, the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, databases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. 14  We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waive its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. 15  The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. 16  The basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker-dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances, a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms that do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. 17  Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians, and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may, however, be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of businesses or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). 18  The client authorizes the discretion to select the custodian to be used, and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 - Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to, and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet Rama Financial, LLC Firm ADV Part 2- Firm Brochure (CRD #171991 / SEC #801-96203) Rama Financial, LLC 8717 N Circulo El Palmito Tucson, AZ 85704 www.ramafinancialllc.com March 28, 2025 This brochure provides information about the qualifications and business practices of Rama Financial, LLC. If you have any questions about the contents of this brochure, please contact us at: (415) 999-2162 or the Chief Compliance Officer at (855) 729-4222. 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 the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Rama Financial, LLC, Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Rama Financial’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on March 28, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................7 Item 7 – Types of Clients ...........................................................................................................................................7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................8 Item 9 – Disciplinary Information ............................................................................................................................10 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................11 Item 12 – Brokerage Practices ..................................................................................................................................12 Item 13 – Review of Accounts .................................................................................................................................16 Item 14 – Client Referrals and Other Compensation ...............................................................................................16 Item 15 - Custody .....................................................................................................................................................16 Item 16 – Item Discretion .........................................................................................................................................17 Item 17 – Voting Client Securities ...........................................................................................................................17 Item 18 – Financial Information ...............................................................................................................................18 3  Item 4 – Advisory Business Firm Description Rama Financial, LLC, does business under the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”. Integrated Advisors, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides investment advice and management to individually managed accounts that is tailored to the needs of individual clients, on a discretionary or non- discretionary basis. For discretionary clients, the Adviser, under a limited power of attorney, has discretion over the selection and the amount of securities to be bought or sold without obtaining specific client consent. Clients may impose restrictions on their investments upon request. These restrictions may include prohibitions or limits on individual securities, security types, asset classes, allocation, liquidity, credit quality and income. For non-discretionary accounts, the Adviser generally does not have discretion with respect to any of the assets. It is understood that the client is relying on the Adviser for general investment advice and client is under no obligation to act on any investment advice provided by the Adviser. The Adviser is given the ability to debit client accounts for advisory fees. The Adviser does not have discretion to move funds without the client’s consent. For these clients, the Adviser can only act on behalf of clients upon their express instructions. In such case, the Adviser cannot act on the clients’ behalf in the event of a volatile market with price swings that affect, negatively or positively, the values of the clients’ holdings. The Firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has associated persons who are in other fields where they receive commissions as compensation. The Adviser is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated do not act as a custodian of client assets and the client always maintains asset control. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Rama Financial, LLC, is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, all aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial 4  situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Rama Financial, through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Rama Financial is mindful of each client’s financial situation, ensuring that the client’s investment objectives are met on an ongoing basis, and ensuring that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITS”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Rama Financial. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load- waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Rama Financial may utilize third-party managers (“Money Manager”) to manage either a portion or a client’s entire portfolio. Rama Financial’s recommendation that a Money Manager manage a client’s account will be based on the Money Manager’s investment philosophy and policies, its record as an investment adviser, and Rama Financial’s determination that the investment style of the Money Manager is consistent with the client’s financial needs, risk tolerance and objectives. To ensure that Money Managers are still appropriate for a client, Rama Financial performs reviews of the Money Manager’s portfolios and financial standing and Rama Financial also updates the client’s financial objectives as necessary. Rama Financial may remove and replace Money Managers at its discretion when it believes a Money Manager is no longer consistent with the client’s needs and objectives or where, in the estimation of Rama Financial, the Money Manager’s portfolio is underperforming relative to its asset class or is poorly positioned relative to current market conditions. Access to certain Money Managers, platforms and programs may be limited to certain types of accounts and may be subject to account minimums, which will vary and may be negotiable depending upon the Money Managers, platforms and programs selected. Certain platforms and programs administered by Rama Financial and/or made available to clients by Rama Financial may be available through other independent investment advisers, and in certain instances, directly via the custodian or other third-party administering the platform or program. In addition, clients may be able to access certain Money Managers directly. As such, clients may be able to access such Money Managers, platforms and programs at a lower cost through other channels. Further, it may be possible for a client to access Money Managers directly or through other platforms or programs for an “unbundled” fee that is lower than the “bundled” fee that is available through Rama Financial. Initial public offerings (IPOs) are not available through Integrated. WRAP Program The Adviser does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. 5  Item 5 – Fees and Compensation Fees are negotiable and may vary, but generally will be based on an annual percentage rate of 1% of assets under management. Fees are payable quarterly at the beginning of each calendar quarter based on the market value of the assets under management at the close of the prior quarter. Fees on additions or withdrawals are pro-rated. A client may terminate an investment advisory agreement with five (5) business days advance written notice. On termination, clients may receive a refund of advisory fees on a pro-rated basis. Adviser prefers to have management fees deducted from client accounts. There are some legacy clients of Adviser that are invoiced and pay separately. Adviser believes that its fees are competitive with fees charged by other investment advisers for comparable services, but comparable services may be available from other sources for lower fees than those charged by Adviser. Adviser’s fees for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and exchange-traded funds (“ETFs”) to shareholders. Clients invested in mutual funds or ETFs will pay advisory fees to Adviser and will pay additional advisory, brokerage, custodial and administrative fees as a shareholder of the applicable mutual fund or ETF. These mutual fund or ETF fees and expenses are described in each fund’s prospectus. Adviser’s fees are also separate and distinct from custodial, accounting, legal and other fees incurred by clients. Adviser prefers to have management fees deducted from client accounts. There are some legacy clients of Adviser that are invoiced and pay separately. Adviser believes that its fees are competitive with fees charged by other investment advisers for comparable services, but comparable services may be available from other sources for lower fees than those charged by Adviser. Integrated Fee Disclosure The clients of Rama Financial will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Rama Financial’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Rama Financial’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a 6  possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Adviser is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. The annual services fee will be pro-rated through the termination date. At termination, after the prior full billing period, the portfolio value will be used as the basis for the fee computation, adjusted for the number of days during the billing period before termination. Based on the termination date, any pre-paid, unearned fees will be promptly refunded to the client on this pro-rata basis. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 6 – Performance Fees Adviser does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $250,000. At the Adviser’s discretion, we may accept 7  clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Adviser provides its clients with individualized investment advice tailored to the investment objectives and financial situation of each client. Adviser’s methods of analysis include fundamental analysis, charting and technical analysis. Adviser offers advice on the following types of securities: equities (exchange listed, over the counter and foreign issues); warrants; corporate debt securities; municipal securities; United States government securities and Certificates of Deposit; and ETFs and mutual funds. These investments bear the risk of loss at any time due to unforeseen market, economic, interest rate, liquidity, or other risks. When appropriate to the needs of the client, Adviser may recommend the use of trading (securities sold within 30 days), margin transactions, short sales and/or option writing as investment strategies. Because these investment strategies may involve increased risk of loss, they are only recommended when consistent with the client’s stated tolerance for risk. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Rama Financial’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position 8  to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs, policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. 9  Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or LP interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. 10  Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations There are no affiliations or activities to disclose specifically to Rama Financial, but associated persons of Integrated Advisors Network are registered representatives of a broker dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated Advisors Network are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors network. Integrated Advisors Network does not make any representation that the brokerage services are at the lowest cost available, and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated Advisors Network. Integrated Advisors Network mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the firm’s Code of Ethics and to ensure that the firm and its associate persons fulfill their fiduciary duty to clients or investors. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Rama Financial. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. 11  Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Potential Conflicts of Interest Related to Non-Discretion The Adviser provides non-discretionary investment management services, pursuant to which we may advise a client with respect to purchasing, selling, holding, valuing, or exercising rights associated with particular investments. In these circumstances, we generally do not execute purchases or sales on behalf of the client or a client may require that the Adviser seek the client’s approval prior to executing any buy or sell transactions for the client’s account. Discretionary and non-discretionary clients may hold the same or similar instruments. Where the Adviser is given authority to execute transactions upon the approval of a non-discretionary client, there may be timing differences related to the provision of advice to a non-discretionary client for consideration and that client’s determination of whether to act on the advice. As a result, trades may be executed for discretionary clients in advance of executions for non-discretionary clients, potentially disadvantaging the non- discretionary clients. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”), TD Ameritrade (“TDA”), and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and 12  operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While we a certain custodian may be recommended, the client will decide whether to do so and will open your account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available TD Ameritrade, Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data 13  • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. 14  • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage, but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. 15  Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Solicitor Referrals The Adviser has entered into agreements where it solicits clients and refers them to third-party investment advisers. The Firm will only refer clients to investment advisers that are registered with the Securities and Exchange Commission (SEC) or with the applicable state(s). If a client is referred to us by a solicitor, this practice is disclosed to the client in writing by the solicitor and the Adviser pays the solicitor out of its own funds – specifically, the Advisor generally pays the solicitor a portion of the advisory fees earned for managing the capital of the client or investor that was referred. The use of solicitors is strictly regulated under applicable federal and state law. The Adviser’s policy is to fully comply with the requirements of Rule 206(4)-3, under the Investment Advisers Act of 1940, as amended, and similar state rules, as applicable. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. 16  The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Item Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. 17  Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 18 

Item 1 – Cover Sheet Longview Investment Advisors Form ADV Part 2A – Firm Brochure 75 Arlington Street, 5th Fl. Boston, MA 02116 617-624-4105 March 28, 2025 This brochure provides information about the qualifications and business practices of LongView Investment Advisors. If you have any questions about the contents of this brochure, please contact us at: (415) 999-2162 or the Chief Compliance Officer at (855) 729-4222. 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 the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to LongView’s Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. SF – IAN’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC #801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on June 10, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................3 Item 4 – Advisory Business .....................................................................................................................................4 Item 5 – Fees and Compensation ...........................................................................................................................11 Item 6 – Performance Fees and Side-By-Side Management ..................................................................................15 Item 7 – Types of Clients .......................................................................................................................................15 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................15 Item 9 – Disciplinary Information ..........................................................................................................................24 Item 10 – Other Financial Industry Activities and Affiliation ...............................................................................24 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .........................26 Item 12 – Brokerage Practices................................................................................................................................27 Item 13 – Review of Accounts ...............................................................................................................................32 Item 14 – Client Referrals & Other Compensation ................................................................................................33 Item 15 – Custody ..................................................................................................................................................35 Item 16 – Investment Discretion ............................................................................................................................36 Item 17 – Voting Client Securities .........................................................................................................................37 Item 18 – Financial Information .............................................................................................................................38 3  Item 4 – Advisory Business Description of the Advisory Firm Longview Investment Management is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser” or “Longview”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. Integrated’s Principal Owner is TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, Integrated upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Advisor Representatives (“Advisor Representatives”). Each advisory relationship at Integrated is managed by one or more Advisor Representatives registered with the firm, who serve as the primary point of contact between Integrated and the client. Advisor Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Advisor Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Advisor Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Advisor Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Advisor Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Neither the Adviser nor Integrated act as a custodian of client assets and the client always maintains asset control. Integrated and the IAR have discretion of client accounts and places trades for clients under a limited power of attorney. Types of Advisory Services Integrated and the IAR provide investment management, financial advisory, and financial planning services. They do not sell securities on a commission basis. The IAR through Integrated provides ongoing portfolio management services based on the risk profile of the client. The risk profile includes the client’s investment objectives, time horizon and risk tolerance. Investment portfolios are customized to meet the needs of each client. The investment professionals emphasized continuous personal client contact and interaction in providing the following types of advisory services: • Investment Management & Supervisory Services, including: - ERISA - Retirement & Employee Benefit Plan Services - Managed Account Solutions (“MAS”) Program Services • Financial Planning Services • Educational Seminars & Workshops Services 4  The investment vehicles used to provide exposure to equities, fixed income and commodities will consist of a combination of index funds (both exchange traded funds and passively managed mutual funds). For diversification purposes, the Adviser prefers to use index funds (over actively managed mutual funds). The weight of each vehicle within the context of the client’s overall portfolio will depend on several factors including, but not limited to, the size of the investment, client risk profile, and other factors such as the cost basis of positions that are transferred from a previous broker. Money market funds will be the main investment vehicles used to provide exposure to the fourth asset class, cash. Client Responsibilities Advisory services depend and rely upon the information received from clients. The adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Advisor Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation - Integrated will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify Integrated in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. Integrated and its IARs reserve the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Following is a summary description of advisory services covered by this Brochure and the nature of the services provided. Please consult the applicable client Agreement and fee schedules for additional information regarding each service. Investment Management & Supervisory Services Investment management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. If appropriate for the account type established, Integrated will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. 5  According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Integrated does not maintain physical custody of client funds or securities other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission. Integrated primarily recommends that its clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Integrated will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS. (See Item 15 - Custody and Item 5 - Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented ongoing as the client, and Advisor Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income and Securities Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Code Standards, Integrated provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)), for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020- 02 ("PTE 2020-02") where applicable, clients should be aware of the following: When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • meet a professional standard of care when making investment recommendations (give prudent advice), follow policies and procedures designed to ensure that we provide advice that is in your best interest, charge no more than is reasonable for our services, and • never put our financial interests ahead of yours when making recommendations (give loyal advice), • avoid misleading statements about conflicts of interest, fees, and investments, • • • give you basic information about conflicts of interest. Integrated benefits financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a 6  client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset- based fee as outlined in the Agreement they executed with our Firm. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated. Integrated will receive no compensation if a client or a prospective client receives a recommendation to leave their plan assets with their old employer. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plan. Further, current employees can sometimes move assets out of their company plan before retiring or changing jobs. There are various factors Integrated will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Integrated, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of:  leaving the funds in the employer's/former employer's plan,  moving the funds to a new employer's retirement plan,  cashing out and taking a taxable distribution from the plan, and  rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any change: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: - Employer retirement plans generally have a more limited investment menu than IRAs, and - Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 2. Consider plan fees - your current plan may have lower fees than Integrated's fees: - if you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA, and - you should understand the various products and services you might take advantage of at an IRA provider and the potential costs. 3. Integrated's strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 7  6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts evidence their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plans assets that comprise the client's account. The plan fiduciaries will confirm the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge Integrated has no responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Advisor Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Integrated is not responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, it is the client's responsibility to obtain and maintain (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Integrated's Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will agree to provide appropriate documents evidencing such coverage promptly upon request. clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Financial Planning Services The Adviser offers broad-based personal financial planning services tailored to the client's individual needs and differentiated by the scope and depth of the areas to be addressed, analysis complexity, recommendations developed, deliverables created, and presentation. The scope of services is determined between the client and Advisor Representative. Financial planning services can take the form of one-on-one advice on investment matters or other guidance as contracted by the client and will range from comprehensive financial planning to consulting on a particular issue, 8  including a focus on topics such as lifestyle objectives, retirement planning, planning for major purchases, long- term care needs, estate planning issues or other financial planning or consulting services needs as designated. A financial plan may include, but is not limited to: a net worth statement, cash flow statement, review of investment accounts - including reviewing asset allocation and providing repositioning recommendations, strategic tax planning, a review of retirement accounts and plans - including recommendations, insurance policy analysis and recommendations for changes, if necessary, one or more retirement scenarios, estate planning evaluation and recommendations, and education planning with funding guidance. Clients are offered financial planning services as part of their investment management services. No additional fees are charged for financial planning services. Depending on the scope of the assignment and the complexity of the planning to be performed or advice to be given, financial planning services can take approximately one week to two months. Financial plans are based on the client's financial situation when the plan is presented and the financial information disclosed by the client to Integrated. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. As with all Integrated advisory services, the expectation is that the client will promptly notify the Adviser in writing of any material changes in assets, net worth, indebtedness, or planning objectives that the Adviser would not otherwise know. The client or their successor shall also promptly notify Integrated in writing of (a) the dissolution, termination, merger, or bankruptcy of the client if the client is other than a natural person and (b) the occurrence of any other event which might affect the validity of their Financial Planning Agreement or Integrated's authority thereunder. Conflicts of Interest Please note that there is an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser or its Advisor Representatives an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received rather than client needs. Integrated mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are under no obligation to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to effect the transaction through Integrated, its Advisor Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are under no obligation to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are under no obligation to place the transaction through Integrated or any third party recommended. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in the Adviser's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. 9  Types of Investments Integrated will generally provide investment and portfolio asset allocation advice and management on the following investment types: • • • • equities (stocks), corporate debt securities, exchange-traded funds investment company securities - variable life insurance, variable annuities, and mutual funds shares (no- load/ low-load), • warrants, and • U.S. government securities. Although Integrated provides advice predominately on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Other securities may be used to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost – typically, institutional share class. Integrated avoids market timing but will increase cash holdings when necessary. (Please note that an investment in money market funds is not insured or guaranteed by the FDIC or other government.) Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may impose restrictions on investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, the IAR will discuss the restriction request's feasibility to ensure expectations are met and confirm client acknowledgment and understanding of imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. In no event and regardless of the advisory service provided is the Adviser obligated to make any investment or enter any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. 10  Assets Under Management As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.35 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Item 5 – Fees and Compensation The advisory clients agree to pay an asset-based advisory fee calculated according to the indicated fee schedules. Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Integrated's Form ADV Part 2A Brochure and the applicable DBA Advisor Representative’s Part 2B Brochure Supplement will be provided to clients before or at the time of client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution, without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Advisory Services Fees The following describes how Integrated and the IAR are compensated for each of its advisory services. Fee Negotiation Availability Under certain circumstances, all advisory services fees are negotiable up to the maximum annual rates listed herein, subject to certain limitations and approval by Integrated. The Adviser, in its sole discretion, may charge lesser fees or choose to reduce or waive minimum fees for services based upon specific criteria such as a pre-existing financial planning client, anticipated future earning capacity, expected additional assets, the amount of client assets under management, related accounts, account composition, client negotiations, and pro bono activities, among others. At Integrated's discretion, certain accounts for members of a client's family or otherwise may be assessed fees based on the total balance of all accounts. Integrated will only accept clients with less than the minimum portfolio size if, in the Adviser’s opinion, the smaller portfolio size will not cause a substantial increase of investment risk beyond the client's identified risk tolerance. According to the selected advisory services, final fee structures will be reflected in each client's written Agreement. Integrated believes that the charges and fees offered are competitive with alternative programs available through other firms that may provide a similar range of services; however, lower fees for comparable services, at times, may be available from other sources. While the Adviser seeks to facilitate advantageous agreements for clients, to the extent fees are negotiable, some clients may pay higher (more >) or lower fees (< less) than other clients for services depending on factors such as account total assets under management, the number of related investment accounts, inception date, or other considerations, than if they had contracted directly with another provider. In all cases, clients are responsible for any tax liabilities that result from any transactions. Regardless of fee negotiation availability, under no circumstances will a client be required to pre-pay an Integrated advisory fee more than six months in advance, in excess of $1,200. Investment Management & Supervisory Services Integrated provides investment management and supervisory services on a fee-only basis based on the value of the assets to be managed, the work to be provided, and the complexity of their situation. If engaged, Integrated will charge an annual fee of up to 1.00%, based upon a percentage of the market value of the client’s assets under 11  management, calculated and billed consistent with the Adviser’s disclosure documents and each client’s contracts’ compensation arrangements. Individual client account fees will vary depending on the selected Program’s investment options and the fee schedule of each Integrated advisory group’s practices. However, in all cases, the Advisor Representative's advisory practices must ensure that the advisory fees they assess clients are accurate, up-to-date, and aligned with Integrated’s disclosures, up to the maximum annual rates listed herein. Clients should refer to the individual brochure of each advisory group for specific details. (Note: Lower fees for comparable services can sometimes be available from other sources.) Each client's executed Agreement will indicate final advisory fees and fee-payment arrangements before the delivery of any advisory services. Fee Billing & Payment The annual investment management and supervisory services fees are prorated, billed quarterly or monthly, and payable in arrears according to the client’s Agreement, based on a percentage of assets under management based on the average daily balance of the preceding quarter or month. The first quarter’s or month’s fees shall be calculated on a pro-rata basis. Clients will choose the frequency at which they wish to be billed and indicate their fee billing preference on their advisory services Agreement. Clients may have their fees directly debited from the account held at their custodian of record. Integrated will not access client funds for fees without written client consent. Clients who wish to have their fees directly debited will authorize the Integrated in writing to deduct any advisory fees due from their custodial account directly and provide their custodian with authorization to deduct such amounts when due and remit them straight to Integrated. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing, a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and their IAR to advise them of the missing items. Clients are urged to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Additions, Withdrawals & Terminations Additions, withdrawals, and terminations to investment management and supervisory services client accounts are governed by the Agreement the client signs. Clients may make additions to their accounts at any time in cash or securities. Integrated reserves the right to liquidate any transferred securities or decline to accept particular securities into the client's account. If Integrated liquidates transferred securities, clients may be subject to additional fees such as transaction fees, other fees assessed at the mutual fund level such as contingent deferred sales charges, and tax ramifications. 12  Clients may make withdrawals from their Integrated accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures. Additionally, if the client transfers their account to another firm, they may pay an outgoing account transfer fee. Terminations can be made to Integrated Agreements by written notice without penalty within five (5) business days after the Agreement execution date. After that, the contracts between Integrated and the client will continue according to the Agreement’s provisions, which state either party may terminate the Agreement without penalty at any time upon written notice to the other party, following the Agreement’s provisions. (A "business day" shall be any day when the New York Stock Exchange is open for trading.) Terminations become effective on receipt of such notice and will not affect: the validity of any action previously taken by Adviser under the Agreement, liabilities or obligations of the parties from transactions initiated before termination of the Agreement, or the client's responsibility to pay management and other fees due, pro-rated through the termination date. • • • The annual services fee will be pro-rated through the termination date. At termination, after the prior full billing quarter, the portfolio value will be used as the basis for the fee computation, adjusted for the number of days during the billing quarter before termination. Any pre-paid, unearned fees will be promptly refunded to the client on this pro-rata basis based on the termination date. If the client is a natural person, the client's death, disability, or incompetency will not terminate or change the terms of an Agreement. However, the client's executor, guardian, attorney-in-fact, or another authorized representative may terminate the client's Agreement by providing written notice to Integrated. Before termination, all directions given or actions taken or omitted by Integrated before the effective Agreement termination shall be binding upon the client and any successor or legal representative. Upon the termination of an Agreement, Integrated will not possess any obligation to recommend or take any action with regard to the securities, cash, or other investments in a client's account and will no longer be entitled to receive fees from the termination date. Clients should refer to their Investment Management Agreement for complete details. Educational Seminars & Workshop Fees Educational seminars and workshops are provided free of charge. Conflicts of Interest Please note that most advisory clients will pay a fee based upon a percentage of the assets under advisement. This compensation method can sometimes lead to conflicts of interest between our firm and the client regarding our advice. As the services available from Integrated can be found through other companies at differing prices, we recommend clients review the components that determine charges and service calculations. Factors for consideration should include but are not limited to account size, type(s) of account(s), transaction charges, the range of advisory services, and each service's ancillary charges. Clients are urged to discuss any questions or concerns with their Advisor Representative. Other Fees & Expenses Clients should note that fees are exclusive of bank or custodial fees, brokerage commissions, transaction fees, and other related costs and expenses a client may incur. Some examples of these fees can include but are not limited to custodial fees, trading charges for odd-lot differentials, fixed income, or other transactional costs, including mark-ups, mark-downs, commissions, and dealer profits, charges imposed directly by exchange-traded funds in 13  the account - which will be disclosed in the applicable fund's prospectus, wire transfer and electronic fund fees, or other costs and taxes on brokerage accounts and securities transactions. A third party can also impose fees for services elected by their clients, such as certificate delivery, American Depositary Receipts ("ADRs"), and transfer taxes mandated by law. Specific portfolios can also include transactions in foreign securities and execution on foreign stock exchanges, resulting in other transaction expenses. ETFs and other managed products or partnerships can also be in clients' portfolios. Clients can be charged for the services by the providers/managers of these products, and the advisory management fee paid to Integrated. Charges can be imposed directly by mutual funds, and mutual fund shares held in client accounts may be subject to 12b-1 fees, short- term redemption fees, and other annual fund expenses. No-load or load waived mutual funds used in client portfolios would not have initial or deferred sales charges; however, if a fund that imposes sales charges is selected, the client may pay an initial or deferred sales charge. Mutual funds pay advisory fees to their managers, which are indirectly charged to all mutual fund shareholders. Clients with mutual funds in their portfolio effectively pay the adviser and any third-party manager, custodian, and mutual fund manager to manage their assets. Each fund's prospectus fully describes fees and costs, which clients must carefully consider. The fees paid to Integrated are separate from the fees and expenses charged by mutual funds. As a client could invest in a mutual fund or investment partnership directly, without the services of Integrated, they should review both the fees charged by the funds and the applicable program fee charged by the adviser to evaluate the advisory services being provided fully and understand the total amount of fees to be paid by them. (Please note Integrated does not accept commission-based compensation, nor does it receive mutual fund 12b-1 fees.) Clients may also incur "account termination fees" upon transferring an account from one brokerage firm (broker- dealer/custodian) to another. These account termination fees can range significantly from a nominal fee to several hundred dollars but can be much higher. Clients should contact their account custodian to determine the amount of account termination fees charged and deducted from their accounts for any accounts that may be transferred. (Please also see Item 12 - Brokerage Practices for additional details.) Integrated believes that the charges and fees offered within its program are competitive with alternative programs available through other firms offering a similar range of services; however, lower fees for comparable services may be available from other sources. For example, a client could invest in mutual funds directly. In that case, the client would not receive the services provided by Integrated, which are designed, among other things, to assist them in determining which investments are most appropriate for their financial condition and objectives, the ability to undertake a disciplined approach to portfolio rebalancing while taking into account the tax ramifications of same and the avoidance of ad hoc emotional reactions to shorter-term market events. Further, some of the funds may not be available to the client directly without the use of an investment adviser granted access to such investments. Integrated encourages clients to speak with their Advisor Representative directly about any questions about the firm’s fees and compensation. Integrated Fee Disclosure The clients of Longview will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Longview’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Longview’s fees are the lowest available for similar services. 14  Performance Fee The Adviser does not charge a performance-based fee (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 6 – Performance Fees and Side-By-Side Management Performance-based fees are fees based on a client's account's share of capital gains or appreciation. Side-by-side management refers to managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Longview does not charge performance-based fees. As discussed in each entity’s disclosure brochure, certain Integrated Advisor Representatives who offer their advisory services through DBAs can charge performance fees, as disclosed within the advisory entity’s Form ADV disclosure documents. Item 7 – Types of Clients Client Types Discretionary and non-discretionary investment advice and management supervisory services are typically provided to individuals, high-net-worth individuals, trusts, estates, charitable organizations, pension & profit- sharing plans, corporations and business entities. Client relationships vary in scope and length of service. Minimum Account Size Investment management and supervisory services and ERISA - retirement and employee benefit plan services clients do not have a minimum account size requirement. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Customized investment recommendations are provided based on each client's specific circumstances and investment objectives as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan that intends to best meet the client's expressed personal short and long- term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include but are not limited to details of cash flow and liquidity requirements, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. And existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Advisor Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. The security analysis methods include charting, cyclical, fundamental, and technical analysis, each of which is briefly summarized below: Charting Analysis - is the use of patterns in performance charts to search for patterns used to help predict favorable conditions for buying and selling a security Cyclical Analysis - is the analysis of business cycles to find favorable conditions for buying and selling a security Fundamental Analysis - refers to the analysis of financial statements, the general financial health of companies, and the analysis of management or competitive advantages 15  Technical Analysis - the analysis of past market data, primarily price and volume. While many sources are consulted, the primary sources of information used for analysis include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses, filings with the Securities and Exchange Commission (“SEC”), and company press releases. Investment Strategies The primary investment strategy for client portfolios is strategic asset allocation - using a passively managed index and exchange- traded funds as the core investments and adding actively-managed funds where there are more potentially significant opportunities. Advisor Representatives may also use long or short-term purchases, short sales, margin transactions, and options writing, including covered or uncovered options and spreading strategies, and other approaches, as appropriate. While Advisor Representatives may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Advisor Representatives will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Market timing is avoided but cash holdings will be increased when necessary. Client cash balances are usually invested in FDIC insured deposit accounts, money market funds, or FDIC insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Risks of Loss & Other Types of Risk Clients should keep in mind that investing in securities involves a risk of loss that they should be prepared to bear. Past performance is in no way an indication of future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot offer any guarantees or promises that a client's financial goals and objectives will be met. Integrated does not represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described and any strategy or investments discussed may not suit all investors. Integrated is not engaged in law and does not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. 16  The following list of investment risks, which is not all-inclusive, is provided for careful consideration by a prospective client before retaining our services or contemplating investments in general. (Please note: The below items are presented alphabetically for ease of reading, not in order of importance.) Adviser's Investment Activities - the Adviser's investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and firm investment decisions will not always be profitable. Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulations changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit risk, interest rate risk, and prepayment risk. Business Risk - is the risks associated with a specific industry or company. Competition Risk - the securities industry and Advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - in administering client portfolios and financial reporting, advisers face inherent interest conflicts. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of the firm and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. 17  Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage-backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates, and the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - non-U.S. securities and other assets (through ADRs and otherwise) may give rise to risks relating to political, social, and economic developments abroad and risks resulting from the differences between the regulations of US and foreign issuers and markets. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is complex, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - the risk that an investment horizon is shortened because of an unforeseen event, for example, the loss of a job, which may force you to sell investments that you were expecting to hold for the long term. Investors may lose money if they must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed- income investments to decline. 18  Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses that would not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long- term investment strategy can expose clients to various risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power), interest rate, economic, market, and political/regulatory risks. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade multiple derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than the cost of investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds in addition to the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The Adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may, upon occasion, acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. Integrated will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have started and may not be able to sell an investment that it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, there is no guarantee that the share price will stay at $1/share. If the share price goes down, you can lose some or all of your principal. The U.S. Securities and Exchange Commission notes, "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable- the rate could go up or down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. Because money market funds are 19  considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Mutual & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments following the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage - borrows money to a significant degree, or concentrates in a particular type of security rather than balancing the fund with different security types. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The costs of managing the funds can reduce the returns on mutual funds and ETFs. Further, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with the performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments not included in the Underlying Index but expected to yield similar performance. Municipal Securities Risk - municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Non-U.S. Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those that conduct a substantial amount of their business outside of the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. 20  Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness, or accuracy of such information and data. In some cases, complete and accurate information is not available. Real Estate Risk - real estate funds face several risks inherent in this market sector. Liquidity, market, and interest-rate risk can influence the gain or loss passed on to the investor. Liquidity and market risk significantly affect more growth- oriented funds, as the sale of appreciated properties depends upon market demand. Conversely, interest rate risk impacts the dividend income that income-oriented funds pay. Clients considering private real estate products should review complete risk disclosures, as reflected in any recommended product offering documents. Reinvestment Risk - is the risk that future proceeds from investments must be reinvested at a lower return rate. Reinvestment Risk primarily relates to fixed income securities. REITs - REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in dilution of shares. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange- traded contract that requires delivery of a commodity, bond, currency, or stock index specified price on a specified future date. Unlike options, which the holder may or may not choose to exercise, futures contracts convey an obligation to purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - There are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors including but not limited to the class of stock such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large- cap") tend to be safer than smaller start-up companies ("small cap") are, but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments - including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for 21  investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - stocks' market value will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting the individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non- diversifiable, as diversification within the system will not reduce risk if the entire system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue and subject the adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in more significant brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, unsystematic risks may be reduced significantly by diversifying different investments. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. 22  It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Risks of Specific Securities Utilized Integrated seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets. However, it will utilize options writing, margin transactions, and short sales, which generally hold a higher risk of capital loss; there is a material risk of loss using any of these strategies. Margin - securities purchased on margin in a client's account are a firm's collateral for the client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act, such as issuing a margin call and/or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. A firm can increase its "house" maintenance margin requirements at any time, without the necessity of providing an advance written notice, without entitlement to an extension of time on the margin call. Options Contracts - an option is a contract that gives the buyer the right and the seller the obligation to buy or sell stock or futures contracts at a specific price for a set period. Options trading can present some or all of the following material risks, including others: - - - - - - - option sellers receive fixed compensation in exchange for accepting an obligation to buy or sell an underlying asset at a price that can fluctuate widely, securities price movement can make exercising options financially impractical; the options would expire worthlessly, which would result in the loss of the entire amount used to purchase the options, options sold may be exercised at any time before expiration, requiring the seller to purchase or sell underlying securities at an unfavorable price, sellers of naked positions run margin risks if the positions go into significant losses (i.e., liquidation of positions by the broker), sellers of call options can lose more money than a short seller of that stock on the same rise in the underlying stock, call options can be exercised outside of market hours, inhibiting remedies that the seller of those options can take, sellers of stock options may be obligated to buy or sell securities upon exercise even if a trading market is not available or they are unable to perform a closing transaction, the value of the underlying stock may unexpectedly increase or decline, leading to automatic - 23  - exercises of options against the seller, and options markets have the right to halt the trading of options, thus preventing investors from realizing value. Securities Futures Contracts - on tangibles and intangibles - a futures contract is a standardized, transferable, exchange- traded contract that requires delivery of a commodity, bond, currency, or stock index specified price on a selected future date. Unlike options, which the holder may or may not choose to exercise, futures contracts convey an obligation to purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include, but are not limited to, the following: - - - futures contracts have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the fluctuations of the overall stock and bond markets. Clients are advised that investors could lose money over short or even long periods, and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Advisor Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. Neither Integrated nor its management has any disciplinary or legal proceedings to disclose material to a client’s evaluation of this advisory practice. The IARs of Longview have not been subject to disciplinary events. Clients may also view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at www.adviserinfo.sec.gov by searching our firm name or CRD #171991. The SEC's website also provides information about any affiliated person registered or required to be registered as an Investment Adviser Representative of the firm. Copies are also available by contacting us directly at 855.729.4222 or viewing our website at www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliation Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 24  1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Mr. Brown is not currently engaged in any other business activities outside the role of being an IAR of Integrated. Solicitor Relationships Under SEC Rule 206(4)-3, the “Cash Solicitation Rule,” Integrated can engage and will directly compensate certain SEC-registered investment advisers as solicitors to refer suitable clients to the Adviser. Integrated can also serve as solicitor to the third-party money managers it engages for its Managed Account Solutions (“MAS”) Program services for advisory, administrative, and/or technological services. In this capacity, the Adviser will introduce clients for whom the referred manager's services are suitable and appropriate. In connection with such relationships, solicitor fees can range from 0% to 50% and vary based on the executed Solicitor Agreement. Fees shared will not exceed any limit imposed by any regulatory agency. Clients should refer to their TPM Agreement for exact details and amounts. (Please see Item 14: Client Referrals & Other Compensation for additional details.) Other Business Relationships Other third-party resources may be used to help run business and provide services to its clients, mostly back- office related. These professionals are sourced, acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, and relationships and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Advisory Agreement. Clients are under no obligation to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. 25  Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Rule 204A-1 of the Investment Advisers Act of 1940 requires all investment advisors registered with the Securities and Exchange Commission to adopt codes of ethics that set forth standards of conduct and comply with federal securities laws. Integrated takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of the supervised personnel who act on its behalf. The adviser believes each of its advisory clients is owed the highest level of trust and fair dealing and holds Associates to a very high standard of business practices and integrity. To that end, Integrated has adopted a Code of Ethics that sets forth the firm's conduct standards in keeping with its fiduciary obligation. Integrated's Code imposes upon Associates the duty to deal fairly and:  render disinterested and impartial advice,  make suitable recommendations to clients within the context of the total portfolio, given their needs, financial circumstances, and investment objectives,  exercise a high degree of care to ensure that all material facts are disclosed to clients,  provide adequate and accurate representations of its business and other information about Integrated's services and investment recommendations,  disclose any conflicts of interest, and  promote fair, ethical, and equitable practices. The Adviser's Code requires all Associates to exercise a fiduciary duty by acting in each client’s best interest while consistently placing client interests first and foremost. The Code applies to all Integrated Associates, including individuals registered with the adviser as Advisor Representatives or considered 'Supervised Persons' under the Advisers Act Rules. The Code may also be applied to any other person designated by the Chief Compliance Officer. Integrated's Code outlines and prohibits certain activities deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict) and specifies reporting requirements and enforcement procedures. Associates must abide fully by all applicable industry regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code, including any updates. The Code requires an affirmative commitment by Associates they will abide by all state and federal securities laws and provisions relating to client information confidentiality, a prohibition on insider trading, restrictions on the acceptance of significant gifts, outside activities reporting, and personal securities trading procedures for Covered Persons, among others. Upon employment or affiliation and at least annually after that, Associates are required to attest to their understanding of, and compliance with, the Adviser’s Code of Ethics, including confirmation and acknowledgment by every licensed Advisor Representative, of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required of them. And execute an affirmation stating they will conduct business honestly, ethically, and fairly, avoiding all circumstances that might negatively affect or appear to affect its duty of complete loyalty to all clients. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Or combine our securities orders with client orders to purchase securities 26  ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated and its affiliates mitigate conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Integrated nor its IARs do not maintain custody of the assets we manage on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide their custodian at the time of the Advisory Agreement execution and enter into a separate broker-dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but are not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab or Fidelity, as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, 27  • • the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • • • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians are in the business of serving independent investment advisory firms, providing advisers and their clients access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to a broad range of institutional investment products, securities transaction execution, and client assets custody. The investment products available include some of which the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, • • 28  access to employee benefits providers, human capital consultants, and insurance providers. • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset- based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or other compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research-related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third- party - originating from a party independent from the broker providing the execution services. A conflict of interest may exist in making a reasonable good-faith allocation between research services and non- research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which did not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a 29  conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research - administrative or accounting services and research benefits from the broker- dealers' services. When this happens, Integrated will make a good-faith allocation between the non-research and research portion of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to have access to this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place-specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have an incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information received from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) 30  Best Execution Integrated and its IARs act on their duty to seek “best execution.” As a matter of policy and practice, Integrated and the IAR conduct initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the clients written Advisory Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated and the IAR will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage In some instances, a client may direct Integrated or the IAR in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; Integrated will not seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account that would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our firm or persons associated with our firm may buy or sell securities for you while we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation process require fair and equitable treatment of all client orders. (See Item 11 - Code of Ethics, Participation or Interest In Client Transactions& Personal Trading.) Client Participation In Transactions Integrated makes investment decisions and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11 - Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) 31  Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions that a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services and ERISA - retirement and employee benefit plan benefit services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation such as retirement, termination of employment, a physical move, or inheritance. Changes in the tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Managed account solutions program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities are consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. 32  Client Reports Regular Reports At the time of account inception, investment management and supervisory services and ERISA - retirement and employee plan benefit services, clients will direct their custodian to send them statements at least quarterly and provide Integrated duplicate copies of all periodic statements and other reports for the account the custodian sends to the client. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the account value at the period beginning and end. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability, detailing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Advisor Representative practices or on an ad hoc basis. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information received from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated nor its IARs cannot guarantee the accuracy or completeness of any report or any other information provided to the client or adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Integrated directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals & Other Compensation Client Referrals Client referrals are received from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. 33  Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), only clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate will be referred, and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Rule 206(4)-3 under the Advisers Act. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any solicitation activities, Advisor Representatives will disclose such referral arrangements to affected clients and provide a separate disclosure document, a copy of the referred outside manager's Form ADV Part 2A, and other such disclosures as may be required by the referred manager or state in which the client is solicited. And will obtain a signed client acknowledgment of receipt of these items, which the referred manager will maintain. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to a solicited client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated has an incentive to recommend clients to referred managers, its primary responsibility is to ensure its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, Integrated does not compensate any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates as described herein presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. 34  Item 15 – Custody Custodial Practices Integrated's policy does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian, who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and their custodian of the record. Integrated is not authorized to withdraw any money, securities, or other property from any client custodial account either in the client's name or otherwise. While Integrated prohibits the firm or its Associates from obtaining, accepting, or maintaining control of client funds, securities, or assets, with a client's consent, the Adviser may be provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which 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 Integrated, 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 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 can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power 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, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or 7. located at the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. 35  Item 16 – Investment Discretion Account Management Style Services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Integrated will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Integrated complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Advisor Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Integrated will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Advisor Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre- approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Advisor Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Integrated reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Integrated engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistent with 36  the jointly agreed upon investment objectives, Integrated reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Integrated will provide ongoing supervision, and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Item 17 – Voting Client Securities Proxy Voting Integrated nor its IARs will not ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Integrated or the IAR may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights of and remedies for large numbers of people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. There is no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these types of legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Integrated will not advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Integrated does not provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. 37  Item 18 – Financial Information Balance Sheet Integrated does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated nor its management has any financial conditions that are likely to impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self-regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in Previous Ten Years The Adviser has no financial impairment that will preclude it from meeting contractual commitments to clients. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. Disciplinary Disclosures Certain of Integrated's financial professionals have legal or disciplinary histories to disclose. Please visit the United States Securities and Exchange Commission's ("SEC") website at www.adviserinfo.sec.gov for a free and simple search tool to research Integrated and its financial professionals, management members, officers, and firm principals. 38 

Item 1 – Cover Sheet All Source Investment Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) CityPlace I 185 Asylum Street, Suite 106 Hartford, CT 06103 (860) 904-5219 www.allsourceinvest.com justin.bernier@allsourceinvest.com patrick.kennedy@allsourceinvest.com March 28, 2025 This brochure provides information about the qualifications and business practices of All Source Investment Management (“All Source” or “Advisor”). If you have any questions about the contents of this brochure, please contact us at: (860) 904-5219 or by email at: justin.bernier@allsourceinvest.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network at compliance@integratedadvisorsnetwork.com or call 855- 729-4222. 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 the Advisor is available on the SEC’s website at www.adviserinfo@sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to All Source Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. All Source’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801- 96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on March 27, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................8 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................9 Item 9 – Disciplinary Action ....................................................................................................................................12 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................14 Item 13 – Review of Accounts .................................................................................................................................17 Item 14 – Client Referrals and Other Compensation ...............................................................................................18 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................19 Item 17 – Voting of Client Securities .......................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisory Business Firm Description All Source Investment Management is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter (the “Advisor” or “All Source”). Integrated Advisors Network (“Integrated”) was founded in 2015 and is an SEC-registered investment advisor. The Advisor is a fee-only investment management firm. The Advisor provides ongoing investment advisory, asset management, financial planning, and consulting services with respect to investments in securities, financial instruments and/or other assets to individuals, families, trusts, estates, conservatorships, foundations, endowments, corporations, family offices, or business entities and pension and profit-sharing plans, charitable organizations, public funds, investment limited partnerships, 401(k) self-directed accounts, IRAs and retirement plans, based on their individual needs. The Advisor does not sell securities on a commission basis as part of its advisory services. However, Integrated Advisors has associated persons who are in other fields where they receive commissions as compensation. The Advisor is not affiliated by ownership with entities that sell financial products or securities. Neither the Advisor nor Integrated Advisors act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and does not require the consent of each client for all security trades. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. All Source Investment Management is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Justin Bernier and Patrick Kennedy are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IAR utilizing Integrated’s programs. Investment policy statements may also be created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives 4  change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s financial situation and portfolio through regular contact with the client, which often includes an annual meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service, and they may be terminated by either party in writing at any time. Asset Management All Source through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situations and investment objectives. The Advisor is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments, including stocks, bonds, mutual funds (stock funds, bond funds, and other share classes), options, exchange-traded funds (“ETFs”), leveraged ETFs, alternative investments, and other securities as chosen by All Source. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created, and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. All Source Investment Management, while working primarily with accredited investors/qualified purchasers, specializes in alternative investments. Therefore, most investment portfolios will have a significant allocation to alternative investments with varying degrees of liquidity. Andersen Capital Management Weather Mark Long/Short, LLC Associates of All Source offers Weather Mark Long/Short, LLC on a fee-based discretionary managed account service. All Source acts as a distributor for Weather Mark Long/Short. Financial Planning All Source through Integrated will typically provide a variety of financial planning services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning, and charitable planning, education planning, and business planning. In certain circumstances, All Source will conduct financial and wealth planning for clients at no extra charge or fee. Even if a formal plan is not developed, All Source tailors and manages investment portfolios according to the specific financial objectives, taxability, and risk tolerance of the client gathered through discussions in which goals and objectives based on a client's particular circumstances are established. Client accounts will be managed by All Source in accordance with the investment objectives, strategies, guidelines, restrictions, and limitations set forth in the investment advisory agreement and/or other applicable account documents. All Source does not assume any responsibility for the accuracy of the information provided by the client and is not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, or other such professional). Under all circumstances, clients are responsible for promptly notifying the Advisor in writing of any material changes to the client’s financial and investment objectives, taxability, time horizon, or risk tolerance. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, 5  commence or alter retirement savings, or establish education or charitable giving programs. All Source may also refer clients to an accountant, attorney, or other specialists. For planning engagements, the Advisor will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of the contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for All Source whenever a financial plan recommends the use of professional investment management services or the purchase of insurance products or other financial products or services. All Source or its associated persons may receive compensation for financial planning and the provision of investment management services and other products and services. All Source nor Integrated do not make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of All Source or use the services of All Source in particular. WRAP Program The Advisor does not sponsor or provides investment management services to WRAP programs. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the agreements at any time by notifying the Advisor in writing. Clients shall be charged pro-rata for services provided through to the date of termination. If the client made an advance payment, the Integrated will refund any unearned portion of the advance payment. The Advisor may terminate any of the agreements at any time by notifying the client in writing. If the client made an advance payment, the Integrated will refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the client’s length of service is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance; therefore, at termination, any unearned fees as determined on a pro-rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Advisor, and fees for comparable services may be available from other sources. Investment management fees will be billed monthly in advance. For advance fee billing accounts, we invoice you before the monthly billing period has begun, based on the asset value of your account on the last day of the previous month. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s 3rd party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. 6  FEE SCHEDULE ANNUAL FEE MANAGED ASSETS 1.5% Below $1,000,000 1.3% $1,000,000 - $3,000,000 1.2% $3,000,000 - $5,000,000 1.1% $5,000,000 - $10,000,000 Negotiable $10,000,000+ Financial Planning Services The Advisor’s fees for planning services are strictly for planning services. Therefore, clients will pay fees and/or commissions for additional services obtained, such as asset management, or products purchased, such as securities. Fees are negotiable. Client fees will be dependent on several factors, including time spent with All Source, the number of meetings, the complexity of client situation, amount of research, services requested, and resources. Consulting Services All Source will bill clients Consulting Services at a pre-determined fee based upon a percentage of the assets. The exact fee is negotiated in advance of services rendered and is disclosed in the executed written agreement that we sign with the client. Fees will be billed quarterly in advance. In special circumstances, other fee-paying arrangements are negotiated. Termination Provisions A client may terminate advisory services obtained from All Source, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with All Source. Thereafter, the client may terminate investment advisory services at any time with written notice to All Source or Integrated. Client will be responsible for any time spent by All Source. If fees were paid in advance, the client will be refunded a prorated portion of the advisory fee. Integrated Advisors Fee Disclosure The clients of All Source will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. All Source’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that All Source fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee-only basis, and no associated persons shall earn compensation based on a securities transaction (i.e., commission), including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisors selected by the Advisor may include mutual funds, variable annuity 7  products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. No-load or load-waived mutual funds may be used in client portfolios, so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Advisor is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Advisor does not act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to institutions, high net worth individuals, trusts, foundations, estates or charitable organizations, and corporations or other business entities directly. All Source Investment Management works primarily with accredited investors/qualified purchasers. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums The Advisor does not require an account minimum for clients. However, at its sole discretion, the Advisor may charge a lesser annual advisory fee based upon various factors, including, for example, anticipated future earning capacity, anticipated future assets, historical relationship, client investment experience, related accounts, account composition, negotiations with client, accounts referred to Advisor by another professional, etc. Other advisory groups of Integrated may or may not have any minimum size account. Clients will be required to sign investment advisory agreements (and/or other contractual arrangements) that, among other things, set forth the nature and scope of our investment advisory and management authority, specific services, and the investment objectives, guidelines, and restrictions applicable to the management of client accounts. 8  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include mean-variance optimization, charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor, which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive, and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staff. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. All Source’s Investment Activities. The Advisor’s investment activities involve an element of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness, or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor may invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor ’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and 9  competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies, or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed-income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flow from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds, or floating rate bonds, the Advisor is exposed to inflation risk because the interest rates the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to 10  political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor ’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor ’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of the Advisor ’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. 11  Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel, and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities, where there is a ready market that is traded through an exchange, are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in the price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Action All Source has not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. 12  Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations Some associated persons of Integrated are registered representatives of a broker dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated are not required to use the brokerage services offered by the registered representatives associated with Integrated. Integrated does not make any representation that the brokerage services are at the lowest cost available, and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated. Integrated mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated is committed to its obligation to ensure associated persons adhere to the firm’s Code of Ethics and to ensure that the firm and its associated persons fulfill their fiduciary duty to clients or investors. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade manes and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of All Source. Insurance Affiliations All Source and /or certain associated persons of All Source do not sell insurance products to advisory clients. Other IARs of Integrated sell insurance products. This does not affect the clients of All Source. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Advisor, managers, members, officers, and employees on the same day purchase or sell the same security, either the clients and the Advisor, managers, members, officers, or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Advisor and its managers, members, officers, and employees may also buy or 13  sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. The Advisor is not required to negotiate "execution-only" commission rates; thus, the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker, which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies, and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, databases, and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction, and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While we may recommend a certain custodian, the client will decide whether to do so and then the account will be opened with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. Selection of Custodian/Broker When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for 14  custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs 15  • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts, or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. 16  • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account, or fund as detailed in any written agreement. No additional compensation shall result from the proposed allocation. No client/investor, account, or fund will be favored over any other client/investor, account, or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts, or funds are required prior to any allocated order. The basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker, and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any possible commission discounts that might otherwise be available as a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker-dealers or third-parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances, a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct the Advisor to use a particular broker or dealer, which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms that do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts, which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, compliance and the associated IARs. Collectively, review client accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account, and the CCO also performs random reviews. 17  Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals, which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets, including cash, securities, acting as a trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfers to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Advisor submit instructions to the custodian to remit a specific dollar amount from the account to the designated third party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians, and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. 18  Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor has limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such a document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may, however, be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of businesses or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. All groups without discretionary authority will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting of Client Securities The Advisor will not vote nor advise clients on how to vote proxies for securities held in client accounts. The client keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to, and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client and six months or more in advance. 19 

Item 1 – Cover Sheet Sztrom Wealth Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 16054 Via Galan Rancho Santa Fe, CA 92091 (858) 395-8907 www.sztromwealth.com March 28, 2025 This brochure provides information about the qualifications and business practices of Sztrom Wealth Management, Inc. If you have any questions about the contents of this brochure, please contact us at (858) 252-0874, or by email at info@sztromwealth.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Sztrom Wealth Management Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Sztrom Wealth Management’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update Business Change of Location Effective 11/26/2024, Sztrom Wealth Management has moved its business location to 16054 Via Galan Rancho Santa Fe, CA 92091. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................3 Item 4 – Advisory Business .....................................................................................................................................4 Item 5 – Fees and Compensation .............................................................................................................................6 Item 6 – Performance Fees .......................................................................................................................................7 Item 7 – Types of Clients .........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................8 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 Item 12 – Brokerage Practices................................................................................................................................13 Item 13 – Review of Accounts ...............................................................................................................................17 Item 14 – Client Referrals and Other Compensation .............................................................................................17 Item 15 - Custody ...................................................................................................................................................18 Item 16 – Investment Discretion ............................................................................................................................18 Item 17 – Voting Client Securities .........................................................................................................................19 Item 18 – Financial Information .............................................................................................................................19 3  Item 4 – Advisory Business Firm Description Sztrom Wealth Management Inc is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser” or “Sztrom Wealth”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. The Firm do not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated does not act as a custodian of client assets and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Any conflicts of interest arising out of the Adviser’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Sztrom Wealth Management is a dba of Integrated Advisors Network, LLC. All advisory services are offered through Integrated Advisors Network, LLC. Michael Sztrom is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment policy statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives 4  change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Sztrom Wealth through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Sztrom Wealth Management is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client- imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITS”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Sztrom Wealth Management. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Sztrom Wealth Management may offer/manage a more active options strategy that is based on the fundamental and/or technical evaluation of each company to determine attractive prices to buy or sell options. Initial public offerings (IPOs) are not available through the Adviser. Financial Planning Sztrom Wealth through Integrated will typically provide a variety of financial planning services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning, charitable planning, education planning, and business planning. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Sztrom Wealth Management may also refer clients to an accountant, attorney, or other specialist. For planning engagements, Adviser will provide a summary of client’s financial situation, observations, and recommendations. For consulting engagements, Adviser may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Sztrom Wealth Management whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Sztrom Wealth Management or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Sztrom Wealth Management nor Integrated does not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services 5  at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Sztrom Wealth Management or use the services of Sztrom Wealth Management in particular. WRAP Program The Adviser does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. The Adviser’s Fee can range from .8% through 1.50%, depending upon the passive or active nature of the portfolio as follows: • Up to $999,999: 1.50% yearly • $1,000,000 - $4,999,999: 1.00% yearly • $5,000,0000 plus: 0.80% yearly Financial Planning Fees There are no charges for Financial Planning for clients. Fee Billing Investment management fees will be billed quarterly in advance. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Integrated Fee Disclosure The clients of Shields Capital Advisors will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Shields’ fees may be higher or lower than other advisory groups at Integrated and there is no representation that Shields fees are the lowest available for similar services. 6  Other Fees The client will likely incur additional fees from brokerages, custodians, administrators and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases, there may be fees charged which are a result of brokered trading activity by associated personnel of the Adviser that is outside of the constructs of the Adviser’s investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client the fees may vary in size depending on the nature of the client’s requests. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. 7  There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Sztrom Wealth Management’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The 8  Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data, and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available. The Adviser is not in a position to confirm the completeness, genuineness, or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls, and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs, policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies, or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. 9  Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5 -year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly and, slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards. There may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or 10  to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments, and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. 11  Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information Integrated is required to disclose information regarding any legal or disciplinary events material to a client’s evaluation of Michael Sztrom and David Sztrom. Michael and David Sztrom have a disciplinary history that requires disclosure pursuant to this item, the details which can be found on the SEC’s website at www.adviserinfo.sec.gov by searching Michael Sztrom and CRD #3042821 and David Sztrom and CRD #5978581. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Sztrom Wealth. Insurance Affiliations Sztrom Wealth Management and/or certain associated persons of Sztrom Wealth Management may sell insurance products to advisory clients. The clients who purchase insurance- r e l a t e d products are informed that Sztrom Wealth Management or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that Sztrom Wealth Management and/or the associated persons may sell insurance products to clients of Sztrom Wealth Management and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. Sztrom Wealth Management makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from Sztrom Wealth Management or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Sztrom Wealth. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients, applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report 12  their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being, or has been purchased or sold by the Adviser on behalf of any client, or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Adviser or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark -ups or mark- downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. 13  Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that 14  of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated 15  transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker, and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage, but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the 16  client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms th at permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm and its registered Investment Adviser Representatives who review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. 17  Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. 18  Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet JC Investment Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 1100 Lake Street, Ste 210G Oak Park, IL 60301 708-948-7092 March 28, 2025 the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler This Brochure provides information about the qualifications and business practices of JC Investment Management. If you have any questions about the contents of this Brochure, please contact us at 708-948-7092. Alternatively, contact at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo@sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to JC Investment Management Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. JC Investment Management’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on March 27, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ............................................................................................................................................... 1 Item 2 – Material Changes ....................................................................................................................................... 2 Item 4 – Advisory Business ..................................................................................................................................... 4 Item 5 – Fees and Compensation ............................................................................................................................. 5 Item 6 – Performance Fees ...................................................................................................................................... 6 Item 7 – Types of Clients ......................................................................................................................................... 6 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................. 7 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 ........................ 13 Item 12 – Brokerage Practices ............................................................................................................................... 13 Item 13 – Review of Accounts .............................................................................................................................. 17 Item 14 – Client Referrals and Other Compensation ............................................................................................. 18 Item 15 - Custody .................................................................................................................................................. 18 Item 16 – Investment Discretion ............................................................................................................................ 19 Item 17 – Voting Client Securities ........................................................................................................................ 19 Item 18 – Financial Information ............................................................................................................................ 19 3  Item 4 – Advisory Business Description of the Advisory Firm JC Investment Management is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser” or “JC Investment”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides personalized investment advice to individuals and small businesses. The Adviser also offers financial planning as a free and complementary service to all investment management clients. The Adviser nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Principal Owners of Integrated Advisors Network, LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser through Integrated will provide ongoing portfolio management services based on the risk profile of the client. The risk profile includes the client’s investment objectives, time horizon and risk tolerance. Investment portfolios are customized to meet the needs of each client. The investment process works through the client completing a client questionnaire and working with the Adviser to determine targeted portfolio constraints. Portfolio constraints provide a range of investment that can take place in the four asset classes considered by the Adviser. These are equities, fixed income, commodities, and cash. At times, the Adviser may override the constraints of the portfolio. The investment vehicles used to provide exposure to equities, fixed income and commodities will consist of a combination of index funds (both exchange traded funds and passively managed mutual funds), actively managed mutual funds and common stocks. For diversification purposes, the Adviser prefers to use index funds (over actively managed mutual funds) due to their transparency and cost benefits. However, there are certain times when actively managed mutual funds will be used within client accounts. The weight of each vehicle within the context of the client’s overall portfolio will depend on several factors including, but not limited to, the size of the investment, client risk profile, and other factors such as the cost basis of positions that are transferred from a previous broker. Money market funds will be the main investment vehicles used to provide exposure to the fourth asset class, cash. Financial Planning Services The Adviser will typically provide a variety of financial planning to individuals, families and other clients based on an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning will involve preparing a financial plan or rendering a financial consultation for clients. The economic scenario created by the Adviser relies on many key assumptions. Assumptions such as projected annual increase in salary or annual savings rate are provided by the client. The Adviser does not assume any responsibility for the accuracy of the information provided by the client and is not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant or other such professional). Under all circumstances, clients are 4  responsible for promptly notifying the Adviser in writing of any material changes to the client’s financial and investment objectives, taxability, time horizon, or risk tolerance. Other key assumptions, such as projected increase in annual expenses or annual investment earnings yield, are created by the Adviser. The Adviser will not provide estate planning and insurance planning services. The Adviser’s financial planning service is made available to all clients at no cost regardless of the client’s investment account balance or net worth. Wrap Fee Programs The Adviser does not participate in wrap fee programs. Other IARs under other group names at Integrated do offer wrap programs. Client Tailored Services and Client Imposed Restrictions Advisory services are tailored to achieve the investment objectives of individual Clients. Generally, the Adviser has the authority to select which and how many securities and other instruments to buy or sell without consultation with the Clients or their Investors. Clients may impose restrictions on investing in certain securities or types of securities. Clients may also request final approval of the purchase and/or sale of any security in their account. Amounts Under Management As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Chris Lynn is an Investment Adviser Representative (“IAR”) of Integrated Advisers Network. Item 5 – Fees and Compensation Fee Schedule The fees and compensation payable to the Adviser are negotiable and vary among its clients. However, the range of compensation is generally as follows: Management Fee Client will pay the Adviser a fee for its investment advisory services. The specific manner in which fees are charged by the Adviser is established in a client’s written agreement with the Adviser. The fee will be calculated on a quarterly basis and collected in advance. There is a tiered structure with a maximum of 0.95%. The tiered rate is calculated based on the total Household balances under the Adviser’s management at the end of the previous quarter. The tiered rate structure is as follows: • 0.95% of the first $1,000,000 • 0.90% of the amount between $1,000,000 and $3,000,000 • 0.85% of the amount between $3,000,000 and $5,000,000 • 0.5% of the amount above $5,000,000 The fee will be calculated in the same manner for all clients; however, the fee is negotiable. Upon termination of the Investment Advisory Agreement, the Adviser shall refund any of the unused portion. The client has the right to terminate the contract without penalty within five (5) business days after entering into the Investment Advisory Agreement with the Adviser. After the five (5) business days, the client may terminate the Investment Advisory 5  Agreement at any time by giving written notice to the advisor. The Adviser may terminate the Agreement at any time by giving the client at least 30 days written notice. The Adviser does not receive compensation for the purchase or the sale of securities or other investment products. The Adviser’s fee is exclusive of commissions, transaction fees, and other related costs and expenses in connection with trading and custody. These fees and expenses shall be incurred by the client. Additionally, clients may incur certain charges imposed by mutual fund and exchange traded funds such as internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to the Adviser’s fee, and the Adviser shall not receive any portion of these commissions, fees, and costs. Integrated Fee Disclosure The clients of JC Investment will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. JC Investment’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that JC Investment’s fees are the lowest available for similar services. Performance Fee The Adviser does not charge a performance-based fee (fees based on a share of capital gains on or capital appreciation of the assets of a client). Fee Billing Investment management fees are deducted quarterly in advance. Account values are based upon pricing information supplied by the client’s 3rd party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the Investment Advisory Agreement. Item 6 – Performance Fees The Adviser does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients The Adviser provides portfolio management services to individuals, high net worth individuals, trusts, corporate and small business profit-sharing plans, and plan participants of corporate and small business retirement plans. There are no account minimum sizes. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. 6  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investment Strategy The Adviser first ascertains the client’s risk profile—age, investment objectives, time horizon, risk tolerance and liquidity needs. The investment strategy undertaken by the Adviser is to create and monitor an investment portfolio that is consistent with the risk profile of each client. The Adviser normally considers four asset classes for the investment of client funds—equities, fixed income, commodities, and cash. For each asset class, the following are the primary investment vehicles: • Equities—primarily index funds (exchange traded funds and passively managed mutual funds) and common stocks. At times, the Adviser will invest in actively managed mutual funds, too. • Fixed Income—primarily index funds and actively managed mutual funds. • Commodities—primarily index funds and actively managed mutual funds. • Cash—primarily money market funds and CDs. Based on the client’s risk profile, the Adviser creates portfolio constraints for each client. Portfolio constraints provide a general range (the minimum to the maximum) of investment that can take place in the four asset classes that are considered by the Adviser. The weight of each investment vehicle within the context of the client’s overall portfolio will depend on several factors including, but not limited to, the size of the investment, client risk profile (risk tolerance, investment objectives, time horizon, etc.), and other factors such as the cost basis of positions that are transferred from a previous broker. The Adviser generally follows these risk management guidelines: • Adhere, with exceptions, to portfolio constraints set for each client; • Limit individual securities (investment in common stocks) to no more than 8% of overall portfolio (with exceptions for certain clients); • Raise cash levels in declining and volatile equity markets; and • 25-100% of portfolio in index or actively managed mutual funds Methods of Analysis Analytical methods vary with the type of investment vehicle. Index fund analysis includes type of exposure provided, assessment of expenses and liquidity-related issues. Actively managed mutual fund analysis includes assessment of expenses, fund manager tenure and historic performance against peers, long-term fund performance, and review of other independent reviewers while bearing in mind that past performance is no guarantee of future results. Common stocks are evaluated using fundamental analysis techniques as well as review of third-party research. Investment in any security always involves risk of loss that clients should be prepared to bear. Market fluctuations, interest rates, inflation, economic downturns, and individual business performance are some of the possible exposures. The Adviser will do its best to tailor the portfolio so that it meets both the client’s return expectations and risk tolerance, but this is not guaranteed. In addition, the client’s return expectations are subject to the realities of the financial markets and dependent on the risk the client is willing to assume. While the Adviser’s investment strategy is designed to mitigate exposure to various risks, the client needs to understand that the risks are there and to be prepared to bear losses that may result. At any point in time, a client’s investments will be worth more or less than originally invested. Here is some more on principal investment risks: 7  Stock Market Volatility. The value of equity securities fluctuates in response to issuer, political, market, and economic developments. Fluctuations can be dramatic over the short as well as long term, and different parts of the market and different types of equity securities can react differently to these developments. Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in the financial condition of a single issuer can impact the market as a whole. Terrorism and related geo-political risks have led, and may in the future lead, to increased short-term market volatility and may have adverse long-term effects on world economies and markets generally. Interest Rate Changes. Debt securities have varying levels of sensitivity to changes in interest rates. In general, the price of a debt security can fall when interest rates rise and can rise when interest rates fall. Securities with longer maturities and mortgage securities can be more sensitive to interest rate changes. Foreign Exposure. Foreign securities, foreign currencies, and securities issued by U.S. entities with substantial foreign operations can involve additional risks relating to political, economic, or regulatory conditions in foreign countries. These risks include fluctuations in foreign currencies; withholding or other taxes; trading, settlement, custodial, and other operational risks; and the less stringent investor protection and disclosure standards of some foreign markets. All of these factors can make foreign investments, especially those in emerging markets, more volatile and potentially less liquid than U.S. investments. In addition, foreign markets can perform differently from the U.S. market. In response to market, economic, political, or other conditions, the Adviser may temporarily use a different investment strategy for defensive purposes. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire 8  confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by 9  investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s 10  investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor 11  to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partner (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information Mr. Lynn has not been subject to any disciplinary events. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of Integrated. The IARs are 12  under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of JC Investment. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer reviews employee trades each quarter. The personal trading reviews ensure that the personal trading of employees does not affect the markets, and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies, or sectors; market, financial and economic studies, and forecasts; financial publications; statistical and pricing services, as well as 13  discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction, and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client will decide whether to do so and will open your account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. 14  Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. 15  The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts, or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account, or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be 16  precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage, but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client’s financial or personal situation. Regular Reports Clients receive statements from custodian and reports from the advisor. The statements from the custodian should be available on a monthly basis and include portfolio holdings, associated market values, monthly account activity and month-end account balance. Additionally, the custodian produces trade confirmations as transactions occur. Reports from the Adviser are sent on a periodic basis and address such topics as the Adviser’s investment strategies, views of the current and historical market, and economic conditions. 17  Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. 18  Item 16 – Investment Discretion The Adviser contracts for discretionary authority to transact portfolio securities accounts on behalf of clients with no specific limitations as to type, amount, concentration, or leverage. Further, the Adviser may enter into any type of investment transaction and employ any investment methodology or strategy it deems appropriate. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to, and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet Vineyard Global Advisors, LLC Form ADV Part 2A - Firm Brochure (CRD #171991 / SEC #801-96203) 9800 Mt. Pyramid Ct. Suite 400 Englewood, CO 80112 Telephone: 303-814-6818 www.vineyardglobaladvisors.com March 28, 2025 Officer of Integrated Advisors Network at 855-729-4222 This Form ADV Part 2A, Appendix 1, Wrap Fee Program brochure (“brochure”) provides information about the qualifications and business practices of Vineyard Global Advisors, LLC, a DBA of Integrated Advisors Network, an investment adviser registered with the United States Securities and Exchange Commission ("SEC"). If you have questions about this Brochure's contents, please contact Tom R. Samuelson, Chief Investment Officer of Vineyard Global Advisors, LLC, at 720-470-3252 or tom@vineyardglobaladvisors.com or Danielle L. Tyler, Chief Compliance or compliance@integratedadvisorsnetwork.com. The information in this Brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Please note that registration as an investment adviser does not imply a certain level of skill or training. An adviser's written and oral communications provide information to determine whether to retain the adviser's services. This Brochure is on file with the appropriate regulatory authorities as Federal and state regulations require. Additional information about Vineyard Global Advisors, LLC and Integrated Advisors Network, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in our firm name or CRD #171991. Results will provide you with all firm disclosure brochures.) 1  Item 2 – Material Changes In this item, Vineyard Global Advisors, LLC is required to summarize only those material changes made to this Brochure since the Adviser’s last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since the last annual updating amendment of March 27, 2024, changes have been made to the following Brochure sections: There have been no material changes since the last annual updating amendment. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients - either by electronic means or hard copy with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at www.adviserinfo.sec.gov by searching either our name or CRD #171991. The SEC's website also provides information about any advisory-affiliated person registered or required to be registered as an Investment Adviser Representative of the firm. You may also request a copy free of charge by contacting us directly at the number(s) located on this Brochure's cover page. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Services, Fees and Compensation ................................................................................................................4 Item 5 – Account Requirements and Types of Clients ...............................................................................................8 Item 6 – Portfolio Manager Selection and Evaluation................................................................................................8 Item 7 – Client Information Provided to Portfolio Managers ...................................................................................16 Item 8 – Client Contact with Portfolio Managers .....................................................................................................17 Item 9 – Additional Information ...............................................................................................................................17 3  Item 4 – Services, Fees and Compensation The Vineyard Global Advisors Managed Advisory Program (“VGA MAP” or the “Program”) is an investment advisory program sponsored and administered by Vineyard Global Advisors, a dba of Integrated Advisors Network LLC (“Integrated”) The Program provides clients with the ability to pay a single fee for the management, brokerage, custody and other services provided under the Program. Vineyard Global Advisors, a dba of Integrated Advisors Network LLC is a registered investment adviser. All accounts participating in the Program are held with a Qualified Custodian (such as Charles Schwab, Fidelity, etc.), who are unaffiliated broker-dealer. The Qualified Custodian maintains custody of the client’s funds and securities; collects interest and dividends; and performs the normal and customary execution and custodial services. The Qualified Custodian will send clients confirmation of each transaction in their VGA MAP account(s) and will send account statements reflecting activity in the client’s VGA MAP account at least quarterly. To join the Program, a client must (1) complete an investor profile that describes the client’s financial needs, investment objectives, time horizon, and risk tolerance, as well as any other factors relevant to the client’s specific financial situation and any other supporting documentation the Program requires; (2) execute the investment advisory WRAP fee agreement (the “Agreement”) with the Adviser; (3) complete a new account agreement with the approved Qualified Custodian that participates in the Program; and (4) open a securities brokerage account with the approved Qualified Custodian and deposit those assets designated for participation in the Program into the account. Account Services The Adviser’s investment advisor representatives (“IARs”) provide investment portfolio advice and supervisory services to clients based on an individual’s financial information, goals and objectives. This investment advice varies depending upon a client’s individual life situation, desires, objectives, and other preferences. IARs use the information initially provided in the investment profile to assist the client in developing an appropriate investment strategy for the assets in his or her account(s). Thereafter, all clients are encouraged to discuss their needs, goals, and objectives with their IAR and to notify the Adviser of any changes. The Adviser requires its IARs to contact clients at least annually to review previous services and/or recommendations and to determine whether changes should be made to the client’s investment strategy. Clients will authorize the Adviser to have trading authorization on their account and the Adviser’s IARs will provide asset management services. Clients will authorize either discretionary or non-discretionary management in the Agreement for the Program. If a Client authorizes the Adviser to provide asset management services on a discretionary basis, the IAR will make all decisions to buy, sell or hold securities, cash, or other investments in the client’s managed account in the IAR’s sole discretion without consulting with the client before making any transactions. Clients must provide written authorization to exercise this discretionary authority. Clients cannot place any restrictions and limitations on the Adviser’s discretionary authority. The Adviser is the manager and program sponsor to the Vineyard Global Advisors Managed Advisory Program (VGA MAP), whereby client accounts are managed for a calculated fee, subject to a fee minimum, that includes both management services and securities transaction/commission costs. VGA MAP is offered to prospective and existing advisory clients is designed to make asset management services available to clients for a convenient single "WRAP fee". Depending upon the number of transactions executed in the client’s account, the overall cost the client will incur if they participate in the WRAP fee program may be higher or lower than they might incur by separately purchasing the types of securities available in VGA MAP. Prior to becoming a client under VGA MAP, the client will be required to enter into a separate written agreement with the Adviser that sets forth the terms and conditions of the engagement and describes the scope of the services to be provided, and the fees to be paid. 4  VGA also has entered into written agreements with certain unaffiliated third party investment advisers to serve as a sub-adviser and provide investment management services to the third party advisers’ clients. Under these sub- advisory arrangements, each third party investment adviser is responsible for working with its clients to select the appropriate strategy for investment. VGA manages the clients’ designated assets based on the respective selected investment strategy. Model Portfolio Investment Selection and Portfolio Management The client’s investment adviser representative (“IAR”) will assist clients in clarifying their investment needs, including but not limited to investment objectives, tolerance for risk, and investment time horizon, and provide professional advice. In an effort to assist the client in achieving his or her investment goals, the IAR will work with the client in selecting the appropriate asset manager(s) and/or strategy(ies) based on such factors as the manager’s selected risk adjusted returns and the client’s suitability needs. The client’s Agreement will document the manager(s) and strategies selected by the client. The asset manager(s) will provide investment management of each client’s funds on a discretionary basis through the client’s VGA MAP account. This written discretionary authority will be granted through limited Trading Authorization as detailed in the Agreement. Asset managers available through the VGA MAP will offer various model portfolios under this program. The model portfolios will include investments in, but not limited to, stocks, bonds, ETFs and mutual funds. The client has ability to withdraw securities or cash; vote securities; receive a written confirmation or other notification of each securities transaction and all other documents required by law to be provided to security holder; and proceed directly as a security holder against the issuer of any security in the client's account. The client can also impose reasonable restrictions on the management of the client's account, including the designation of particular securities or types of securities that should not be purchased for the account, or that should be sold if held in the account. Performance Evaluation and Monitoring Services The asset manager(s) for the client’s account will monitor, rebalance, and manage all of the changes to the client’s VGA MAP account. The Adviser will furnish quarterly performance measurement reports to its clients. These reports are intended to inform clients as to how their investments have performed during the selected period. Clients will also receive account statements from the Qualified Custodian at least quarterly, detailing all of the activity in the client’s account, including the amount of advisory fees paid directly to the Adviser. Information contained in the performance reports is believed to be accurate, however, the accuracy and completeness of the information is not guaranteed, and is not intended to replace the account statements clients receive from the Qualified Custodian. The statements clients receive from the Qualified Custodian should be considered the official record for all pertinent account information. Clients should compare the information contained in the Qualified Custodian’s account statement with the Adviser’s performance reports. Clients should promptly convey any discrepancies to their IAR or the Adviser’s home office. Clients should also notify the Adviser if they do not receive the account statements from The Qualified Custodian on at least a quarterly basis. Calculations and data provided on the performance reports should not be relied upon for tax purposes, but rather clients should use the original transaction confirmations and 1099s instead. Changes in Your Financial Circumstances The Adviser’s IARs make investment decisions for a client’s portfolio on a discretionary basis according to the client’s stated objectives, financial circumstances, and risk tolerance. The Adviser is not required to verify any information it receives from clients or from a client’s other professionals (e.g. attorney, accountant, etc.) and the Adviser is expressly authorized to rely on the information clients provide. Clients must promptly notify the Adviser of any change in financial circumstances or investment objectives that might affect the manner in which a client’s account(s) should be managed. 5  Program Fees The Adviser charges a single asset-based fee for advisory services, which includes the cost of portfolio management services, custodial services and the execution of securities transactions. The fee will be assessed and billed quarterly in advance. The fee for any given calendar quarter is debited by the custodian from the client’s account at the beginning of the calendar quarter, based on the total portfolio value as of the last business day of the preceding calendar quarter. Clients will receive a debit notice showing the fee for that quarter and how it was calculated. The first fee will be billed upon execution of the Agreement and will be based upon the opening value of the account. If the Agreement is executed at any time other than the first day of a calendar quarter, the payment will be prorated. The Adviser provides investment management services for an annual fee based on the amount of assets under management (portfolio value). The fee varies between 0.35% and 1.00%, based on the following tiered fee schedules: VGA ETF Advantage Series, VGA Allocation Plus Series, VGA Global Fixed Income Account Size Program Fee Up to $500,000 0.50% $500,000 - $1,000,000 0.45% $1,000,000 - $5,000,000 0.40% Over $5,000,000 0.35% VGA Advantage Plus, VGA R3000 Enhanced Dividend, VGA Enhanced S&P 500, VGA Dynamic Yield, VGA Covered Call, VGA Private Client Service, VGA Risk Managed Income, VGA Quantitative Value, VGA Quantitative Growth, VGA Sector Rotation, VGA Equity Style Flex, VGA Optimized Equity Alpha Account Size Up to $500,000 $500,000 - $1,000,000 $1,000,000 - $5,000,000 Over $5,000,000 Program Fee 0.75% 0.70% 0.65% 0.60% SpiderRock Proprietary Model Fees Proprietary Model SpiderRock Qualified Solutions – Conservative (SRQSC) SpiderRock Qualified Solutions – Moderate (SRQSM) SpiderRock Qualified Solutions – Growth (SRQSG) SpiderRock Hedged Equity Concentrated Stock (SRHEC) SpiderRock Hedged Equity Portfolio SpiderRock Cash Security Put (SRCSP) SpiderRock Structured Downside Protection (SRSDP) SRA Annual Fee 0.40% AUM 0.40% AUM 0.40% AUM 0.50% AUM 0.50% AUM 0.50% AUM 0.50% AUM 6  SpiderRock S&P CBOE BXM Replication SpiderRock S&P CBOE PUT Replication SpiderRock Negative Duration Equity (SRNDE) SpiderRock Structured Note Replication (SRSNR) SpiderRock Managed Index Income (SRMII) SpiderRock Opportunistic Yield Enhancement (SROYE) SpiderRock Exchange Fund Replication (SREFR) 0.50% AUM 0.50% AUM 0.60% AUM 0.60% AUM 0.60% AUM 0.70% AUM 0.85% AUM VGA Custom Covered Call The program fee is 1.00% for all account sizes. The Adviser may negotiate to charge a lesser fee based upon certain criteria such as size, type, and complexity of account; related accounts; anticipated changes in accounts; among other factors. Fee Comparison A portion of the fees paid to the Adviser are used to cover the securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios, the financial advice offered by the Adviser through the client’s selected IAR, as well as the fees charged by the asset managers engaged to provide services under the Program. The asset managers servicing accounts through the Program receive a fee based upon the assets under their management. Services provided through the Program may cost clients more or less than purchasing these services separately. The number of transactions made in a client’s account(s), as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Fees paid for the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs. As the Adviser absorbs certain transaction costs in WRAP fee accounts, the Adviser may have a financial incentive not to place transaction orders in those accounts since doing so increases its transaction costs. Thus, an incentive exists to place trades less frequently in a WRAP fee arrangement. Additions, Withdrawals and Terminations Clients may make additions to and withdrawals from their account at any time in cash or securities. The Adviser reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients must notify the Adviser upon withdrawing assets from their account. The Adviser advises clients that (1) when the Adviser liquidates transferred securities, they may be subject to additional fees such as transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications and (2) withdrawals are subject to the usual and customary securities settlement procedures. If the client terminates his or her account during any billing period, the Adviser will refund the client’s account any pre-paid advisory fees on a pro-rata basis from the date of termination to the end of the billing period. For amounts withdrawn from an existing account during the quarter, any pre-paid advisory fee for those assets will be refunded on a pro-rata basis from the date of the withdrawal to the end of the billing period, and credited to the account during the next billing cycle. Additionally, if the client transfers his or her account to another firm, the client may pay an outgoing account transfer fee. Integrated Fee Disclosure The clients of Vineyard Global Advisors will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may 7  vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Abundantia’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Abundantia fees are the lowest available for similar services. Other Charges There may be other costs assessed by third parties and/or the Adviser, which are not included in the Program Fee. For example, there may be charges imposed directly by a mutual fund or exchange-traded fund in the account (e.g. fund management fees and other fund expenses as disclosed in the prospectus), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, annual check writing and debit card fees, check stop payment fees, returned check fees, ACH return fees, security transfer and redemption fees, reorganization processing fees, trade confirmation fees, outgoing account transfer fees, margin extension fees, margin debit interest, IRA annual maintenance fees, IRA termination fees, amounts charged to produce year-end statements and account reports, and other fees and taxes on brokerage accounts and securities transactions and fees for trades executed away from custodian. Clients may obtain a schedule of these additional fees by contacting their IAR or the Adviser. Compensation The Adviser’s IARs receive a portion of the advisory fee that clients pay to the Adviser as a percentage of the client’s overall advisory fee. This creates an incentive for IARs to recommend that clients participate in a WRAP fee program rather than a non-WRAP fee program (where clients pay for trade execution costs) or brokerage account where commissions are charged. In some cases, the Adviser may stand to earn more compensation from advisory fees paid to the Adviser through a WRAP fee program arrangement if a client’s account is not actively traded. In addition, the Adviser may have arrangements in place with other management personnel and/or affiliates through which profits are split per agreed upon terms. Item 5 – Account Requirements and Types of Clients The Adviser generally provides investment advice to individuals, high net worth individuals, pension and profit sharing plans, trusts, estates, or charitable organizations, and corporations or business entities. Client relationships vary in scope and length of service. Minimum Account Size The Adviser requires a minimum account size of $50,000 for portfolio asset management. Exceptions may be made, solely at the Adviser’s discretion, based on a variety of factors, including but not limited to, prior or anticipated investment activity and family or employment relationships. The Adviser may, at its discretion, aggregate related accounts in the same household in determining whether the account minimum has been met. Minimums may be negotiated depending on a client’s personal circumstances. Item 6 – Portfolio Manager Selection and Evaluation Selecting and Reviewing Portfolio Managers The Adviser acts as the sponsor and portfolio manager under the Program. Clients’ investment portfolios are managed either directly by the Adviser or through the use of certain asset managers (see above). The Adviser uses a detailed due diligence process to evaluate and approve asset managers for the VGA MAP. Factors influencing selection of an asset manager include, but are not limited to, accessibility; ability to customize, knowledge of products currently offered, tenure, relative cost, education, and knowledge of general economic and market factors 8  and other criteria. The Adviser also reviews performance numbers provided the asset managers and other third- party reporting sources in its evaluation process. The Adviser will offer the investment management services of numerous professional asset managers. The Adviser continues to monitor the performance of all asset managers participating in the Program to make certain they are continually providing the performance and value for which they were selected. The Adviser seeks to ensure the asset managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The Adviser may eliminate an asset manager who is under-performing from the platform at its. In the event that an asset manager needs to be replaced, the Adviser has the sole discretion to hire a new asset manager and adjust the weighting of the allocation accordingly. Related Persons as Portfolio Managers The Adviser and its related persons act as portfolio manager(s) for the WRAP fee program(s) previously described in this WRAP Fee Program Brochure. This creates a conflict of interest in that portfolio managers could place their own or the Adviser's interests before a client’s interest. The Adviser has adopted Compliance Procedures and a Code of Ethics that requires the Adviser’s portfolio managers and other employees of the Adviser to adhere to their fiduciary duty and avoid activities, interests and relationships that run contrary (or appear to run contrary) to the best interests of clients. The Adviser uses the same detailed due diligence process described above to evaluate and approve related portfolio asset managers for the VGA MAP as it does for outside managers. Advisory Business Vineyard Global Advisors LLC is a DBA of Integrated Advisors Network, an investment advisor registered with the Securities and Exchange Commission ("SEC") pursuant to the Investment Advisers Act of 1940 (the "Advisers Act") (collectively and hereafter referred to as "VGA" or "the Adviser”). Integrated, organized as a limited liability company in 2014, has been SEC-registered since May 11, 2015. The Adviser is a fee-only investment management firm. The Adviser provides personalized investment advice primarily to other investment advisers or Investment Adviser Representatives. However, occasionally the Adviser will work with to individuals, high net worth individuals, pension and profit sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. The Adviser does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Adviser is not affiliated with entities that sell financial products or securities. The Adviser does not act as a custodian of client assets and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. The Adviser acts as a sponsor and does provide investment advice to a WRAP program through Integrated Advisors Network LLC. The goals and objectives for each client are documented in our client relationship management system, Investment Policy Statements, and/or Investor Questionnaires. Clients may impose restrictions on investing in certain securities or types of securities. Performance-Based Fees and Side-by-Side Management The Adviser does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Methods of Analysis, Investment Strategies and Risk of Loss Security analysis methods may include charting, fundamental analysis, technical analysis and cyclical analysis. Strategies may include long-term purchases, short-term purchases, trading, short sales, margin transactions, and option writing (including covered options, uncovered options or spreading strategies). 9  Each IAR may use a different investment methodology when managing client assets based upon the objectives stated by the client. The Adviser does not represent, warrant, or imply that the services or methods of analysis used by the Adviser can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections, crashes, or extraordinary events. The Adviser cannot assure clients’ goals or objectives will be achieved or its advisory services will provide a better return than other investment strategies. Investing in securities involves risk of loss that clients should be prepared to bear. Past performances of any recommended managers or funds or securities, or the success of a manager is no guarantee of future success. There can be no assurance that clients will not incur losses. The following risk factors are not intended to be a full or complete listing of all the risks involved in investing, and clients should engage in their own evaluation of such risks. Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, the face value on existing bonds becomes less attractive, causing their market values to decline. Similarly, equities may also suffer from a rising interest rates. Therefore, in real terms, client portfolios may not keep up with the rate of inflation. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events that may cause prices to fall. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. 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. Investments made in foreign countries may depreciate if the corresponding value of the country’s currency goes down. 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 carry a higher risk of potential 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. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many individuals are interested in buying or selling a standard asset or product. For example, Treasury Bills are highly liquid, while real estate properties are not. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. 10  VGA MAP currently includes the following asset management strategies: VGA ETF Advantage Series The VGA ETF Advantage series are a group of managed asset allocation strategies offered by Vineyard Global Advisors (VGA) that utilize exchange traded funds (ETF’s) in five custom market models that range from capital preservation (10% equity - 90% fixed income) to aggressive growth (90% equity - 10% fixed income). The models are offered in both tax-sensitive and qualified versions. The strategies provide exposure to nine different asset classes that include US equities, foreign developed equities, emerging market equities, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management while additional downside protection is provided by tactical asset class adjustments and the use of opportunistic hedge positions based on input from our macro models. Exchange Traded Funds offer low operating costs, tax efficiency and low minimum investment entry levels, making the ETF Advantage strategy available to lower account sizes (minimum $10,000). VGA Allocation Plus Series The VGA Allocation Plus series are a group of managed asset allocation strategies offered by Vineyard Global Advisors (VGA) that utilize mutual funds and exchange traded funds (ETF’s) in five custom market models that range from capital preservation (10% equity - 90% fixed income) to aggressive growth (90% equity - 10% fixed income). The models are offered in both tax-sensitive and qualified versions. Actively-managed mutual funds are selected through proprietary research designed to identify those managers that have been able to consistently offer returns above their respective asset categories (manager “alpha”). In asset categories where little additional alpha can be obtained through active management, that category is sourced with a passive ETF. The strategies provide exposure to nine different asset classes that include US equities, foreign developed equities, emerging market equites, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management while additional downside protection is provided by tactical asset class adjustments and opportunistic hedge positions based on input from our macro models. Several of the mutual funds require higher minimum initial investment levels, making this strategy available for account sizes of $100,000+. VGA Advantage Plus Series The VGA Advantage Plus Series are a group of managed asset allocation strategies offered by Vineyard Global Advisors (VGA) that utilize mutual funds, exchange traded funds (ETF’s) and internal proprietary investment strategies in five custom market models that range from capital preservation (10% equity - 90% fixed income) to aggressive growth (90% equity - 10% fixed income). The Allocation Advantage Plus strategy is offered in a unified managed account (UMA) format, which is a sophisticated design that combines multiple investment vehicles into a single portfolio account, maximizing efforts to enhance diversification. The models are offered in both tax- sensitive and qualified versions. The strategy utilizes both VGA-actively managed strategies and mutual funds that have been selected through proprietary research designed to identify managers that have been able to consistently offer returns above their respective asset categories (manager “alpha”). The internal strategies and mutual funds are included in an effort to maximize risk-adjusted returns. In asset categories where active management has provided minimal alpha, that category is sourced with a passive ETF. The strategies provide exposure to nine different asset classes that include US equities, foreign developed equities, emerging market equities, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management while additional downside protection is provided by tactical asset class adjustments and opportunistic hedge positions based on input from our macro models. Several mutual funds and the internal strategies require higher minimum investment levels, making this strategy available for account sizes of $500,000+. 11  VGA R3000 Enhanced Dividend The VGA R3000 Enhanced Dividend strategy is a proprietary strategy managed by VGA that invests primarily in dividend-paying US stocks that are selected through a proprietary screening process developed to identify companies that may offer above-average total return potential, with a primary focus on income. The strategy may also invest in income producing American Depository Receipts (“ADRs”), Exchange Traded Funds (“ETFs”), and Closed-End Funds (“CEFs”). The strategy deploys a risk-managed approach whereby equity exposure is reduced when our macro models determine the investment backdrop has deteriorated. Equity exposure can range from between 25% net long (during maximum negative market backdrops) to 125% net long (during maximum positive market backdrops). Minimum account size: $25,000. VGA Enhanced S&P 500 The VGA Enhanced S&P 500 strategy is a proprietary strategy managed by VGA that invests in S&P 500 stocks that are selected through a proprietary screening process developed to identify companies that may offer above- average total return potential. The strategy deploys a risk-managed approach whereby equity exposure is reduced when our macro models suggest the investment backdrop has deteriorated. Equity exposure can range from -5% net long (during maximum negative market backdrops) to 120% net long (during maximum positive market backdrops). VGA Enhanced S&P 500 seeks to outperform the S&P 500 index with a bias toward downside risk management. The strategy is designed to provide equity market participation during bullish phases as determined by our macro models while attempting to provide downside protection when our macro models suggest the equity market backdrop has deteriorated. Minimum account size: $25,000. VGA Global Fixed Income The VGA Global Fixed Income strategy is a proprietary fixed income allocation strategy managed by VGA that invests in fixed income Exchange Traded Funds (ETF’s), Closed-end Funds (“CEF’s”) and mutual funds. The strategy invests across 22 fixed income categories selected for their diversification attributes. The strategy is offered in both tax-sensitive and qualified versions. Risk management may be further enhanced through the use of ETF hedge positions, which can be included to manage interest rate and credit risk, depending upon input from our macro models. The VGA Global Fixed Income strategies are intended for investors with low risk tolerance and to provide portfolio diversification benefits when added to higher volatility equity allocations. Minimum account size: $10,000. VGA Dynamic Yield The VGA Dynamic Yield is an income-focused strategy that invests in U.S. dividend paying stocks, American Depository Receipts (“ADR’s), Closed-end mutual funds (“CEF’s”) and Open-end mutual funds. Its primary objective is to offer risk-managed income sourced through dividends, interest income and royalty payments. It seeks to achieve its objective by investing across a portfolio of approximately 65 positions that offers exposure to all the major, publicly-traded income producing asset categories. Risk management is achieved through: 1) broad diversification across asset classes, 2) dynamic adjustment of the equity and fixed income portions of the portfolio (based on input from our macro models) and, 3) the use of opportunistic ETF hedge positions to further address equity, credit and interest rate risk. Minimum account size: $25,000. VGA Covered Call VGA Covered Call is a proprietary separately managed account strategy that seeks attractive risk- adjusted returns through the purchase of a diversified equity portfolio and concurrent sale of call options which may provide partial downside protection plus the potential for auxiliary income generation. The portfolio consists of 16 - 35 individual covered call positions that are diversified by sector, strike price and expiration date. Individual stocks are systematically selected through proprietary screens and then scored using a multi- factor model that evaluates their attractiveness at time of purchase. Minimum account size: $150,000. 12  VGA Custom Covered Call The VGA Custom Covered Call strategy is offered on an account by account basis as a way for clients to generate auxiliary income on concentrated equity positions through the sale of call options. First, the client determines a level at which he/she is indifferent to selling the underlying stock position. Then, VGA deploys an opportunistic covered call writing program around the agreed upon exit price with an eye towards trading the calls for a profit should the overall stock market or that particular stock decline in value. Minimum account size: $1,000,000. VGA Optimized Equity Alpha VGA Optimized Equity Alpha is a strategy managed by VGA that invests in US-listed stocks and exchange traded funds (ETF’s), seeking to achieve its objective of long-term capital appreciation by combining a sector rotation strategy and a style preference strategy (growth vs. value). These two different approaches are combined into one strategy due to their diversification benefits. The strategy is designed to provide strong equity market participation during neutral to bullish investment backdrops (as determined by VGA’s proprietary macro models) with a focus on capital preservation during bearish investment backdrops. Equity exposure can range from 100% net long during maximum bullish backdrops to 0% during maximum bearish backdrops. Minimum account size: $150,000. VGA Private Client Services (“PCS”) The VGA Private Client Services (“PCS”) provides customized portfolio construction solutions to high net- worth clients (generally liquid net worth in excess of $1,000,000). Customized portfolios solutions are designed and implemented after consultation with an advisor that seeks to determine the appropriate allocation based on the client’s individualized investment objectives and/or financial plan. An open architecture environment is utilized that may invest across a broad array of stocks, bonds, exchange- traded funds, closed and open end mutual funds, proprietary internal strategies and alternative and structured investment products. VGA PCS is offered in a unified managed account (UMA) format, which is a sophisticated design that combines multiple investment vehicles into a single portfolio account, maximizing efforts to enhance diversification. Minimum account size: $1,000,000. VGA Risk Managed Income The VGA Dynamic Yield is an income-focused strategy that invests in U.S. dividend paying stocks, American Depository Receipts (“ADR’s), Closed-end mutual funds (“CEF’s”) and Open-end mutual funds. Its primary objective is to offer a low-volatility, risk-managed income solution sourced through dividends, interest income and royalty payments. Risk Management is achieved through: 1) constraining equity exposure to a maximum of 30% of the overall strategy, 2) dynamic adjustment of the equity and fixed income portions of the portfolio (based on input from our macro models) and, 3) the use of opportunistic ETF hedge positions to further address equity, credit and interest rate risk. Minimum account size: $25,000. VGA Quantitative Value The VGA Quantitative Value is a strategy managed by VGA that invests in a targeted portfolio of approximately 50 top-ranked stocks in the Russell 3000 Value index selected through a proprietary screening process designed to identify companies with above-average total return potential. The screening process seeks to identify companies with a unique blend of value, quality, profitability, growth, and price momentum attributes that have historically been associated with superior stock performance. The strategy is offered in two versions: long-only and hedged. The Long-only version remains at least 80% invested regardless of the market backdrop. The hedged version will scale overall portfolio equity exposure from 0% net long to 100% net long during maximum bearish to maximum bullish market backdrops, respectively. The strategy is rebalanced quarterly, although individual positions may be adjusted opportunistically. The minimum account size is $50,000. VGA Quantitative Growth VGA Quantitative Growth is a strategy managed by VGA that invests in a targeted portfolio of approximately 50 top-ranked stocks in the Russell 3000 Growth index selected through a proprietary screening process designed to identify companies with above-average total return potential, utilizing a "growth at a reasonable price" or GARP 13  methodology. The screening process seeks to identify companies with a unique blend of earnings growth, earnings momentum, earnings consistency, valuation and price momentum attributes that have historically been associated with superior stock performance. The strategy is offered in two versions: long-only and hedged. The long-only version remains at least 80% invested regardless of the market backdrop. The hedged version will scale overall portfolio equity exposure from 0% net long to 100% net long during maximum bearish to maximum bullish market backdrops, respectively. The strategy is rebalanced quarterly, although individual positions may be adjusted opportunistically. Minimum account size: $50,000. VGA Sector Rotation VGA Sector Rotation is a strategy managed by VGA that invests in an equity portfolio of S&P 500 sector exchange traded funds (ETF’s) based upon their total return potential, as determined by VGA’s proprietary ranking models. Top-ranked sectors determined will receive a higher portfolio weight and bottom-ranked sectors determined will receive a lower weight (or are held in cash). The strategy is offered in two versions: long-only and hedged. The long-only version will hold cash in sectors that are bottom-ranked, otherwise it remains fully invested regardless of market backdrop. The hedged version deploys a risk-managed approach whereby equity exposure is reduced when our macro models determine the investment backdrop has deteriorated. Minimum account size: $10,000. VGA Style Flex VGA Style Flex is a strategy managed by VGA that invests in a targeted portfolio of individual stocks and ETF’s selected to emphasize market preference for either growth or value stocks. Growth or value attractiveness is determined through a proprietary blend analysis of relative strength and breadth factors. The strategy is designed to provide strong equity market participation during neutral to bullish investment backdrops (as determined by VGA’s macro models) with an emphasis on the predominant equity style that appears to be in favor (growth or value). When neither style appears to be in favor, the strategy’s focus shifts towards capital preservation by reducing overall equity exposure. Equity exposure can range from 100% net long during maximum bullish backdrops to 0% during maximum bearish backdrops. Minimum account size: $75,000. SpiderRock Hedged Equity Concentrated Stock (SRHEC) A risk management option overlay model which seeks to hedge downside risks for concentrated stock positions. The strategy uses options and combinations of options to construct a hedge structure that protects the underlying securities from large downside moves, whiles at the same time preserving a portion of the upside. The strategy seeks a consistent reduction in stock volatility, while also allowing Program Clients to maintain their current stock positions and its dividends. The option positions are dynamically rebalanced during times of market volatility, and systematically implemented to take advantage of option pricing inefficiencies. SpiderRock Advisors allows for up to three tickers per Allocated Sleeve. SpiderRock Hedged Equity Portfolio (SRHEP) A risk management option overlay model which uses option combinations of puts and calls to construct a dynamic collar structure that protects the underlying portfolio from large downside moves, while at the same time preserving a portion of the upside. The strategy seeks a consistent reduction in portfolio volatility, while also allowing Program Clients to maintain their underlying portfolio positions and dividends. The option positions are dynamically rebalanced during times of market volatility, and systematically implemented to take advantage of option pricing inefficiencies. SpiderRock Cash Secured Put (SRCSP) The objective of SRSCSP is to write puts systematically against cash in Program Client’s Allocated Sleeves. This allows a Program Client to potentially enhance portfolio yield, and acquire long positions in the underlying securities, should the price of the underlying security decline by a predetermined amount. The SRCSP program can 14  be implemented on 50/75/100 allocation of the Allocated Sleeve in which the SRCSP program is applied, and is available in taxable and non-taxable Allocated Sleeves. SpiderRock Structured Downside Protection (SRSDP) The objective of SRSDP is to create a dynamic structure of puts and/or calls to buffer Program Client’s Allocated Sleeves from downside moves in equities. This allows a Program Client to potentially avoid some of a downside move, should the price of their underlying equities decline during a discrete period of time. The SRSDP program can be implemented on taxable accounts, covering a 25/50/75/100 allocation of the Allocated Sleeve. SpiderRock S&P CBOE BXM Replication (SRBXM) The objective of the SRBXM is to replicate the options component of the Standard and Poor’s CBOE BXM (BuyWrite) index. Using the CBOE BXM prospectus as a template, this strategy sells At The Money calls on a monthly basis against the beta of the underlying positions in the Allocated Sleeve. The SRBXM program can be implemented on 25/50/75/100 allocation of the Allocated Sleeve in which the SRBXM program is applied, and is available in taxable Allocated Sleeves only. SpiderRock S&P CBOE PUT Replication (SRPUT) The objective of SRPUT is to replicate the options component of the Standard and Poor’s CBOE PUT (PutWrite) index. Using the CBOE PUT prospectus as a template, this strategy sells the first Out of The Monet puts on a monthly basis against a portfolio of cash or T-bills in an Allocated Sleeve. The SRPUT program can be implemented on $250,000 increments and is available in taxable and non-taxable Allocated Sleeves. SpiderRock Negative Duration Equity (SRNDE) This strategy seeks to create long equity exposure through listed index options. The current low-interest rate environment has created a scenario wherein the interest rate variable is also positively correlated to moves in interest rates, allowing for an increase in value if rates rise, and a decrease in value if rates decline. For Program Clients who are already exposed to interest rate risk through fixed-income holdings in their Allocated Sleeves, the SRNDE program seeks to hedge that exposure through the “negative duration” associated with the interest rate variable within the options. SpiderRock Managed Index Income (SRMII) An option overlay model which allows Program Clients to profit from the excess premium that is generally attached to major market, index options. The SRMII program sells index calls options to target a net long market exposure of 40 – 60% for a combined stock-options Allocated Sleeve. The SRMII program has been designed as a cost effective, hedging vehicle, and can be implemented on a 25.50/75/100 % allocation of the Allocated Sleeve in which the SRMII program is applied. The SRMII program is only available in taxable Allocated Sleeves. SpiderRock Structured Note Replication (SRSNR) The objective of SRSNR is to structure a payoff profile at a future date in alignment to client views using listed derivatives and eligible collateral instruments. This allows an investor to create a profile that equity and/or fixed income would not be able to achieve. Strategy structures tend to provide less downside and tailored upside given market conditions versus the long only equivalent. The program can be cash or security collateralized, and is available in taxable and non-taxable accounts (certain structures). SpiderRock Opportunistic Yield Enhancement (SROYE) The objective of SROYE is to write calls opportunistically against Program Clients’ Allocated Sleeves, single securities, and broad based indices, thus allowing a Program Client to potentially enhance portfolio yield while possibly lowering portfolio volatility by monetizing the volatility of the Program Client’s underlying positions in 15  the Allocated Sleeve. The SROYE program can be implemented on a 50/75/100% allocation of the Allocated Sleeve, and is available in taxable and non-taxable Allocated Sleeves. SpiderRock Exchange Fund Replication (SREFR) SREFR is a risk management option overlay model that seeks to reduce market exposure to concentrated single name equity positions while replacing it with exposure to a broad based index in order to reduce idiosyncratic risk in an Allocated Sleeve. THE SREFR program uses options and combinations of options to construct a hedge structure that protects the underlying securities from large downside moves, while at the same time preserving a portion of the upside. Additionally, the SREFR program uses options to create synthetic long exposure to a broad based index. The option positions are dynamically rebalanced during times of market volatility, and systematically implemented to take advantage of option pricing inefficiencies. SpiderRock Qualified Solutions – Conservative (SRQSC) A risk management option overlay model which seeks to reduce market exposure to a diversified equity and fixed income allocation. Through the use of covered call selling and protective put purchases, the strategy seeks to mitigate risk from equity market movements, while generating premium from selling covered calls. SpiderRock Qualified Solutions – Moderate (SRQSM) A risk management option overlay model which seeks to partially reduce market exposure of a diversified equity and fixed income allocation. Through the use of covered calls, the strategy seeks to achieve long-term growth while generating income in addition to equity dividends and portfolio yields, which may help to mitigate risk from equity market movements. SpiderRock Qualified Solutions – Growth (SRQSG) An option overlay model which seeks to partially reduce market exposure of a diversified equity and fixed income allocation. Through the use of covered calls, the strategy seeks to achieve long-term growth while generating income in addition to equity dividends and portfolio yields, which may help to mitigate risk from equity market movements. Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The custodian will promptly forward any proxy voting information to clients or their representatives. Item 7 – Client Information Provided to Portfolio Managers the Privacy Policy from The Adviser gathers information (such as financial information, investment objectives, and risk tolerance) regarding clients to aid in providing appropriate and suitable investment advice regarding participation in the VGA MAP and selection of the appropriate portfolio. The Adviser shares this information only when necessary for processing or administering your account. Please consult the Adviser’s privacy policy for further details about information sharing. Clients may obtain a copy of the Adviser’s website at www.vineyardglobaladvisors.com or upon request to your IAR. 16  Item 8 – Client Contact with Portfolio Managers The Adviser serves as the program sponsor and the portfolio manager. There are no restrictions placed on a client’s ability to contact and consult with the Adviser. Clients should contact the Adviser directly with any questions regarding their account. Item 9 – Additional Information Disciplinary Information The Adviser and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Other Financial Industry Activities and Affiliations VGA is a dba of Integrated, an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Code of Ethics The Adviser has adopted a Code of Ethics for the purpose of instructing its personnel in their ethical obligations and to provide rules for their personal securities transactions. The Adviser and its personnel owe a duty of loyalty, fairness and good faith towards their clients, and the obligation to adhere not only to the specific provisions of the Code but to the general principles that guide the Code. The Code of Ethics covers a range of topics that may include: general ethical principles, reporting personal securities trading, exceptions to reporting securities trading, reportable securities, initial public offerings and private placements, reporting ethical violations, distribution of the Code of Ethics, review and enforcement processes, amendments to Form ADV and supervisory procedures. The Adviser will provide a copy of the Code of Ethics to any client or prospective client upon request. Participation or Interest in Client Transactions The Adviser or individuals associated with the Adviser may buy or sell securities identical to those recommended to clients for their personal accounts. In addition, any related person(s) may have an interest or position in a certain security, which may also be recommended to a client. Under the Adviser’s Code of Ethics, the Adviser and its 17  managers, members, officers and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer reviews all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Adviser). The personal trading reviews ensure that the personal trading of employees does not affect the markets, and that clients of the Adviser receive preferential treatment. Review of Accounts IARs will conduct periodic reviews of client accounts. IARs may meet with clients as frequently as is agreed upon or as is requested by the client or IAR. In most cases, a meeting of some kind will occur at least annually. IARs must extend to clients the opportunity to discuss their account(s) on at least an annual basis. At this meeting, or at other times as appropriate, the IAR should note any updates or changes to a client’s financial situation, goals and objectives. An Adviser principal periodically reviews Program accounts to identify issues or activity which may require further research and/or action. Clients will receive account statements directly from the account custodian, as well as periodic performance reports. The Adviser urges clients to compare the information provided on performance closely to the information presented on the account statements provided by the account custodian. Clients should defer to the custodian’s account statements where discrepancies are noted. Clients can direct any questions about account statements to the custodian or the Adviser. Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals, which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Other Compensation The Adviser may receive certain benefits from recommended broker-dealer/custodians. These benefits do not depend on the amount of transactions we direct to the broker-dealer/custodian. These benefits may include: A dedicated trading desk that services our clients, a dedicated service group and an account services manager dedicated to our accounts, access to a real time order matching system, ability to block client trades, electronic download of trades, balances and positions in the broker-dealer/custodian's portfolio management software, access to an electronic interface with broker- dealer/custodian's software, duplicate and batched client statements, confirmations and year-end summaries, and the ability to have advisory fees directly debited from client accounts (in accordance with federal and state requirements.) 18  Products & Services Available to Us from Schwab Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis, at no charge to advisors. Services that Benefit Client Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients or their account(s). Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provides access to client account data (such as duplicate trade confirmations and account statements); facilitates trade execution and allocate aggregated trade orders for multiple client accounts; • • provides pricing and other market data; facilitates payment of our fees from our clients’ accounts; and • assists with back-office functions, recordkeeping and client reporting. • Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: educational conferences and events • technology, compliance, legal, and business consulting; • • publications and conferences on practice management and business succession; and access to employee benefits providers, human capital consultants and insurance providers. • Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s experience, help reach their goals and put their interests before that of our Firm or its associated persons. Financial Information The Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage client accounts. 19 

Item 1: Cover Sheet ____________________________________________________________________________________ Vineyard Global Advisors, LLC Form ADV Part 2A - Firm Brochure (CRD #171991 / SEC #801-96203) 9800 Mt. Pyramid Ct. Suite 400 Englewood, CO 80112 Telephone: 303-814-6818 www.vineyardglobaladvisors.com March 28, 2025 This Form ADV Part 2A Disclosure Brochure ("Brochure") provides information about the qualifications and business practices of Vineyard Global Advisors, LLC, a DBA of Integrated Advisors Network, an investment adviser registered with the United States Securities and Exchange Commission ("SEC"). If you have questions about this Brochure's contents, please contact Tom R. Samuelson, Chief Investment Officer of Vineyard Global Advisors, LLC, at 720-470-3252 or tom@vineyardglobaladvisors.com or Danielle L. Tyler, Chief Compliance Officer of Integrated Advisors Network at 855-729-4222 or compliance@integratedadvisorsnetwork.com. The information in this Brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Please note that registration as an investment adviser does not imply a certain level of skill or training. An adviser's written and oral communications provide information to determine whether to retain the adviser's services. This Brochure is on file with the appropriate regulatory authorities as Federal and state regulations require. Additional information about Vineyard Global Advisors, LLC and Integrated Advisors Network, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in our firm name or CRD #171991. Results will provide you with all firm disclosure brochures.) 1  Item 2: Material Changes ___________________________________________________________________________________________ In this item, Vineyard Global Advisors, LLC is required to summarize only those material changes made to this Brochure since the Adviser’s last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since the last annual updating amendment of March 27, 2024, there have been no material changes. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients - either by electronic means or hard copy with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at www.adviserinfo.sec.gov by searching either our name or CRD #171991. The SEC's website also provides information about any advisory-affiliated person registered or required to be registered as an Investment Adviser Representative of the firm. You may also request a copy free of charge by contacting us directly at the number(s) located on this Brochure's cover page. 2  Item 3: Table of Contents ___________________________________________________________________________________________ Item 1: Cover Sheet ................................................................................................................................... 1 Item 2: Material Changes ........................................................................................................................... 2 Item 3: Table of Contents .......................................................................................................................... 3 Item 4: Advisory Business ......................................................................................................................... 4 Item 5: Fees & Compensation.................................................................................................................... 9 Item 6: Performance-Based Fees & Side-by-Side Management ............................................................. 13 Item 7: Types of Clients ........................................................................................................................... 14 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ...................................................... 14 Item 9: Disciplinary Information ............................................................................................................. 30 Item 10: Other Financial Industry Activities & Affiliations .................................................................... 30 Item 11 - Code of Ethics, Participation or Interest in Client Transactions & Personal Trading .............. 32 Item 12: Brokerage Practices ................................................................................................................... 34 Item 13: Review of Accounts .................................................................................................................. 39 Item 14: Client Referrals & Other Compensation ................................................................................... 39 Item 15: Custody ...................................................................................................................................... 39 Item 16: Investment Discretion ................................................................................................................ 41 Item 17: Voting Client Securities ............................................................................................................ 42 Item 18: Financial Information ................................................................................................................ 43 3  Item 4: Advisory Business ____________________________________________________________________________________ Overview Vineyard Global Advisors LLC is a DBA of Integrated Advisors Network, an investment advisor registered with the Securities and Exchange Commission ("SEC") pursuant to the Investment Advisers Act of 1940 (the "Advisers Act") (collectively and hereafter referred to as "VGA" or "the Adviser”). Integrated, organized as a limited liability company in 2014, has been SEC-registered since May 11, 2015. VGA is located at 9800 Mt. Pyramid Court. Suite 400, Englewood, CO 80112. Integrated is located at 8117 Preston Road, Suite 300, Dallas, TX 75225. Principal Owners VGA’s Principal Owners are Christopher J. (“Clark”) Richard, Co-Founder and CEO, Thomas R. Samuelson, Chief Investment Officer and Benjamin T. Newhouse, Co-Founder. Integrated’s Principal Owner is TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Advisory Business As used in this brochure, the words "we," "our," "us," or “the firm” refer to VGA and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. The term Associated Persons ("Associates") refers to the Adviser’s Covered Persons and Supervised Personnel - the officers, employees, and individuals providing investment advice or advisory services on behalf of the firm. VGA serves as a fiduciary to clients, as defined under the applicable laws and regulations. As fiduciaries, we uphold a duty of loyalty, fairness and good faith towards each client and seek to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. VGA’s advisory services are made available to clients primarily through its investment professionals - individuals associated with our firm as Investment Advisor Representatives (“Advisor Representatives”). Each advisory relationship at VGA is managed by one or more registered Advisor Representatives who serve as the primary point of contact between VGA and the client. Advisor Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Advisor Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Advisor Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. VGA's advisory services are designed and aimed to complement each client's individual needs, as described within its written investment advisory client services contracts (the "Advisory Agreement," or “Agreement”) that discloses, in substance, the scope of service, contract term, advisory fee, formula for computing the fee and refunds due (if any), and the type of account management authority granted to VGA. Final advisory fee structures are documented within the written Agreement. Advisor Representatives are restricted to providing the services and fees specified within each Agreement, subject to the client's listed objectives, limitations, and restrictions. Agreements must be completed and executed to engage in VGA's advisory services, and clients can engage VGA for additional services at any time. (Please refer to Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management style.) 4  Once established, no Agreement can be assigned - within the meaning of the Advisers Act - by the Adviser without the consent of the client as set forth in the Agreement. (Note: Transactions that do not result in a change of actual control or management of the Adviser within the meaning of the Advisers Act shall not be considered an assignment.) Non-Exclusive Relationship VGA's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client's specific financial situation. Accordingly, since investment strategies and advice are custom-tailored based on each client's specific financial situation, the advice we provide to one client can differ or conflict with that provided for the same security or investment for another. (See Item 8: Methods of Analysis, Investment Strategies & Risk of Loss for additional information.) Other Professional Service Provider Recommendations If requested by the client, VGA can recommend the services of other professionals for implementation purposes. These professionals, who can be lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Unless disclosed otherwise, we do not receive referral fees for such recommendations, and clients are under no obligation to engage in any recommended professional services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Unless noted, VGA is not a party to the transaction and does not maintain the authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any referred VGA client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider's separate contract, including fees and charges and for those charges when assessed, should they choose to engage the referred professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from VGA. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities VGA's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Advisor Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation. VGA will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify VGA in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if earlier disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Advisory Agreement or our authority thereunder. VGA reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Following is a summary description of advisory services covered by this Brochure. 5  Types of Advisory Services VGA is a fee-only investment management firm; it does not sell securities on a commission basis. The Adviser provides investment supervisory services - also known as asset management services, for separately managed client accounts. Clients may choose from the following advisory services: Investment Management Services • • Wrap Fee Program Services* Investment Management Services With VGA’s Investment Management Services, Advisor Representatives will collect financial profile information from clients at the onset of the advisory relationship through personal discussions and questionnaires designed to help them assess the client's objectives and determine their risk tolerance to create a customized portfolio management investment plan. Multiple aspects of the client's financial affairs are reviewed, with agreed-upon realistic and measurable goals set based on the disclosed information. Advisor Representatives will document the goals and objectives for each client in the Client Relationship Management System, using Integrated's programs. According to the selected service(s); the client's written Agreement will document the details of the advisory relationship and the final advisory fee structure. If appropriate for the account type established, the Advisor Representative will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. Advisor Representatives will use portfolio rebalancing software to maintain client allocations according to the IPS in effect. We will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) Neither VGA nor Integrated maintains physical custody of client funds or securities other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission. Therefore, according to the client's Agreement, the custody of client assets will be held by an independent and separate Qualified Custodian (“Custodian”), who will take possession of the cash, securities, and other assets within the client's portfolio account. As account goals and objectives will often change over time, suggestions are made and implemented ongoing as the client and Advisor Representative periodically review their financial situation and at annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Client Tailored Services VGA offers the same suite of services to all its clients. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at VGA’s discretion, as detailed herein and defined in each client's written Advisory Agreement. (For more information, see Item 5: Fees & Compensation.) 6  Client Imposed Restrictions Clients can, at any time, impose restrictions on investing in particular securities or security types according to their preferences, values, or beliefs. Such restrictions must be submitted to VGA in writing. Clients can also amend/change such limitations by once again providing written instructions. Reasonable efforts are made to comply with client investment guidelines, including any client's reasonable limits by standard industry practices. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similar account without restrictions. It is important to note that client-imposed restrictions within their account and variations could result in positive or negative performance differences for the account compared to accounts without such restrictions. The restrictions can also potentially prevent achieving a client's specific goals. Upon receiving a client's written restrictions, VGA will discuss the restriction request's feasibility to confirm expectations are met and verify the client's acknowledgment and understanding of the imposed restriction's possible outcomes. VGA reserves the right to either reject client-imposed restrictions or end the client relationship. In no event and regardless of the advisory service provided is VGA obligated to make any investment or enter any transaction it believes in good faith would violate any federal or state law or regulation. Wrap Fee Program Services Under our Wrap Fee Program Services, VGA is the Sponsor of the Vineyard Global Advisors Managed Account Program ("VGA MAP" or the “Program”), a bundled asset-based fee Program that differs from a regular advisory services account in that clients receive both investment advisory services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Wrap Fee” or “Program Fee") regardless of the number of trades completed by a client. The assets in each Program are regularly monitored, with investment strategy purchase and sale transactions based on the client's specific needs and investment goals. Program clients will undergo the same collection of client profile information and analysis as indicated in the preceding “Investment Management Services” section and enter into a separate Agreement to participate in the Program that sets forth the terms and conditions of the engagement, describes the scope of the services to be provided, fees to be paid, and type of authority granted to VGA. Final advisory fee structures are documented within the written Agreement. Clients will then invest in the Program by establishing one or more accounts with the Custodian. As the Program's Sponsor and investment manager, VGA receives management fees and a portion of the Wrap Fee related to administrative services the Adviser performs from the payment of the Wrap Fee. Generally, clients participating in this type of Program will pay the Wrap Fee to the Program sponsor quarterly in based on the total portfolio value as of the last business day of the preceding calendar year. With the client’s written permission, this fee payment will be debited from the client’s account by the Custodian. VGA passes on a portion of the Wrap Fee to the broker-dealer partner of the Program for its services, which can include management and custodial fees, the execution of securities brokerage transaction/trading expenses, and reporting and administrative costs) and retains a portion of the Wrap Fee for the advisory services it provides. The overall costs clients will incur if they participate in our Wrap Fee Program can be higher or lower than they could incur by separately purchasing the types of securities available in the Program. Clients should be aware that a conflict of interest exists whenever VGA recommends participating in its Wrap Fee Program. Because the Wrap Fee Program has a higher fee, Advisor Representatives have a slight incentive to offer it over a non-wrap fee program, so they could be financially incentivized to recommend such a service. 7  In addition, VGA will also work with other Advisor Representatives by having their clients participate in the VGA MAP. (Note: Incorporated by reference is the VGA MAP Program WRAP Brochure.) The SEC rules require that a Wrap Fee Brochure be provided to clients before or when entering a Program Agreement. VGA has prepared a Wrap Fee Brochure to satisfy this requirement that provides clients with important information about our Program, including further information about the services and fees the client will pay. Clients are encouraged to carefully review all Program documents and discuss any questions they may have with their Advisor Representative and other professionals prior to Program participation and at any time they may have questions or concerns after Program account establishment. Types of Investments The types of investments available to clients can include certificates of deposit, corporate debt securities, commercial paper, equities (stocks), futures contracts, investment company securities (variable annuities, variable life insurance, and mutual funds shares), municipal securities, options contracts, partnership interests, U. S. government securities, and warrants, among others. Assets in mutual funds and exchange-traded funds are typically invested in no-load or low-load funds, usually through brokers or fund companies. Brokerages can charge a transaction fee for the purchase of some funds which the client will pay unless in a wrap program. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades which the client will pay unless in a wrap program. The Adviser does not receive any compensation, in any form, from fund companies. Initial public offerings (IPOs) are not available through the Adviser. VGA can also advise on any investment held in the client’s portfolio at the inception of the advisory relationship. Although VGA provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives and will use other securities to help diversify a portfolio when appropriate. (For additional information on investment considerations, see Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss.) VGA can allocate assets among private funds, including funds of funds, managed by third parties. With respect to fund of funds, VGA recommends funds on an alternative investment platform which manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents which each investor is required to receive and/or execute prior to being accepted as an investor in a fund. VGA does not invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Before acting on any analysis, advice, or recommendation, VGA recommends prospective investors should consult with their legal counsel, tax, and other financial investment professionals, as necessary, to aid in due diligence as proper for their situation and determine the suitability of the risk associated with any investment. Conflicts of Interest Clients should be aware that the specific advisory services selected and the compensation to VGA and their Advisor Representative will differ according to the exact service chosen. The compensation we receive can be greater than the amounts otherwise received had the client participated in another service or paid separately for investment advice, brokerage, or other relevant services. 8  Due to the differences in fee schedules among the various advisory programs and services offered by VGA and the client’s Advisor Representative, a conflict of interest exists when there is a financial incentive to recommend a particular service over others. Factors that bear upon the cost of a particular advisory program in relation to the cost of the same services purchased separately include but are not limited to, the type and size of the account, the historical and expected size or number of trades for the account, and the number and range of supplementary advisory and client-related services provided to the account. Clients are under no obligation to act upon any recommendations or purchase any products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through VGA or any recommended third party. The client can act on recommendations received by placing their business and securities transactions with any brokerage of their choice. VGA does not represent that the products or services offered are at the lowest available cost - clients could be able to obtain the same or similar products or services at a lower price from other providers. VGA has adopted and implemented compliance policies and procedures and a Code of Ethics (“Code”) to mitigate conflicts of interest. Our Code is available for review free of charge to any client or prospective client upon request. Assets Under Management As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non-discretionary basis. Item 5: Fees & Compensation ___________________________________________________________________________________________ Advisory Services Fees & Compensation VGA’s advisory clients agree to pay an asset-based advisory fee calculated according to the schedules indicated herein. (Note: Wrap Fee Program clients should review the Adviser’s Form ADV Part 2A Appendix 1 - Wrap Fee Brochure for information about the fees associated with that advisory service.) Fee Negotiation Availability Under certain circumstances, all advisory fees are negotiable up to the maximum annual rates listed herein, subject to certain limitations and approval by VGA. The Adviser, in its sole discretion, can charge lesser fees or choose to reduce or waive minimum fees for services based upon specific criteria such as pre-existing client relationships, the number of related investment accounts, inception date, total account assets under management, expected additional assets, anticipated future earning capacity, account composition, and client negotiations, among others. At our discretion, certain employee accounts or for members of a client's family or otherwise can be assessed fees based on the total balance of all accounts. While VGA seeks to facilitate advantageous agreements for clients, to the extent fees are negotiable, some clients can pay higher (more) or lower fees (less) than other clients for services than if they had contracted directly with another provider. According to the selected advisory services, the final fee structures will be reflected in each client's written Agreement. Lower fees for comparable services can sometimes be available from other sources. In all cases, clients are responsible for any tax liabilities that result from any transactions. Regardless of fee negotiation availability, under no circumstances will a client be required to pre-pay a VGA advisory fee more than six months in advance, in excess of $1,200. Investment Management Services Fees Schedule of Fees For Investment Management Services, VGA will charge from 0.25% - 0.75% of the total assets under management, up to a maximum annual fee of up to 2.95%, based upon a percentage of the market value of the client’s assets under management, calculated and billed consistent with the Adviser’s disclosure documents and 9  each client’s executed Agreement. Each client's executed Agreement will indicate the exact advisory service and strategy(ies) selected, the final advisory fee and the fee-payment arrangement before the delivery of any advisory services commences. (Note: Lower fees for comparable services can sometimes be available from other sources.) Fee Calculation Except as otherwise described in this section, Investment Management Services advisory fees are billed quarterly in advance, based on a percentage of assets under management calculated on the average daily balance of the client’s account as of the last day of the preceding quarter. (Note: This means clients will be invoiced for advisory fees due before the next quarter’s billing period begins.) If an Agreement is executed at any time other than the first day of a calendar month/quarter, our fees will apply on a pro-rata basis, which means that the advisory fee is payable in proportion to the number of days in the month/quarter for which you are a client. Assets under management include all U.S. securities, non-U.S. securities, cash and other instruments in a client's account advised by VGA. VGA considers cash to be an asset class. Depending on market conditions, investment advisory strategies often involve moving to cash positions for varying periods. As a result, cash balances are included in the value of the assets under our management that are the basis for charging our advisory fee unless otherwise noted in the Agreement. The advisory fee billed to the cash portion of client accounts will exceed money market yields when rates for such money market funds are lower than the advisory fees charged to the account. Securities without a readily available market price are valued at fair value, as determined in good faith by the Custodian. With respect to client account assets in alternative investments, alternative investment managers and underlying vehicles are responsible for providing the Custodian with an asset's valuation in accordance with applicable laws. Fee Payment Clients will choose how they wish to be billed and indicate their fee billing and payment preference on their advisory services Agreement. Clients may have their fees directly debited from their Custodial account or billed. Fee payment in full is expected upon invoice presentation. The Adviser will not access client funds for fees without written client consent. Clients who wish to have their advisory fees directly debited will authorize VGA in writing to directly deduct advisory fees due from their Custodial account and provide the Custodian with authorization to deduct such fees and instructions to remit them straight to VGA. VGA will calculate the advisory fees due based on the client’s Agreement and send the client an invoice showing the amount of the fee, the value of the assets on which the fee is based, the period covered by the fee, and the specific manner in which the fee was calculated, and the account Custodian will agree to send the client a statement, at least quarterly, indicating all amounts disbursed from their account, including the amount of the advisory fee paid directly to VGA. The account Custodian does not verify the accuracy of the Adviser’s advisory fee calculation. Upon receiving VGA’s instructions, the Custodian will automatically deduct and pay from the client’s account the fee amount due, regardless of the portfolio’s market performance during the preceding quarter. VGA’s account advisory fee will be payable first from free credit balances, money market funds, or cash equivalents, if any, and second from the liquidation of a portion of the client’s securities holdings. Please note that ongoing fees reduce the value of an investment portfolio over time - when our advisory fee is debited from the portfolio's assets, clients have less money invested to generate a return. Clients are encouraged to discuss the impact of fees with their Advisor Representative. 10  When authorized by the client to debit advisory fees from client accounts, VGA is deemed to have custody of client assets to the extent the Adviser is permitted to instruct Custodians to deduct the fees. If clients find any inconsistent information between our invoice and the statement(s) they receive from their Custodian, they should contact us directly. If a client is not receiving statements directly from their Custodian, in addition to promptly advising their Advisor Representative, VGA also recommends they contact their Custodian. VGA urges clients to review any Custodial account statements received promptly upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Clients who wish to be billed for their advisory services fees will authorize this form of payment in writing on their Agreement and request that we invoice them directly monthly or quarterly for any fees due. Clients will then make fee payments to us by separate check or credit card within 45 days of invoice receipt. Under no circumstance will any advisory fees be deducted from amounts they hold within their Custodial account(s). (See Item 15: Custody for additional details.) Account Additions, Withdrawals & Terminations Clients can make additions to their VGA accounts in cash or securities at any time. VGA reserves the right to liquidate any transferred securities or decline to accept particular securities into the client's account, according to the type of authority granted to the Adviser. If VGA liquidates transferred securities, clients can be subject to additional fees such as transaction fees, other fees assessed at the mutual fund level such as contingent deferred sales charges, and tax ramifications. Clients can make withdrawals from their VGA accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures. Additionally, if the client transfers their account to another firm, they can pay an outgoing account transfer fee. Generally, account terminations can be made to a VGA Agreement by written notice without penalty within five (5) business days after the Agreement execution date. After that, the Agreement between VGA and the client will continue in effect until either party terminates following the terms of the Agreement, which state termination can be made by either party upon written notice to the other party. Terminations become effective on receipt of such notice and will not affect: the validity of any action previously taken by the Adviser under the Agreement, liabilities or obligations of the parties from transactions initiated before termination of the Agreement, or the client's obligation to pay management and other fees due, prorated through the termination date. • • • Upon receiving the termination notice of the agreement, VGA will take steps to deliver cash/and or securities as per the client's instructions. If securities are liquidated, clients can incur liquidation fees or contingent deferred sales charges. Depending on market conditions, a liquidation can result in a loss. In addition, the Custodian or broker- dealer liquidating the security positions can impose additional fees. If the client holds certain alternative investments and/or illiquid securities, they may have to wait for specific redemption schedules. Clients shall be charged pro rata for services provided through to the date of termination. Any unearned advisory fees at the time of account termination will be promptly returned to the client. If the client is a natural person, the client's death, disability, or incompetency will not terminate or change the terms of an Agreement. Instead, the Agreement shall immediately terminate upon the Adviser’s receipt of written notice of the client's death. The disability or incompetency of the client will not terminate or change the terms of this 11  Agreement; however, the client’s executor, guardian, attorney-in-fact, or other authorized representative can terminate this Agreement by giving written notice to VGA. Before termination, all directions given or actions taken or omitted by VGA before the effective Agreement termination shall be binding upon the client and any successor or legal representative. From the termination date, the Adviser will no longer be entitled to receive fees and has no obligation to recommend or act concerning an account's securities, cash, or other investments on the terminated Agreement. Clients should refer to their Agreement for complete details. Wrap Fee Program Services Fees VGA’s Wrap Fee Program Services fees for the Vineyard Global Advisers Managed Account Program (“VGA MAP” or the “Program”) are asset-based fees that will include investment advisory services fees and the fees for most of the brokerage, custody, clearance, settlement, and other administrative services and transaction costs to the broker-dealer/Custodian with custody of the client’s assets and, therefore, are usually higher than a typical asset- based advisory fee. VGA will receive a portion of the Wrap Fee for its services. Wrap Fees are generally billed quarterly in advance, based on the net asset value of each account at the end of the previous period, including assets invested in cash and cash equivalents, accrued interest, and dividends. (For complete details, refer to the Adviser’s Form ADV Part 2A – Appendix 1 Wrap Fee Brochure and the Wrap Fee Program Agreement.) Integrated Fee Disclosure The following is for disclosure purposes only: Integrated retains other Adviser Representatives who offer fees that can vary from the VGA fees disclosed herein, which fees may be collected in arrears or in advance, as disclosed within each advisory group’s specific brochure. Fee schedules are specific to each Integrated advisory group, and VGA’s clients will not pay or be affected by the fees charged by these Advisor Representative groups. The VGA advisory group may have fees that are higher or lower than these other Integrated advisory groups, and there is no representation that VGA's fees are the lowest available for similar services. Fees Charged to Third Party Advisers VGA receives an annual fee based on the total assets in each third-party adviser's clients' accounts, for which we provide sub-advisory management services. The Adviser is paid the sub-advisory fees quarterly, either in advance or arrears, depending on the arrangement with the third-party adviser. Other Fees Conflicts of Interest Please note that most advisory clients will pay a fee based on a percentage of the assets under advisement. This compensation method can sometimes lead to conflicts of interest between our firm and the client regarding our advice. As the services available from Integrated can be found through other companies at differing prices, we recommend clients review the components that determine charges and service calculations. Factors for consideration should include but are not limited to account size, type(s) of account(s), transaction charges, the range of advisory services, and each service's ancillary charges. Integrated urges clients to discuss any questions or concerns with their Advisor Representative. Other Fees & Expenses Clients should note that our fees are exclusive of bank or custodial fees, brokerage commissions, transaction fees, and other related costs and expenses a client may incur. Some examples of these fees can include but are not limited to custodial fees, trading charges for odd-lot differentials, fixed income, or other transactional costs, including mark- ups, mark-downs, commissions, and dealer profits, charges imposed directly by exchange-traded funds in the account - which will be disclosed in the applicable fund's prospectus, wire transfer and electronic fund fees, or other costs and taxes on brokerage accounts and securities transactions. A third party can also impose fees for services elected by their clients, such as certificate delivery, American Depositary Receipts ("ADRs"), and transfer taxes 12  mandated by law. Specific portfolios can also include transactions in foreign securities and execution on foreign stock exchanges, resulting in other transaction expenses. ETFs and other managed products or partnerships can also be in clients' portfolios. Clients can be charged for the services by the providers/managers of these products, and the advisory management fee paid to VGA. Charges can be imposed directly by mutual funds, and mutual fund shares held in client accounts may be subject to 12b-1 fees, short-term redemption fees, and other annual fund expenses. No-load or load-waived mutual funds used in client portfolios would not have initial or deferred sales charges; however, if a fund that imposes sales charges is selected, the client may pay an initial or deferred sales charge. Mutual funds pay advisory fees to their managers, which are indirectly charged to all mutual fund shareholders. Clients with mutual funds in their portfolio effectively pay the adviser and any third-party manager, Custodian, and mutual fund manager to manage their assets. Each fund's prospectus fully describes fees and costs, which clients must carefully consider. The fees paid to us are separate from the fees and expenses charged by mutual funds. As a client could invest in a mutual fund or investment partnership directly and without our services, they should review both the fees charged by the funds and the applicable program fee charged by the adviser to evaluate the advisory services being provided fully and understand the total amount of fees to be paid by them. (Please note the Adviser does not accept commission-based compensation nor receive mutual fund 12b-1 fees.) Clients may also incur "account termination fees" upon transferring an account from one brokerage firm (broker- dealer/Custodian) to another. These account termination fees can range significantly from a nominal fee to several hundred dollars but can be much higher. Clients should contact their account Custodians to determine the amount of account termination fees charged and deducted from their accounts for any accounts that may be transferred. (Please also see Item 12 - Brokerage Practices for additional details.) We believe that the charges and fees offered within its program are competitive with alternative programs available through other firms offering similar services; however, lower fees for comparable services may be available from other sources. For example, a client could invest in mutual funds directly. In that case, the client would not receive the services provided by us, which are designed, among other things, to assist them in determining which investments are most appropriate for their financial condition and objectives, the ability to undertake a disciplined approach to portfolio rebalancing while taking into account the tax ramifications of same and the avoidance of ad hoc emotional reactions to shorter-term market events. Further, some of the funds may not be available to the client directly without the use of an investment adviser granted access to such investments. VGA encourages clients to speak with their Advisor Representative directly about any questions about our fees and compensation. Item 6: Performance-Based Fees & Side-by-Side Management ___________________________________________________________________________________________ Performance-based fees are fees based on a client's account's share of capital gains or appreciation. Side-by-side management refers to managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. VGA provides its services for an advisory fee based upon a percentage of a client's assets under management by Federal and state. Fees are not based on a share of managed securities' capital gains or capital appreciation. However, the Adviser may employ certain investments with a performance fee in which the Adviser does not participate. As applicable, these fees are explained in the Adviser’s Agreement and the investments' offering documents or private placement memorandum. 13  Item 7: Types of Clients ___________________________________________________________________________________________ Client Types VGA typcially provides investment advice to investment advisory firms or individual Investment Adviser Representatives (including other Integrated Advisor Representatives). The Adviser may occasionally provide services to individuals, high net-worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, and corporations or business entities. Client relationships vary in scope and length of service. Minimum Account Size A minimum account size of $50,000 is required to open and maintain an Investment Management Services account. At their sole discretion, Advisor Representatives may negotiate to waive stated account minimums or charge a lesser management fee based upon specific criteria such as a pre-existing client, anticipated future earning capacity, expected future additional assets, the dollar amount of assets to be managed, related accounts, account composition, negotiations with the client, and pro bono activities, among others. Smaller portfolio accounts will only be accepted if, in the sole opinion of VGA, the lesser account size will not cause a substantial increase in investment risk beyond the client's identified risk tolerance. The portfolios of family members can also be aggregated to meet minimum account requirements. (See Item 5 - Fees & Compensation, Fee Negotiation Availability for additional details.) The minimum account size required under VGA’s Wrap Fee Program Services is disclosed in each MAS Program Agreement. (Note: In selecting a referred manager, the client is responsible for understanding the account minimums, requirements, and fee agreement they are executing with the referred manager.) Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ___________________________________________________________________________________________ Methods of Analysis VGA provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include but are not limited to cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. Security analysis methods may include charting, cyclical analysis, fundamental analysis, and technical analysis. Charting Analysis - involves the gathering and processing of price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore, the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. Fundamental Analysis - 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 14  of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Technical Analysis - a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that the performance of the stock, rather than the performance of the company itself, has more to do with the company’s future stock price. Risk: Some risks of this type of analysis include biased opinions or indicators that – while providing possible entry and exit points and information for consideration, can produce false or conflicting signals or not be 100% accurate in their forecasting. This technique can be used from time to time to generate tactical ideas for buying and/or selling a security. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Advisor Representatives may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Advisor Representatives will consider only the account’s managed assets, not other investments the client may hold elsewhere. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Investment Strategies Strategies may include long-term purchases, short-term purchases, trading, short sales, margin transactions, and option writing (including covered options, uncovered options or spreading strategies). Other types of investment strategies from which clients can choose include: VGA ETF Advantage Series - The VGA ETF Advantage series is a group of managed asset allocation strategies offered by VGA that utilize exchange-traded funds (“ETFs”) in five custom market models that range from capital preservation (10% equity-90% fixed income) to aggressive growth (90% equity-10% fixed income). The models are offered in both tax-sensitive and qualified versions. The strategies provide exposure to nine different asset classes that include U.S. equities, foreign-developed equities, emerging market equities, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management, while additional downside protection is provided by tactical asset class adjustments and the use of opportunistic hedge positions based on input from our macro models. ETFs offer low operating costs, tax efficiency and low minimum investment entry levels, making the ETF Advantage strategy available to lower account sizes (minimum $10,000). VGA Allocation Plus Series - The VGA Allocation Plus series is a group of managed asset allocation strategies we offer that utilize mutual funds and ETFs in five custom market models that range from capital 15  preservation (10% equity-90% fixed income) to aggressive growth (90% equity-10% fixed income). The models are offered in both tax-sensitive and qualified versions. Actively managed mutual funds are selected through proprietary research designed to identify those managers that have been able to consistently offer returns above their respective asset categories (manager "alpha"). In asset categories where little additional alpha can be obtained through active management, that category is sourced with a passive ETF. The strategies provide exposure to nine different asset classes that include U.S. equities, foreign-developed equities, emerging market equities, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management, while additional downside protection is provided by tactical asset class adjustments and opportunistic hedge positions based on input from our macro models. Several of the mutual funds require higher minimum initial investment levels, making this strategy available for account sizes of $100,000+. VGA Advantage Plus Series - The VGA Advantage Plus Series is a group of managed asset allocation strategies offered VGA that utilize mutual funds, ETFs and internal proprietary investment strategies in five custom market models that range from capital preservation (10% equity-90% fixed income) to aggressive growth (90% equity-10% fixed income). The Allocation Advantage Plus strategy is offered in a unified managed account (“UMA”) format, which is a sophisticated design that combines multiple investment vehicles into a single portfolio account, maximizing efforts to enhance diversification. The models are offered in both tax-sensitive and qualified versions. The strategy utilizes both VGA-actively managed strategies and mutual funds that have been selected through proprietary research designed to identify managers that have been able to consistently offer returns above their respective asset categories (manager "alpha"). The internal strategies and mutual funds are included in an effort to maximize risk- adjusted returns. In asset categories where active management has provided minimal alpha, that category is sourced with a passive ETF. The strategies provide exposure to nine different asset classes that include U.S. equities, foreign-developed equities, emerging market equities, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management, while additional downside protection is provided by tactical asset class adjustments and opportunistic hedge positions based on input from our macro models. Several mutual funds and internal strategies require higher minimum investment levels, making this strategy available for account sizes of $500,000+. VGA R3000 Enhanced Dividend - The VGA R3000 Enhanced Dividend strategy is a proprietary strategy managed by VGA that invests primarily in dividend-paying U.S. stocks that are selected through a proprietary screening process developed to identify companies that may offer above-average total return potential, with a primary focus on income. The strategy may also invest in income-producing American Depository Receipts ("ADRs"), ETFs, and closed-end funds ("CEFs"). The strategy deploys a risk- managed approach whereby equity exposure is reduced when our macro models determine the investment backdrop has deteriorated. Equity exposure can range from between 25% net long (during maximum negative market backdrops) to 125% net long (during maximum positive market backdrops). The minimum account size is $25,000. VGA Enhanced S&P 500 - The VGA Enhanced S&P 500 strategy is a proprietary strategy managed by VGA that invests in S&P 500 stocks that are selected through a proprietary screening process developed to identify companies that may offer above-average total return potential. The strategy deploys a risk- managed approach whereby equity exposure is reduced when our macro models suggest the investment backdrop has deteriorated. Equity exposure can range from -5% net long (during maximum negative market backdrops) to 120% net long (during maximum positive market backdrops). VGA-enhanced S&P 500 seeks to outperform the S&P 500 index with a bias toward downside risk management. The strategy is designed to provide equity market participation during bullish phases as determined by our macro models while attempting to provide downside protection when our macro models suggest the equity market backdrop has deteriorated. The minimum account size is $25,000. 16  VGA Global Fixed Income - The VGA Global Fixed Income strategy is a proprietary fixed-income allocation strategy managed by VGA that invests in fixed-income ETFs, CEFs and mutual funds. The strategy invests across 22 fixed-income categories selected for their diversification attributes. The strategy is offered in both tax-sensitive and qualified versions. Risk management may be further enhanced through the use of ETF hedge positions, which can be included to manage interest rate and credit risk, depending upon input from our macro models. The VGA Global Fixed Income strategies are intended for investors with low-risk tolerance and to provide portfolio diversification benefits when added to higher volatility equity allocations. The minimum account size is $10,000. VGA Dynamic Yield - The VGA Dynamic Yield is an income-focused strategy that invests in U.S. dividend- paying stocks, American Depository Receipts ("ADRs”), CEFs and open-end mutual funds. Its primary objective is to offer risk-managed income sourced through dividends, interest income and royalty payments. It seeks to achieve its objective by investing in a portfolio of approximately 65 positions that offers exposure to all the major, publicly- traded income-producing asset categories. Risk management is achieved through (1) broad diversification across asset classes, (2) dynamic adjustment of the equity and fixed-income portions of the portfolio (based on input from our macro models) and (3) the use of opportunistic ETF hedge positions to further address equity, credit and interest rate risk. The minimum account size is $25,000. VGA Covered Call - VGA Covered Call is a proprietary separately managed account strategy that seeks attractive risk-adjusted returns through the purchase of a diversified equity portfolio and concurrent sale of call options, which may provide partial downside protection plus the potential for auxiliary income generation. The portfolio consists of 16-35 individual covered call positions that are diversified by sector, strike price and expiration date. Individual stocks are systematically selected through proprietary screens and then scored using a multi-factor model that evaluates their attractiveness at the time of purchase. The minimum account size is $150,000. VGA Custom Covered Call - The VGA Custom Covered Call strategy is offered on an account-by-account basis as a way for clients to generate auxiliary income on concentrated equity positions through the sale of call options. First, the client determines a level at which they are indifferent to selling the underlying stock position. Then, VGA deploys an opportunistic covered call writing program around the agreed-upon exit price with an eye towards trading the calls for a profit should the overall stock market or that particular stock decline in value. The minimum account size: $1,000,000. VGA Optimized Equity Alpha - VGA Optimized Equity Alpha is a strategy managed by VGA that invests in U.S.-listed stocks and ETFs, seeking to achieve its objective of long-term capital appreciation by combining a sector rotation strategy and a style preference strategy (growth vs. value). These two different approaches are combined into one strategy due to their diversification benefits. The strategy is designed to provide strong equity market participation during neutral to bullish investment backdrops, as determined by VGA's proprietary macro models, with a focus on capital preservation during bearish investment backdrops. Equity exposure can range from 100% net long during maximum bullish backdrops to 0% during maximum bearish backdrops. The minimum account size is $150,000. VGA Private Client Services ("PCS") - The VGA Private Client Services ("PCS") provides customized portfolio construction solutions to high net-worth clients, generally with a liquid net worth in excess of $1,000,000. Customized portfolio solutions are designed and implemented after consultation with an advisor who seeks to determine the appropriate allocation based on the client's individualized investment objectives and/or financial plan. An open architecture environment is utilized that may invest across a broad array of stocks, bonds, exchange-traded funds, closed and open-end mutual funds, proprietary internal strategies and alternative and structured investment products. VGA PCS is offered in a unified managed account format, which is a sophisticated design that combines multiple investment vehicles into a single portfolio account, maximizing efforts to enhance diversification. The minimum account size: $1,000,000. 17  VGA Risk Managed Income - The VGA Dynamic Yield is an income-focused strategy that invests in U.S. dividend-paying stocks, ADRs), CEFs and open-end mutual funds. Its primary objective is to offer a low- volatility, risk-managed income solution sourced through dividends, interest income and royalty payments. Risk Management is achieved through (1) constraining equity exposure to a maximum of 30% of the overall strategy, (2) dynamic adjustment of the equity and fixed income portions of the portfolio (based on input from our macro models) and (3) the use of opportunistic ETF hedge positions further to address equity, credit and interest rate risk. The minimum account size is $25,000. VGA Quantitative Value - The VGA Quantitative Value is a strategy managed by VGA that invests in a targeted portfolio of approximately 50 top-ranked stocks in the Russell 3000 Value index selected through a proprietary screening process designed to identify companies with above-average total return potential. The screening process seeks to identify companies with a unique blend of value, quality, profitability, growth, and price momentum attributes that have historically been associated with superior stock performance. The strategy is offered in two versions: long-only and hedged. The Long-only version remains at least 80% invested regardless of the market backdrop. The hedged version will scale overall portfolio equity exposure from 0% net long to 100% net long during maximum bearish to maximum bullish market backdrops, respectively. The strategy is rebalanced quarterly, although individual positions may be adjusted opportunistically. The minimum account size is $50,000. VGA Quantitative Growth – VGA Quantitative Growth is a strategy managed by VGA that invests in a targeted portfolio of approximately 50 top-ranked stocks in the Russell 3000 Growth index selected through a proprietary screening process designed to identify companies with above-average total return potential, utilizing a "growth at a reasonable price" or GARP methodology. The screening process seeks to identify companies with a unique blend of earnings growth, earnings momentum, earnings consistency, valuation and price momentum attributes that have historically been associated with superior stock performance. The strategy is offered in two versions: long-only and hedged. The long-only version remains at least 80% invested regardless of the market backdrop. The hedged version will scale overall portfolio equity exposure from 0% net long to 100% net long during maximum bearish to maximum bullish market backdrops, respectively. The strategy is rebalanced quarterly, although individual positions may be adjusted opportunistically. Minimum account size: $50,000. VGA Sector Rotation - The VGA Sector Rotation is a strategy managed by VGA that invests in an equity portfolio of S&P 500 sector ETFs based on their total return potential, as determined by VGA's proprietary ranking models. Top-ranked sectors determined will receive a higher portfolio weight, and bottom-ranked sectors determined will receive a lower weight or are held in cash. The strategy is offered in two versions: long-only and hedged. The long-only version will hold cash in sectors that are bottom-ranked; otherwise, it remains fully invested regardless of the market backdrop. The hedged version deploys a risk-managed approach whereby equity exposure is reduced when our macro models determine the investment backdrop has deteriorated. The minimum account size is $10,000. VGA Style Flex - The VGA Style Flex is a strategy managed by VGA that invests in a targeted portfolio of individual stocks and ETFs selected to emphasize market preference for either growth or value stocks. Growth or value attractiveness is determined through a proprietary blend analysis of relative strength and breadth factors. The strategy is designed to provide strong equity market participation during neutral to bullish investment backdrops, as determined by VGA's macro models, with an emphasis on the predominant equity style that appears to be in favor (growth or value). When neither style appears to be in favor, the strategy's focus shifts towards capital preservation by reducing overall equity exposure. Equity exposure can range from 100% net long during maximum bullish backdrops to 0% during maximum bearish backdrops. The minimum account size is $75,000. 18  Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. VGA will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account Custodian of your individually selected accounting method. Please note that all decisions regarding cost-basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. VGA cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Adviser's Investment Activities - the Adviser's investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by VGA. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and VGA investment decisions will not always be profitable. Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When 19  a bond is called, it may be impossible to replace it with a bond of equal character, paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high- quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of the firm and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage-backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a 20  callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates, which may cause the value of many fixed-income investments to decline. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring 21  the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or 22  financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager who trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The costs of managing the funds can reduce the returns on mutual funds and ETFs. Also, while some mutual funds are "no-load" and charge no fee to buy into or sell out of the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may 23  prevent the ETF from correlating with the performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S. Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks - a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased 24  market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk - is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available 25  for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, 26  intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using 27  AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality. Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Risks of Specific Securities Utilized While VGA seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. 28  - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. VGA does not represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described, and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods, and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the 29  suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Advisor Representative. Item 9: Disciplinary Information ___________________________________________________________________________________________ Integrated is required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. Neither Integrated nor its management has any disciplinary or legal proceedings to disclose material to a client’s evaluation of this advisory practice. Integrated has no outstanding issues and is registered as an investment adviser without restriction. VGA does not have any disciplinary items to disclose material to a client’s evaluation of its advisory practice. Certain of Integrated’s other Advisor Representatives may have disciplinary actions against them for violations of certain securities regulations, rules, and/or statutory provisions by Federal or state regulatory agencies. Clients may view Integrated’s and our disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at www.adviserinfo.sec.gov by searching our firm name or CRD #171991. The SEC's website also provides information about any affiliated person registered or required to be registered as an Investment Adviser Representative of the firm, including their disclosure items (if any). Copies are also available by contacting us directly or viewing our website, as disclosed on the cover of this Brochure. Item 10: Other Financial Industry Activities & Affiliations ___________________________________________________________________________________________ VGA is a dba of Integrated, an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Integrated and VGA Associates can be Registered Representatives (“RRs”) of non-affiliated broker-dealers and Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based 30  compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. If your Advisor Representative offers brokerage products as an RR through their unaffiliated broker-dealer, they are not acting in a brokerage capacity or on behalf of the Adviser concerning the services provided under our Agreement(s). The Adviser is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. This practice presents a conflict of interest because the objectivity of the advice rendered to clients could be biased. The Advisor Representatives providing investment advice on behalf of our firm, who are also RRs of outside and separate broker-dealers, can be incentivized to effect securities transactions to generate commissions rather than solely based on a client’s needs. The Adviser addresses this conflict of interest by requiring Associates to disclose this type of relationship to clients. Associates satisfy this requirement by advising their clients of the nature of and their role in the transaction or relationship and any compensation - including commissions or otherwise, to be paid to them by the brokerage firms with which they are affiliated at the time of any recommendation is made and/or product transactions occur. The Adviser further mitigates conflicts through its procedures to review client accounts relative to the client or investor's financial situation to ensure appropriate investment management services. The Adviser is committed to ensuring that Associates adhere to the Firm's Code of Ethics and that the Adviser and all Associates fulfill their fiduciary duty to clients/investors. Designations VGA Associates can hold various other designations in connection with the approved outside business activities, separate from their role with the Adviser. VGA does not solicit clients to utilize any services offered by Associates in this capacity. Associates' recommendations or compensation for such designation services are separate from VGA’s advisory services and fees. Insurance Services Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use VGA for investment advisory services. In these capacities, Advisor Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from the Adviser. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents or Advisor Representatives. Sub-Advisory Services to Third-Party Managers VGA has entered into written agreements with certain unaffiliated third-party investment advisers to serve as a sub- adviser and provide Investment Management Services to the third-party advisers' clients. Under these sub-advisory arrangements, each third-party investment adviser is responsible for working with its clients to select the appropriate strategy for investment. VGA manages the clients' designated assets based on the respective selected investment strategy. (Please refer to Item 5: Fees & Compensation for additional information.) Tax Preparation Services Advisory clients may choose to use non-affiliated independent tax preparation services. Clients of the tax 31  preparation providers may decide to use VGA for investment advisory services. Although Associates will make clients aware of the availability of tax preparation services, advisory clients are not required to utilize such services. Other Business Relationships VGA uses third-party resources to help run its business and provide services to its clients, mostly back-office related. The Adviser sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-added providers to service clients. While VGA has developed a network of professionals - accountants, lawyers, and otherwise, neither the Adviser nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since VGA’s Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. VGA addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of the firm, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, VGA’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of VGA, the investment adviser or under any VGA Advisory Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how VGA mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics (“Code”). A copy of our Code is available for review free of charge to any client or prospective client upon request. Item 11 - Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ____________________________________________________________________________________ Code of Ethics Rule 204A-1 of the Investment Advisers Act of 1940 requires all investment advisors registered with the Securities and Exchange Commission to adopt codes of ethics that set forth standards of conduct and comply with federal securities laws. The Adviser takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of the supervised personnel who act on its behalf. The adviser believes each of its advisory clients is owed the highest level of trust and fair dealing and holds Associates to a very high standard of business practices and integrity. To that end, the firm has adopted a Code of Ethics that sets forth its conduct standards in keeping with its fiduciary obligation. VGA’s Code imposes upon Associates the duty to deal fairly and: render disinterested and impartial advice, • • make suitable recommendations to clients within the context of the total portfolio, given their needs, financial circumstances, and investment objectives, exercise a high degree of care to ensure that all material facts are disclosed to clients, • • provide adequate and accurate representations of its business and other information about VGA's services and investment recommendations, • disclose any conflicts of interest, and 32  • promote fair, ethical, and equitable practices. The Adviser's Code requires all Associates to exercise a fiduciary duty by acting in each client’s best interest while consistently placing the client's interests first and foremost. The Code applies to all Associates, including individuals registered with the adviser as Advisor Representatives or considered 'Supervised Persons' under the Advisers Act Rules. The Code may also be applied to any other person the Chief Compliance Officer designates. Our Code outlines and prohibits certain activities deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict) and specifies reporting requirements and enforcement procedures. Associates must abide fully by all applicable industry regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code, including any updates. The Code requires an affirmative commitment by Associates they will abide by all state and federal securities laws and provisions relating to client information confidentiality, a prohibition on insider trading, restrictions on the acceptance of significant gifts, outside activities reporting, and personal securities trading procedures for Covered Persons, among others. Upon employment or affiliation and at least annually after that, Associates are required to attest to their understanding of and compliance with the Adviser’s Code of Ethics, including confirmation and acknowledgment by every licensed Advisor Representative of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required of them. And execute an affirmation stating they will conduct business honestly, ethically, and fairly, avoiding all circumstances that might negatively affect or appear to affect its duty of complete loyalty to all clients. Personal Trading The Adviser and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested in before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Or combine our securities orders with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, the Adviser has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Our policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. The Adviser performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, we also prohibit insider trading and have implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how the Adviser mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Our Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons 33  associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Item 12: Brokerage Practices ____________________________________________________________________________________ Preferred Custodians & Brokers-Dealers The Adviser does not maintain custody of the assets we manage on our client’s behalf. Client assets are required to be held in an account at a "Qualified Custodian," generally a broker-dealer or bank. Clients will decide on their Custodian during Advisory Agreement execution and enter into a separate broker-dealer/Custodian client account agreement directly with the Custodian of their choice. While the Adviser works with multiple Custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred Qualified Custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers The Adviser seeks to select and recommend a Custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab and Fidelity as its preferred Custodians, it will occasionally review other Custodians to determine their compensation's reasonableness. In studying the topic and selecting a Custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the Custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. 34  Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their clients access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the Custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services VGA can receive from our preferred Qualified Custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some of which the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each Custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to us that benefit us but do not directly benefit our clients or their accounts. These products and services assist us with managing and administering client accounts. They include investment research, both a Custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on VGA’s commitment to maintaining client assets in accounts at the Custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if VGA had not committed. In addition to commissions or asset-based fees, Custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the 35  commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each Custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a Custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the Custodian. Our preferred Qualified Custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence VGA to recommend a Custodian to clients for custody and brokerage services as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third party - originating from a party independent from the broker providing the execution services. A conflict of interest may exist in making a reasonable good-faith allocation between research services and non- research services because VGA allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which did not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for VGA’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in VGA’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between VGA and its clients, as services received from our Custodians benefit VGA because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each Custodian. This required minimum can give VGA an incentive to recommend that our clients maintain their accounts with a specific Custodian based on our interest in receiving custodial services that benefit our business rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, VGA may receive non-research - administrative or accounting services and research benefits from the broker-dealers' services. When this happens, VGA will make a good-faith allocation between the non-research and research portion of the services received and pay VGA money ("hard dollars") for the non-research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our Custodians might not be the lowest compensation VGA might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), VGA may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction, recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker- dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in 36  servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet our sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Our preferred Qualified Custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate Custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on VGA’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per Custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred Qualified Custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our Custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account Custodian who maintains their investment assets. VGA statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. We urge clients to promptly review any statements they receive directly from their Custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from VGA may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution VGA acts on its duty to seek “best execution.” As a matter of policy and practice, VGA conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. VGA seeks to ensure compliance with the client's written Advisory Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another Custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While VGA will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct us in writing to use another broker-dealer/Custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the Custodian; we will not seek better execution services, better prices, or aggregate client transactions for execution 37  through other Custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account that would otherwise be the case had the client used the adviser’s recommended Custodian(s). Subject to its duty of best execution, VGA may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific Custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. VGA does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our firm or persons associated with our firm may buy or sell securities for you while we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. VGA’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions VGA makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, VGA’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an VGA trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. VGA’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. 38  Item 13: Review of Accounts ___________________________________________________________________________________________ Periodic Reviews Account reviewers are members of the firm, CCO, and the associated Advisor Representatives. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account, and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account Custodian. Account reviewers are members of the firm, CCO, and the associated Advisor Representatives. Collectively, they review accounts not less than once a year. Item 14: Client Referrals & Other Compensation ___________________________________________________________________________________________ Incoming Client Referrals The Adviser receives client referrals, which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15: Custody ___________________________________________________________________________________________ Custodial Practices The Adviser does not accept physical custody of a client's securities. Clients will keep all account assets with the Custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate Qualified Custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the Custodian of record. The Adviser is not authorized to withdraw any money, securities, or other property from any client custodial account in the client's name or otherwise. While VGA prohibits the firm or its Associates from obtaining, accepting, or maintaining control of client funds, securities, or assets, with a client's consent, the Adviser may be provided with the authority to seek deduction of its fees from a client's custodial accounts. This process is generally more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the Custodian's form or 39  separately, to their Custodian and request the Custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If the Adviser is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. VGA requires the client to complete and sign the appropriate standing letter of authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. The firm’s policy ensures it meets and complies with the SEC's seven conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. To do this, the Adviser will require: 1. the client provides an instruction to the Custodian in writing, which 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, 2. the client authorizes VGA, 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, 3. the client's 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, 4. the client can terminate or change the instruction to the client's Custodian, 5. VGA has no authority or power 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, 6. VGA maintains records showing that the third party is not a related party of the Adviser or located at the same address as the Adviser, and 7. in writing, the client's Custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, the Adviser is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Account Statements The Qualified Custodian will send the client account statements, at least quarterly, itemizing activity and account transactions, specific investments held in the account, the value of the portfolio, deposits, withdrawals and advisory fees that occurred during the period of the statement. These statements will be delivered by postal mail or electronically, as selected by the client. VGA urges clients to promptly review any statements they receive directly from their Custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s)' investment performance against the appropriate benchmark applicable to the type of investments held in the account and any periodic information from us. VGA cannot guarantee the accuracy or completeness of any report, or any other information provided to the client by the Custodian or another service provider to the client. VGA encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. 40  If a client believes there are any inaccuracies or discrepancies in any reports received from their Custodian, or if they do not understand the information in any report, document or statement received, they should promptly and in all cases before the next statement cycle, report any items of concern to their Advisor Representative or VGA directly. Unless the client indicates otherwise, by promptly notifying VGA in writing of concerns regarding statements received, investments VGA makes at their direction and in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. If clients are not receiving statements, at least quarterly, from their Custodian, they should promptly inform their Custodian directly and their Advisor Representative. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in any statement received from the Adviser with the statements received directly from their Custodian to ensure accuracy of all account transactions. Item 16: Investment Discretion ____________________________________________________________________________________ Account Management Style Our advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, the Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting the Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as VGA deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Advisor Representative may agree to from time to time (collectively, the “Investment Guidelines”). Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a limited power of attorney as a stand-alone document or as part of the account opening paperwork through their Custodian, and the Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. 41  Non-Discretionary Authority Some clients may engage their Advisor Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by the Adviser or their Custodian to establish the account trading authorization, and we will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Advisor Representative may agree to from time to time. Under this management style, the Adviser must receive approval from the client before placing any trades in the client's account. As a result, until the Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistent with the jointly agreed upon investment objectives, the Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement’s termination provisions if they so desire. Once an investment portfolio is constructed, the Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. The Adviser seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Item 17: Voting Client Securities ____________________________________________________________________________________ Proxy Voting VGA will not ask for or accept voting authority for client securities and is not obligated to forward proxy notices to clients or their agents. VGA will direct the Custodian to forward all shareholder-related materials directly to the client's address on record. Clients maintain the responsibility for exercising their right to vote for proxies. While VGA can assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of supplying client information about a particular proxy vote in any of the above situations. It is the client's obligation to vote their proxies. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies, Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisers to clients. VGA has no duty or obligation to evaluate a client's eligibility, advise, or submit claims to participate in the proceeds of securities class action settlements or other related legal actions, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in any manner concerning legal proceedings involving securities currently or previously held by the client's account or securities issuers. VGA does not provide legal or tax advice, engage in any activity that might be deemed to constitute the practice of law or accountancy, or act for the client in any manner concerning legal proceedings involving securities held or previously held by the client's account or the issuers of such securities. 42  VGA is not obligated to forward copies of written or electronic notices of any legal actions, proceedings, or materials affecting such securities. It is the client's responsibility to respond to any legal actions or proceedings involving the securities purchased or held in their account and/or initiate litigation to recover damages if they may have been injured as a result of the actions, misconduct, or negligence by the corporate management of issuers of such securities. Item 18: Financial Information ___________________________________________________________________________________________ Balance Sheet VGA neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance and therefore is not required to include a balance sheet with this Brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients VGA does not have any financial condition that will likely impair its ability to meet contractual commitments to clients. VGA has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years VGA has not been the subject of a bankruptcy petition in the last ten years. Disciplinary Disclosures Certain of the Adviser’s financial professionals have legal or disciplinary histories to disclose. Please visit the United States Securities and Exchange Commission's ("SEC") website at www.adviserinfo.sec.gov for a free and simple search tool to research the Adviser and its Advisor Representatives. 43 

Item 1 – Cover Sheet Echelon Investment Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 408 W 8th Street, Suite 103 Dallas, TX 75208 (214) 232-5974 www.echelonim.com March 28, 2025 This brochure provides information about the qualifications and business practices of Echelon Investment Management, LLC. If you have any questions about the contents of this brochure, please contact us at (214) 232- 5974, or by email at info@echelonim.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222. 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 the Advisor is available on the SEC’s website at www.adviserinfo@sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 - Material Changes Annual Update This section describes material changes to Echelon Investment Management Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Echelon Investment Management’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on March 27, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 - Material Changes ..........................................................................................................................................2 Item 3 – Table Of Contents ........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees & Compensation ..................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................7 Item 7 – Types Of Clients ..........................................................................................................................................8 Item 8 – Methods Of Analysis, Investment Strategies And Risk Of Loss .................................................................8 Item 9 – Disciplinary Information ............................................................................................................................12 Item 10 – Other Financial Industry Activites And Affiliations ................................................................................12 Item 11 – Code Of Ethics, Participation Or Interest In Client Transactions And Personal Trading ........................13 Item 12 – Brokerage Practices ..................................................................................................................................13 Item 13 – Review Of Accounts ................................................................................................................................17 Item 14 – Client Referrals And Other Compensation ..............................................................................................17 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................18 Item 17 – Voting Client Securities ...........................................................................................................................18 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisory Business Firm Description Echelon Investment Management, LLC is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Advisor” or “Echelon”. Integrated Advisors, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Advisor nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Principal Owners of Echelon Investment Management LLC are as follows: Echelon Investment Management is owned equally by James Mathis and James Tindall. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Echelon Investment Management, LLC is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. James Mathis and James Tindall are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment policy statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. 4  Types of Services Investment Management As part of the investment management service, all aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Echelon through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Echelon is mindful of each client’s financial situation, ensuring that the client’s investment objectives are met on an ongoing basis, and ensuring that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITS”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Echelon. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Echelon may utilize third-party managers (“Money Manager”) to manage either a portion or a client’s entire portfolio. Echelon’s recommendation that a Money Manager manage a client’s account will be based on the Money Manager’s investment philosophy and policies, its record as an investment adviser, and Echelon’s determination that the investment style of the Money Manager is consistent with the client’s financial needs, risk tolerance and objectives. To ensure that Money Managers are still appropriate for a client, Echelon performs reviews of the Money Manager’s portfolios and financial standing and Echelon also updates the client’s financial objectives as necessary. Echelon may remove and replace Money Managers at its discretion when it believes a Money Manager is no longer consistent with the client’s needs and objectives or where, in the estimation of Echelon, the Money Manager’s portfolio is underperforming relative to its asset class or is poorly positioned relative to current market conditions. Access to certain Money Managers, platforms and programs may be limited to certain types of accounts and may be subject to account minimums, which will vary and may be negotiable depending upon the Money Managers, platforms and programs selected. Certain platforms and programs administered by Echelon and/or made available to clients by Echelon may be available through other independent investment advisers, and in certain instances, directly via the custodian or other third-party administering the platform or program. In addition, clients may be able to access certain Money Managers directly. As such, clients may be able to access such Money Managers, platforms and programs at a lower cost through other channels. Further, it may be possible for a client to access Money Managers directly or through other platforms or programs for an “unbundled” fee that is lower than the “bundled” fee that is available through Echelon. Initial public offerings (IPOs) are not available through Integrated. WRAP Program The Advisor does not sponsor or provide investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. 5  Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees & Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. Account Asset Value Equity/Balanced Annual Fee $0 - $1,000,000 1.5% $1,000,000.01 - $2,000,000 .90% $2,000,000.01 + .80% $4,000,000 and up Negotiable Fee Billing Investment management fees will be billed quarterly or monthly in arrears based on the total market value of the account as shown on the Firm’s provided portfolio statement on the last business day of the quarter or month. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Integrated Fee Disclosure The clients of Echelon will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Echelon’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Echelon’s fees are the lowest available for similar services. 6  Other Fees The Advisor’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisers selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The Advisor, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Advisor will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Advisor is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Advisor does not act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Conflict of Interest Between Different Fee Structures The Advisor offers several different services detailed in this brochure that compensate the Advisor differently depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Advisor mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Advisor is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. 7  Item 7 – Types of Clients Description The Advisor generally provides investment advice to investment advisory firms or individual Investment Adviser Representatives (that may be other IARs at Integrated Advisors Network LLC). The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $250,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Echelon’s Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to 8  initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs, policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the 9  Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. 10  It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own Advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or LP interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. 11  Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations Associated persons of Integrated Advisors Network are registered representatives of a broker dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated Advisors Network are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors Network. Integrated Advisors Network does not make any representation that the brokerage services are at the lowest cost available and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated Advisors Network. Integrated Advisors Network mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Echelon. Money Managers Echelon recommends or selects other Money Managers to manage part or all of your account. Echelon does not have any agreements where it will receive any direct or indirect compensation from the Money Managers, therefore, we are not aware of any conflicts that may arise from these recommendations or selections. 12  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Advisor may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Advisor on behalf of any client or is being considered for purchase or sale. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, 13  it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: 14  Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities 15  for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. 16  Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and its associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. 17  Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice 18  or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet Shields Capital Advisors Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 22 Ashcroft Ct. Fox River Grove, IL 60021 (312) 953-0115 www.shieldscap.com March 28, 2025 This brochure provides information about the qualifications and business practices of Shields Capital Advisors, Inc. If you have any questions about the contents of this brochure, please contact us by telephone at (312) 953- 0115, or by email at bill@shieldscap.com Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Shields Capital Advisors Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Shields Capital Advisors’ current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801- 96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on March 27, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................8 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................8 Item 9 – Disciplinary Action ....................................................................................................................................12 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................14 Item 13 – Review of Accounts .................................................................................................................................17 Item 14 – Client Referrals and Other Compensation ...............................................................................................18 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................19 Item 17 – Voting Client Securities ...........................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisory Business Firm Description Shields Capital Advisors Inc is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”, “Shields Capital Advisors” or “Shields”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC-registered investment adviser. The Adviser is a fee-only investment management and consulting firm. The Adviser provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, charitable organizations, and State or Municipal Government Entities directly. The Firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated does not act as a custodian of client assets and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as insurance planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Shields Capital Advisors is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network, LLC. William Yocius and Dennis Hoffman are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client, which often includes an annual 4  meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Shields Capital Advisors through Integrated provide investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Shields Capital Advisors is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client- imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Shields Capital Advisors or a third-party manager. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds and ETFs is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Initial public offerings (IPOs) are not available through Integrated. Pension Planning Shields Capital Advisors will typically provide a variety of pension planning services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, Shields Capital Advisors offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: Identifying investment objectives and restrictions; • • Providing guidance on various assets classes and investment options; • Recommending money managers to manage plan assets in ways designed to achieve objectives; • Monitoring performance of money managers and investment options and making recommendations for changes; • Recommending other service providers, such as custodians, administrators and broker-dealers; and • Creating a written pension consulting plan. Shields Capital Advisors has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, Shields will always ensure those other advisers are properly licensed or registered as an investment adviser. Shields conducts due diligence on any third- party investment adviser, which may involve one or more of the following: phone calls, meetings, and reviews of the third-party adviser's performance and investment strategy. Shields then makes investments with a third-party investment adviser by investing with the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third- party adviser on behalf of Shields's client. Shields may also allocate among one or more private equity funds or private equity fund advisers. Shields will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. WRAP Program The Adviser does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. 5  Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the month completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. Total Assets Under Management Annual Fees $0 - $250,000 1.00% 0.50% $250,001 – And Up Investment management fees will be billed quarterly in advance. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Pension Consulting Fees Shields Capital Advisors generally charges as fixed project-based fee to provide clients with retirement plan consulting services. Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor, as memorialized in the Agreement. These fees vary, based on the scope of the services to be rendered. In those situations where Shields Capital Advisors has agreed to manage a plan’s assets. Total Assets Under Management Annual Fee All Assets 0.95% Integrated Fee Disclosure The clients of Shields Capital Advisors will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Shields’ fees may be higher or lower than other 6  advisory groups at Integrated and there is no representation that Shields fees are the lowest available for similar services. Other Fees Shields Capital Advisors will receive its standard fee on top of the fee paid to the third-party adviser. This relationship will be memorialized in each contract between Shields Capital Advisors and each third-party adviser. The fees will not exceed any limit imposed by any regulatory agency. Shields Capital Advisors may engage in the selection of third-party money managers, but does not have any such arrangements in place at this time. This service may be canceled with 30 days’ notice. The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisors selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases, there may be fees charged which are a result of brokered trading activity by associated personnel of the Adviser that is outside of the constructs of the Adviser’s investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client the fees may vary in size depending on the nature of the client’s requests. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. 7  Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit sharing plans, charitable organizations, and government entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $100,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Shields Capital Advisory’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific 8  industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit 9  the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards. There may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or 10  to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel, and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. 11  Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Fixed Income Investments. Fixed income securities are subject to the risk of an issuer’s ability to meet principal and interest payments on the obligation (credit risk) and may also be subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (market risk). The market values of fixed income securities tend to vary inversely with the level of interest rates. Yields and market values of fixed income securities fluctuate over time, reflecting not only changing interest rates but the market’s perception of credit quality and the outlook for economic growth. Lower-rated or unrated (i.e., high yield) securities are more likely to react to developments affecting the market and credit risk than are more highly rated securities, which primarily react to movements in the general level of interest rates. Lower-rated securities are defined as securities below the fourth-highest rating category by a nationally recognized statistical rating organization. Such obligations are speculative and may be in default. The adviser may invest Client assets in such ‘high yield’ securities. In addition, the adviser may invest Client accounts in unrated securities. When economic conditions appear to be deteriorating, medium to lower-rated securities may decline in value due to heightened concern over credit quality, regardless of prevailing interest rates. Investors should carefully consider the relative risks of investing in high yield securities and understand that such securities are not generally meant for short-term investing. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Action The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Shields Capital. Insurance Affiliations Shields Capital Advisors and/or certain associated persons of Shields Capital Advisors may sell insurance products to advisory clients. Shields Capital Advisors offer insurance products that are associated with an insurance company with which Shields Capital Advisors has established a relationship. Insurance products include fixed or index annuities, life, health, long term care, and general agency insurance. The Adviser earns commissions on these insurance products in addition to any fees earned from financial planning, investment management, or other services offered. The commissions are based on the standard commission schedule of the provider of the insurance products and are generally not negotiable. The clients who purchase insurance related products are informed that Shields 12  Capital Advisors or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that Shields Capital Advisors and/or the associated persons may sell insurance products to clients of Shields Capital Advisors and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. Insurance related products are excluded from investment advisory management fees. Shields Capital Advisors makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from Shields Capital Advisors or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Shields Capital. Associated persons of Integrated can also act as a pension consultant and from time to time, may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. Shields Capital Advisors always act in the best interest of the client and clients are in no way required to utilize the services of any representative of Shields in connection with such individual’s activities outside of Shields. Integrated Advisors Network mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer, and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers, and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Adviser or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. 13  Item 12 – Brokerage Practices Brokerage/Custodian Selection and Soft Dollars The Adviser has the authority over the selection of the broker/custodian to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client will decide whether to do so and will open your account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. 14  Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part 15  of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional 16  compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. 17  Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. 18  Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Advisers discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet Paragon Wealth Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 8117 Preston Rd., Suite 300 Dallas, TX 75225 (817) 832-5584 March 28, 2025 This brochure provides information about the qualifications and business practices of Paragon Wealth. If you have any questions about the contents of this brochure, please contact us at (817) 832-5584, or by email at john.fowler@paragonwealth.net. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Paragon Wealth’s Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Adviser Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Paragon Wealth’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment at www.adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update There are no material changes to this Brochure. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................8 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................8 Item 9 – Disciplinaary Information ..........................................................................................................................12 Item 10 – Other Financial Idustry Activites and Affiliations ...................................................................................12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................13 Item 13 – Review of Accounts .................................................................................................................................17 Item 14 – Client Referrals and Other Compensation ...............................................................................................18 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................18 Item 17 – Voting Client Securities ...........................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisory Business Firm Description Paragon Wealth is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Advisor” or “Paragon”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is a SEC registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. The Firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has some associated persons who are in other fields where they receive commissions as compensation. The Advisor is not affiliated by ownership with entities that sell financial products or securities. The Advisor nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Paragon is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. John (Johnny) Fowler is an Investment Advisor Representative (“IAR”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the Investment Adviser Representative utilizing the Advisor’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. 4  Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Paragon through Integrated provides investment advisory services to Clients that are tailored to the Clients’ needs based on their financial situation and investment objectives. Paragon is mindful of each Client’s financial situation, endeavoring to ensure that the Client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of Clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Paragon. For some Clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no- load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Paragon may offer/manage a more active options strategy that is based on the fundamental and/or technical evaluation of each company to determine attractive prices to buy or sell options. Initial public offerings (IPOs) are not available through Integrated. Financial Planning Paragon through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Paragon may also refer clients to an accountant, attorney or other specialist. For planning engagements, Advisor will provide a summary of client’s financial situation, observations, and recommendations. For consulting engagements, Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Paragon whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Paragon or its associated persons may receive compensation for financial planning and the provision of investment 5  management services and/or the sale of insurance and other products and services. Paragon nor Integrated do not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Paragon or use the services of Paragon in particular. Wealth Coaching, Second Opinions & Financial Analysis Fees Paragon may provide coaching services that typically do not include investment advisory or management services, financial planning services, nor the review or monitoring of a client's investment portfolio. The Advisor may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Advisor. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Advisor if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Advisor’s previous recommendations and/or services. WRAP Program The Advisor does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s Fee can range from 0% through 2.00%, depending upon the passive or active nature of the portfolio. Financial Planning Fees Financial Planning for clients without $100,000+ under management and for complex situations is provided under a fixed fee arrangement agreed upon at the first meeting and based on an hourly rate ranging between, $125 - $250. Twenty-five percent of the fee is payable in advance before the financial planning process is started. The remaining seventy-five percent is payable at the end of the engagement. Wealth Coaching, Second Opinions & Financial Analysis Fees Paragon provides a range of education, coaching and analysis services including "second opinions" on existing 6  investment portfolios. These services are provided based on an hourly rate ranging between, $125 -$250. An estimate of project cost is made before the project is started. Twenty-five percent of the fee is payable in advance, and the balance is payable at the end of the engagement. Fee Billing Investment management fees are billed monthly, in advance based on the total market value of the account as shown on the Firm’s provided portfolio statement on the last business day of the month. Account values are based upon pricing information supplied by the client’s 3rd party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Integrated Fee Disclosure The clients of Paragon will not pay and will not be affected by the fees of other IARs at Integrated. The following 832is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Paragon’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Paragon fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisors selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The Advisor, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Advisor will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Advisor is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive 7  commissions as compensation. The investment management services are provided through separately managed accounts for each client The Advisor does not act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Conflict of Interest Between Different Fee Structures The Advisor offers several different services detailed in this brochure that compensate the Advisor differently depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Advisor mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Advisor is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. 8  Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Paragon’s Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full 9  benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cashflow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes special problems enforcing claims against foreign governments. 10  • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. 11  Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partner (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information Paragon and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations Some associated persons of Integrated are registered representatives of a broker dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors Network. Integrated does not make any representation that the brokerage services are at the lowest cost available and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated. 12  Integrated mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Paragon. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer, and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Advisor, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Advisor, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Advisor and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. 13  In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While we a certain custodian may be recommended, the client will decide whether to do so and will open your account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. 14  Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a 15  specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each Client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many Clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded 16  from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. 17  Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Solicitor Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Advisor submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or 18  sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities, and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet Vineyard Wealth Advisors Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) PO Box 675285 Rancho Santa Fe, CA 92067 (417) 881-7100 www.vineyardasset.com March 28, 2025 This brochure provides information about the qualifications and business practices of Vineyard Wealth Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at by telephone at (417) 881- 7100, or by email at info@vineyardwealthadvisors.com . Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222. The information in this Brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Please note that registration as an investment adviser does not imply a certain level of skill or training. An adviser's written and oral communications provide information to determine whether to retain the adviser's services. This Brochure is on file with the appropriate regulatory authorities as Federal and state regulations require. Additional information about Vineyard Wealth Advisors, LLC and Integrated Advisors Network, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in our firm name or CRD #171991. Results will provide you with all firm disclosure brochures.) 1  Item 2 – Material Changes Annual Update In this item, Vineyard Wealth Advisors, LLC is required to summarize only those material changes made to this Brochure since the Adviser’s last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since the last annual updating amendment of March 28, 2024, changes have been made to the following Brochure sections: Item 1 Address Updated Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients - either by electronic means or hard copy with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at www.adviserinfo.sec.gov by searching either our name or CRD #171991. The SEC's website also provides information about any advisory-affiliated person registered or required to be registered as an Investment Adviser Representative of the firm. You may also request a copy free of charge by contacting us directly at the number(s) located on this Brochure's cover page. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 6 – Performance Fees .........................................................................................................................................7 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................8 Item 9 – Disciplinary Information ............................................................................................................................11 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................14 Item 13 – Review of Accounts .................................................................................................................................18 Item 14 – Client Referrals and Other Compensation ...............................................................................................18 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................19 Item 17 – Voting Client Securities ...........................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................20 3  Item 4 – Advisory Business Vineyard Wealth Advisors LLC is a dba of Integrated Advisors Network LLC, hereinafter “the Adviser” or “Vineyard Wealth”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser (such registration does not imply that the Adviser has attained a certain level of skill or training). The Adviser provides investment management services to individuals and wealthy individuals on a separate account management basis. The Adviser is a fee-only investment management. The Firm does not sell securities on a commission basis. The Firm is not affiliated with any entities that sell financial products or securities. The Adviser does not act as a custodian of client assets and the client always maintains asset control. The Adviser does have discretion of client accounts but if non-discretionary assets are accepted the Adviser will seek client approval prior to placing a trade on behalf of the client. The Adviser does have discretion over which brokerage firms to trade with and the resulting commissions to be paid and/or where the account is held in custody and the resulting expenses related to that custodianship. Integrated Advisors Network LLC does act as a sponsor and does provide investment advice to a WRAP program. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network, LLC are as follows: Integrated’s Principal Owner is TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Types of Advisory Services Vineyard Wealth Advisers is a dba of Integrated Advisors Network, LLC. All advisory services are offered through Integrated Advisors Network LLC. Christopher “Clark” Richard, is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system. Investment policy statements are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Agreements Investment Management Agreement As part of the investment management service, many aspects of the client’s financial affairs are reviewed and realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. 4  Financial Planning Agreement The financial plan may include, but is not limited to: a net worth statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations. The financial planning may be the only service provided to the client and does not require that the client use or purchase the investment advisory services offered by the Adviser or any of the insurance products or other products and services offered by the associated persons of the Adviser. There is an inherent conflict of interest for the Adviser whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. The Adviser or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. The Adviser does not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of the Adviser or use the services of the Adviser in particular. Asset Management Investments may also include equities (stocks), warrants, options, corporate debt securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), and U. S. government securities. Assets are invested primarily in no-load or low-load mutual funds and exchange-traded funds, usually through brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Brokerages may charge a transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. The Adviser does not receive any compensation, in any form, from fund companies. Initial public offerings (IPOs) are not available through Integrated. VGA can allocate assets among private funds, including funds of funds, managed by third parties. With respect to fund of funds, VGA recommends funds on an alternative investment platform which manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents which each investor is required to receive and/or execute prior to being accepted as an investor in a fund. VGA does not invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Separate Account Management Platforms As part of the Adviser’s Asset Management Services, the Adviser offers access to multiple managers and allocation services through Separate Account Management Platforms. Based on the client’s needs and suitability, the Adviser may recommend or select a Separate Account Management Platform, to manage all, or a portion of, the client’s assets. Each platform includes access to sub-managers. WRAP Fee Programs Generally, the Adviser considers the Separate Account Management Platform to be a WRAP fee program through which investment advisory services and execution of the client’s transactions are provided for specified fees that are not based directly upon transactions in the client’s account. The Adviser receives a portion of the WRAP fee for investment management services provided. The Adviser and the representative do not manage WRAP fee accounts differently from other programs. For a complete description of the WRAP program, the WRAP fee and what services 5  are included in the WRAP fee, refer to ADV Part 2A, Appendix 1, the WRAP Fee Program Brochure specific to the program that is being utilized. Termination of Agreements A Client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded. Assets Under Management As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non-discretionary basis. Item 5 – Fees and Compensation Investment Management The Adviser bases its fees on a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. In addition, the Adviser may have arrangements in place with other management personnel and affiliates through which profits are split per agreed upon terms. Fees for investment management generally range from 1.50% to 2.50% based on household asset holdings, investment program selected. The fees may include a fee paid to third-party managers that range from 0.18% - 1.00% that is included in the overall management fee. The third-party manager may offer their services as part of a WRAP program. Financial Planning The fee for a financial plan is predicated upon the facts known at the start of the engagement. The fee range is $1,500 to $5,000 and is negotiable. Since financial planning is a discovery process, situations occur wherein the client is unaware of certain financial exposures or predicaments. In the event that the client’s situation is substantially different than disclosed at the initial meeting, a revised fee will be provided for mutual agreement. The client must approve the change of scope in advance of the additional work being performed when a fee increase is necessary. After delivery of a financial plan, future face-to-face meetings may be scheduled as necessary for up to one month. Follow-on implementation work is billed separately at the rate of $250 per hour. Fee Billing Investment management fees are billed quarterly, in advance, meaning that we invoice you before the three-month billing period has begun. Payment in full is expected upon invoice presentation. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. 6  Integrated Fee Disclosure The clients of Vineyard Wealth will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Vineyard Wealth’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Vineyard Wealth’s fees are the lowest available for similar services. Other Fees Unless the client portfolio account is in a wrap program, the client will likely incur fees from brokerages, custodians, administrators and other service providers. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products, the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Adviser is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are 7  discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients The Adviser generally provides investment advice to individuals, pension and profit-sharing plans, trusts, estates, or charitable organizations, corporations or business entities. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis, technical analysis and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Investment Strategies Strategies may include long-term purchases, short-term purchases, trading, short sales, margin transactions, and option writing (including covered options, uncovered options or spreading strategies). The primary investment strategy used on client accounts is strategic asset allocation. This means that we use passively-managed index and exchange-traded funds as the core investments and then add actively- managed funds where there are greater opportunities to make a difference. Portfolios are globally diversified to control the risk associated with traditional markets. The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. Each client executes an Investment Policy Statement that documents their objectives and their desired investment strategy. The Adviser’s strategies do not involve frequent trading. Strategies may include long-term purchases, short-term purchases, short sales, and margin transactions. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. 8  Vineyard Wealth Advisor’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. 9  Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients will be exposed to risks that are specific to the securities in their particular investment portfolio. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality. Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. 10  Currency. 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. Limited Liquidity of Interests. An investment in a partnership usually involves substantial restrictions on liquidity and its interests are not freely transferable. There is no market for these interests and no market should be expected to develop. Additionally, transfers are usually subject to the consent of the general partner at the general partner’s sole discretion. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Adviser and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations VWA is a DBA of Integrated, an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Integrated and VWA Associates can be Registered Representatives (“RRs”) of non-affiliated broker-dealers and Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based 11  compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. If your Advisor Representative offers brokerage products as an RR through their unaffiliated broker-dealer, they are not acting in a brokerage capacity or on behalf of the Adviser concerning the services provided under our Agreement(s). The Adviser is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. This practice presents a conflict of interest because the objectivity of the advice rendered to clients could be biased. The Advisor Representatives providing investment advice on behalf of our firm, who are also RRs of outside and separate broker-dealers, can be incentivized to effect securities transactions to generate commissions rather than solely based on a client’s needs. The Adviser addresses this conflict of interest by requiring Associates to disclose this type of relationship to clients. Associates satisfy this requirement by advising their clients of the nature of and their role in the transaction or relationship and any compensation - including commissions or otherwise, to be paid to them by the brokerage firms with which they are affiliated at the time of any recommendation is made and/or product transactions occur. The Adviser further mitigates conflicts through its procedures to review client accounts relative to the client or investor's financial situation to ensure appropriate investment management services. The Adviser is committed to ensuring that Associates adhere to the Firm's Code of Ethics and that the Adviser and all Associates fulfill their fiduciary duty to clients/investors. Designations VWA Associates can hold various other designations in connection with the approved outside business activities, separate from their role with the Adviser. VWA does not solicit clients to utilize any services offered by Associates in this capacity. Associates' recommendations or compensation for such designation services are separate from VWA’s advisory services and fees. Insurance Services Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use VWA for investment advisory services. In these capacities, Advisor Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from the Adviser. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents or Advisor Representatives. Sub-Advisory Services to Third-Party Managers VWA has entered into written agreements with certain unaffiliated third-party investment advisers to serve as a sub-adviser and provide Investment Management Services to the third-party advisers' clients. Under these sub- advisory arrangements, each third-party investment adviser is responsible for working with its clients to select the appropriate strategy for investment. VWA manages the clients' designated assets based on the respective selected investment strategy. (Please refer to Item 5: Fees & Compensation for additional information.) 12  Tax Preparation Services Advisory clients may choose to use non-affiliated independent tax preparation services. Clients of the tax preparation providers may decide to use VWA for investment advisory services. Although Associates will make clients aware of the availability of tax preparation services, advisory clients are not required to utilize such services. Other Business Relationships VWA uses third-party resources to help run its business and provide services to its clients, mostly back-office related. The Adviser sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-added providers to service clients. While VWA has developed a network of professionals - accountants, lawyers, and otherwise, neither the Adviser nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor their management person(s) have any other material relationships or conflicts of interest with other financial industry participants. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since VWA’s Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. VWA addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of the firm, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, VWA’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of VWA, the investment adviser or under any VWA Advisory Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how VWA mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics (“Code”). A copy of our Code is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer, and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. 13  Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Adviser is Danielle Tyer. She reviews all employee trades each quarter (except for his own trading activity that is reviewed by another principal or officer of the Firm). The employee personal trading reviews ensure that the personal trading of employees does not affect the markets, and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, databases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction, and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that are managed and/or advised on (see Item 15—Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While we a certain custodian may be recommended, the client will decide whether to do so and will open your account with said custodian by entering into an account agreement directly with them. 14  Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting 15  Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each Client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many Clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in 16  accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. 17  Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed annually or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals, which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser has entered into several agreements where it solicits clients and refers them to third-party investment advisers. The Adviser will only refer clients to investment advisers that are registered with the Securities and Exchange Commission (SEC) or with the applicable state(s). Currently, the Adviser receive a split of management fees that ranges between 15% and 50%. The Adviser is required to present a disclosure to all prospects and clients which details the compensation to the Adviser and other general terms of the relationship between the third-party and the Adviser. The Adviser has clients and prospects sign this disclosure and return it to the third-party adviser. The agreement between the Adviser and the third-party adviser(s) may be terminated by either party’s written notice. Item 15 - Custody Custody Policy The Adviser does not accept physical custody of a client's securities. Clients will keep all account assets with the Custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate Qualified Custodian who will take possession of all account cash, securities, 18  and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the Custodian of record. The Adviser is not authorized to withdraw any money, securities, or other property from any client custodial account in the client's name or otherwise. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the Client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. 19  Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 20 

Item 1 – Cover Sheet Andersen Capital Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 10 Proctor St. Manchester-by-the-Sea, MA 01944 (617) 678-2002 www.andersencapitalmanagement.com March 28, 2025 This brochure provides information about the qualifications and business practices of Andersen Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at: (617) 678- 2002, or by email at: pandersen@andersencm.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222. 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 the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes This section describes material changes to Andersen Capital Management Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Andersen Capital Management’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request. Material Changes since the Last Update There have been no material changes since the last annual filing on March 27, 2025 2  Item 3 – Table of Contents Item 1 – Cover Sheet ........................................................................................................................................... 1 Item 2 – Material Changes ................................................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................... 3 Item 4 – Advisory Business ................................................................................................................................. 4 Item 5 – Fees and Compensation .......................................................................................................................... 5 Item 6 – Performance Fees ................................................................................................................................... 6 Item 7 – Types of Clients ..................................................................................................................................... 7 Item 8 – Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 7 Item 9 – Disciplinary Information ...................................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 10 Item 12 – Brokerage Practices............................................................................................................................ 11 Item 13 – Review of Accounts ........................................................................................................................... 14 Item 14 – Client Referrals and Other Compensation ........................................................................................... 15 Item 15 – Custody ............................................................................................................................................. 15 Item 16 – Investment Discretion ........................................................................................................................ 16 Item 17 – Voting Client Securities ..................................................................................................................... 16 Item 18 – Financial Information ......................................................................................................................... 16 3  Item 4 – Advisory Business Firm Description Andersen Capital Management, LLC (“the Advisor” or “Andersen Capital Management” or “Andersen”) is a dba of the registered entity Integrated Advisors Network, LLC (“Integrated”). Integrated was founded in 2015 and is an SEC registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides personalized investment management primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Advisor does not act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated’s Principal Owner is TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Types of Advisory Services The Advisor through Integrated provides investment management services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of February 29, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Andersen Capital Management is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Peter Andersen is an Investment Adviser Representative of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the Investment Adviser Representative utilizing the Advisor’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. 4  Types of Services Portfolio Management The Advisor through Integrated invests primarily in stocks of a selected group that is undervalued and manages clients on a fully discretionary basis. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service, and the agreement may be terminated by either party in writing at any time. WRAP Program The Advisor does not sponsor or provide investment management services to a WRAP program. Termination of Agreements A client may terminate any of the agreements at any time by notifying the Advisor in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client makes an advance payment, the Advisor will refund any unearned portion of the advance payment. The Advisor may terminate any of the agreements at any time by notifying the client in writing. If the client makes an advance payment, the Advisor will refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor’s fees are generally not negotiable, although the Advisor reserves the right to negotiate its fees. Although the Advisory Service Agreement is an ongoing agreement and adjustments may be required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance. The Advisor’s Fee is generally 1%. Performance Fees The Advisor may also charge a performance-based fee (the “Incentive Fee”) equal to a percentage of the realized and unrealized appreciation of the net asset value (“NAV”) of the client’s account (as reasonably determined in good faith by Advisor and as adjusted for any withdrawals or additions to the client’s account). Incentive Fees will only be charged to clients who meet the definition of “qualified client” under Rule 205-3(d) of the Investment Advisers Act of 1940 (the “Advisers Act”), as amended. All performance fee arrangements will be in accordance with Rule 205-3 under the Advisers Act. The Incentive Fee for the relevant period is negotiable and shall be described more fully in each Investment Management Agreement. Please refer to Item 6: Performance-Based Fees and Side-By-Side Management below for additional information about performance-based fees. Fee Billing Investment management fees will be billed quarterly in advance or arrears. Payment in full is expected upon invoice presentation. Account values are based on pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Integrated Fee Disclosure The clients of the Advisor will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. 5  Investment Advisor Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Andersen’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Andersen fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. Item 6 – Performance Fees As noted under Item 5: Fees and Compensation, in addition to or in lieu of Asset-Based Advisory Fees, the Advisor may charge performance-based fees (i.e., Incentive Fees) to certain clients. Such Incentive Fees will only be charged to clients who meet the definition of “qualified client” as defined in Rule 205-3(d) of the Advisers Act. All such fees will only be charged in accordance with the provisions of Rule 205-3 of the Advisers Act. Specifically, the Advisor may charge a periodic (either a quarterly or an annual) Incentive Fee equal to a percentage of the realized and unrealized appreciation of the NAV of the client’s account (as reasonably determined in good faith by the Advisor and as adjusted for any withdrawals from or additions to the account made during the period) as of the end of the immediately preceding period, as adjusted for withdrawals from and additions to the account during the period. The Incentive Fee is negotiable and may vary by account as detailed in each Investment Management Agreement. Performance-based compensation payable to the Advisor may be larger than otherwise would be the case if the fee was only an Asset-Based Advisory Fee because the amount of the Incentive Fee will be based on the account’s performance (which includes unrealized and realized gains and losses). Performance-based fee arrangements may result in a conflict of interest because the receipt of such performance-based compensation may create an incentive for the Advisor to (1) make investments that are riskier or more speculative than would be the case in the absence of a performance-based fee structure and (2) use margin and/or leverage in the client’s account. Such fee arrangements also may create an incentive for the Advisor to favor higher fee paying accounts over other accounts in the allocation of investment opportunities and could cause the portfolio manager to devote a disproportionate amount of time to the management of accounts that pay performance-based fees. The Advisor’s side-by-side management of accounts that are charged an Asset-Based Advisory Fee and accounts that are charged an Incentive Fee is governed by the Advisor’s internal policies and procedures, which are designed and implemented to ensure that all clients are treated fairly and equitably, and to prevent the conflicts described above from influencing the allocation of investment opportunities among clients. Performance-based fee structures could also create an incentive for the Advisor to overvalue certain assets held by clients. The Advisor has adopted policies designed to promote fair, accurate and current valuations of securities and portfolios. The Advisor utilizes, to the fullest extent possible, the most recent prices reported by the qualified custodians and/or largest securities exchange on which such securities are traded for timely valuation information for clients’ securities and portfolios. 6  Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations and corporations, or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $100,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include a company’s stock and bond price behavior, inspections of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, and other securities. The Advisor cannot guarantee that it will be successful in accurately predicting such movements. Andersen Capital Management’s Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through 7  sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness, or accuracy of such information and data, Advisor in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards; there may be less public information about the operations of issuers in such markets. 8  Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality. Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult advisers, counsel, and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. 9  Currency. 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. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information Mr. Andersen has not been subject to any disciplinary events. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Mr. Andersen does not have any investment-related business or occupation in which he is actively engaged. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Advisor may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Advisor on behalf of any client or is being considered for purchase or sale. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. 10  Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. The Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. 11  Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business 12  entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts, or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional 13  compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker, and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO and its IARs. Collectively, they review accounts at least once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives 14  and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 – Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. 15  Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and the Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 16 

Item 1 – Cover Sheet Candid Financial Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 13619 62nd Avenue NE Kirkland, WA 98034 (206) 941-7598 candidfinancial.com March 28, 2025 This brochure provides information about the qualifications and business practices of Candid Financial, LLC. If you have any questions about the contents of this brochure, please contact us at (206) 941-7598, or by email at sue@candidfinancial.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo@sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Candid Financial Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Candid Financial’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on March 27, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes ........................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................3 Item 4 – Advisory Business ......................................................................................................................................4 Item 5 – Fees and Compensation ..............................................................................................................................6 Item 6 – Performance Fees .......................................................................................................................................6 Item 7 – Types of Clients..........................................................................................................................................7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................7 Item 9 – Disciplinary Information ............................................................................................................................9 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................9 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Training ..........................9 Item 12 – Brokerage Practices ................................................................................................................................10 Item 13 – Review of Accounts ...............................................................................................................................12 Item 14 – Client Referrals and Other Compensation ..............................................................................................13 Item 15 - Custody ...................................................................................................................................................13 Item 16 – Investment Discretion .............................................................................................................................14 Item 17 – Voting Client Securities .........................................................................................................................14 Item 18 – Financial Information .............................................................................................................................14 3  Item 4 – Advisory Business Firm Description Candid Financial LLC is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser” or “Candid Financial”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides personalized investment advice primarily to individuals and families. Other clients may include pension and profit-sharing plans, trusts, estates, charitable organizations, corporations and business entities, individuals, and families. The Firm nor Integrated do not sell securities on a commission basis as an investment adviser. However, Integrated has some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Adviser does not have discretion of client accounts and places trades for clients with their approval. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning and consulting matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis Candid Financial is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Susan Katz and Amanda Klug are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment policy statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. 595-58-5770 Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives 4  change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. The Adviser may provide limited financial planning or other consulting services as part of its investment management services. To the extent specifically requested by a client, the Adviser may provide limited consultation services to its investment management clients on investment and non-investment related matters. Any such consultation services, to the extent rendered, shall be rendered exclusively on an unsolicited basis, for which the Adviser will not receive additional compensation. The client is under no obligation to act upon the Advisers recommendation. On occasion the Adviser will also provide free seminars related to financial planning, small business ownership, college savings, and other financial issues. These programs are designed to educate the public regarding their finances and the service offerings by the Adviser. Candid Financial provides investment Advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Candid Financial is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), and other securities as chosen by Candid Financial. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds and ETF’s is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Initial public offerings (IPOs) are not available through the Adviser as Investment Adviser Representatives. WRAP Program The Adviser does sponsor and provide investment management services to a WRAP program. The Adviser is the sponsor of the Candid Financial Program (the "Program"), a WRAP fee program. The Adviser provides its investment management services through the Program. In the event the client participates in the Program, the Adviser shall provide its investment management services and arrange for brokerage transactions under a market value of the assets being managed by the Adviser that includes all commissions. The Adviser receives this fee for the management services it provides to participants in the Program, who may pay a higher aggregate fee than if investment management and brokerage services are purchased separately. A complete description of the Program's terms and conditions (including fees) are contained in the Program's WRAP fee brochure. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. 5  Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in arrears. The investment management fees are non-negotiable. The account fee is 1% annually. Investment management fees will be billed and deducted quarterly immediately following the quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Integrated Fee Disclosure The clients of Candid Financial will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Candid Financials’ fees may be higher or lower than other advisory groups at Integrated and there is no representation that Candid Financials’ fees are the lowest available for similar services. Other Fees The client may incur additional fees from brokerages, custodians, administrators and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-Advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases, there may be fees charged which are a result of brokered trading activity by associated personnel of the Adviser that is outside of the constructs of the Adviser’s investment Advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client the fees may vary in size depending on the nature of the client’s requests. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. 6  For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, charitable organizations, and corporate and business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser does not have an account minimum. Other advisory groups of Integrated have minimum account sizes. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis method include fundamental analysis. The main sources of information include annual reports, prospectuses, filings with the Securities and Exchange Commission, company press releases, and research services. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities, along with the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Investment Activities. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and seeks independent corroboration, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the 7  Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the client. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards. There may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. 8  Regulatory Risks Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade manes and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Candid Financial. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Training Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated Advisors Network’s Chief Compliance Officer and requires the Chief Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated Advisor Network’s Chief Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Chief Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell 9  specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm do not receive preferential treatment. Item 12 – Brokerage Practices Brokerage/Custodian Selection and Soft Dollars The Adviser has the authority over the selection of the broker/custodian to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases, and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark- downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared 10  with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs 11  • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser does not aggregate orders. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser does not allow clients to direct brokerage. All trading is done at Fidelity. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. 12  Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, a summary of objectives, and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement 13  from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser does not contract for limited discretionary authority to transact portfolio securities accounts on behalf of clients. The Adviser does not have the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Adviser will consult with the client prior to each trade in order to obtain client approval for the transaction(s). Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 14 

Item 1 – Cover Sheet Sawyer Capital Investment Advisors Form ADV Part 2A – Firm Brochure 2231 Leyden St. Denver, CO 80207 (720) 231-4010 www.sawyercia.com March 28, 2025 This brochure provides information about the qualifications and business practices of Sawyer Capital Investment Advisors. If you have any questions about the contents of this brochure, please contact us at (720) 231-4010. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Sawyer Capital Investment Advisors Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. through the SEC’s Investment Adviser Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729- 4222 or by email at compliance@integratedadvisorsnetwork.com. Sawyer Capital Investment Advisors’ current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update Item 4 - Business Change of Location Effective September 2024, the business address for this Advisor was changed to 2231Leyden Street Denver, CO 80207. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................8 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................9 Item 9 – Disciplinary Information ............................................................................................................................12 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................14 Item 13 – Review of Accounts .................................................................................................................................17 Item 14 – Client Referrals and Other Compensation ...............................................................................................18 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................19 Item 17 – Voting Client Securities ...........................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisory Business Firm Description Sawyer Capital Investment Advisors is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser” or “Sawyer Capital”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides ongoing investment advisory and management services, with respect to investments in securities, financial instruments and/or other assets, to individuals, families and high net worth individuals, based on their individual needs. The Firm does not sell securities on a commission basis as part of its advisory services. However Integrated has some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated act as a custodian of client assets and the client always maintains asset control. The Adviser does have discretion of client accounts and does not require the consent of each client for all security trades. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s, Integrated or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Sawyer Capital Investment Advisors, LLC, is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network, LLC. Don Sawyer is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the Investment Adviser Representative utilizing the Adviser’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual 4  meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Sawyer Capital through Integrated offers discretionary portfolio management services. Investment advice is tailored to meet the clients' needs and investment objectives. If you retain our Firm for portfolio management services, Sawyer Capital will meet with you to determine your investment objectives, risk tolerance, and other relevant information at the beginning of our advisory relationship. If you participate in our discretionary portfolio management services, Sawyer Capital will require you to grant our Firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our Firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing Sawyer Capital with your restrictions and guidelines in writing. The Adviser may offer complimentary financial planning services as part of our portfolio management services. In limited circumstances and in our sole discretion, we may also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements with Sawyer Capital, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by Sawyer Capital on a non-discretionary basis. As part of our portfolio management services, in addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by our Firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our Firm. Initial public offerings (IPOs) are not available through Integrated. Financial Planning Sawyer Capital through Integrated offers financial planning services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad-based financial planning to consultative or single subject planning. If you retain our Firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our Firm and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our Firm if your financial situation, goals, objectives, or needs change. 5  You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage Firm. There is an inherent conflict of interest for Sawyer Capital whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Sawyer Capital or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Sawyer Capital nor Integrated do not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Sawyer Capital or use the services of Sawyer Capital in particular. WRAP Program The Adviser does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected quarterly in advance. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. Fee Schedule Annualized Investment Management Fees Incremental Account Value To Annual Percentage Fee Incremental Account Value From $0 $1,000,001 $1,000,000 Over 1.50% 0.90% Investment management fees will be billed quarterly in advance, based on an average daily balance. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. 6  If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. Financial Planning Fees We may charge a fixed fee for financial planning services, which generally ranges between $1500 - $3000. The fee is negotiable depending upon the complexity and scope of the plan, your financial situation, and your objectives. We do not require you to pay fees six or more months in advance and in excess of $500. Should the engagement last longer than six months between acceptance of financial planning agreement and delivery of the financial plan, any prepaid unearned fees will be promptly returned to you less a pro rata charge for bona fide financial planning services rendered to date. At our discretion, we may offset our financial planning fees to the extent you implement the financial plan through our Portfolio Management Service. You may terminate the financial planning agreement upon 30 days written notice to our Firm. If you have pre- paid financial planning fees that we have not yet earned, you will receive a prorated refund of those fees. If financial planning fees are payable in arrears, you will be responsible for a prorated fee based on services performed prior to termination of the financial planning agreement. Integrated Fee Disclosure The clients of Sawyer Capital will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Sawyer Capital’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Sawyer Capital’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund 7  expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Adviser is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to individuals and high net worth individuals. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums The Adviser in general, does not require a minimum dollar amount to open and maintain an advisory account; however, we have the right to terminate your account if it falls below a minimum size which, in our sole opinion, is too small to manage effectively. Some advisory groups of Integrated have minimum size account. 8  We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. Clients will be required to sign investment advisory agreements (and/or other contractual arrangements) that, among other things, set forth the nature and scope of our investment advisory and management authority, specific services, the investment objectives, guidelines, and restrictions applicable to the management of client accounts. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Sawyer Capital’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such 9  opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunity for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs, policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. 10  Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. 11  To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or LP interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. 12  Item 10 – Other Financial Industry Activities and Affiliations Affiliations Mr. Sawyer will also be working with ReDefine Independent Advisers as the Director of Investment Operations. He will assist RIA investment representatives with operational and administrative aspects related to custodian platforms. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Sawyer Capital. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. 13  Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases, and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. 14  Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part 15  of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional 16  compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. 17  Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. 18  Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet BURNS BLACKBURN GROUP Form ADV Part 2A – Firm Brochure (CRD # 171991/ SEC #801-96203) 2100 Palomar Airport Road Suite 214-11 Carlsbad, CA 92011 (760) 456-9526 curtis@burnsblackburngroup.com todd@burnsblackburngroup.com March 28, 2025 This brochure provides information about the qualifications and business practices of Burns- Blackburn Group, Inc. If you have any questions about the contents of this brochure, please contact us at (760) 456- 9526, or by email at curtis@burnsblackburngroup.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Burns-Blackburn Group, Inc. Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Burns-Blackburn Group’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801- 96203 or upon request through the client’s IAR. Material Changes since the Last Update There have been no material changes since the last update dated March 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ...............................................................................................................................................1 Item 2 – Material Changes ......................................................................................................................................2 Item 3 – Table of Contents ......................................................................................................................................3 Item 4 – Advisory Business ....................................................................................................................................4 Item 5 – Fees and Compensation ............................................................................................................................6 Item 6 – Performance Fees ......................................................................................................................................8 Item 7 – Types of Clients ........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................8 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 ........................13 Item 12 – Brokerage Practices ..............................................................................................................................14 Item 13 – Review of Accounts ..............................................................................................................................18 Item 14 – Client Referrals and Other Compensation ............................................................................................18 Item 15 - Custody ..................................................................................................................................................18 Item 16 – Investment Discretion ...........................................................................................................................19 Item 17 – Voting Client Securities ........................................................................................................................19 Item 18 – Financial Information ............................................................................................................................19 3  Item 4 – Advisory Business Firm Description Burns-Blackburn Group Inc. is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter (“the Advisor” or “Burns-Blackburn”). Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Advisor is a fee-only investment management and financial planning firm. The Advisor provides personalized investment advice primarily to individuals and high net worth individuals directly. The Firm does not sell securities on a commission basis as an investment adviser. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Advisor nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Burns-Blackburn is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network, LLC. Todd Blackburn and Curtis Burns are Investment Advisor Representatives (“IARs”) of Integrated Advisors Network, LLC. They share 50-50% ownership in the Burns-Blackburn Group. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an 4  annual meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Burns-Blackburn through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Burns-Blackburn is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Burns-Blackburn. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds and ETFs is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Initial public offerings (“IPOs”) are not available through Integrated. Financial Planning Burns-Blackburn through Integrated will typically provide a variety of financial planning services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning, charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Burns- Blackburn may also refer clients to an accountant, attorney or other specialist. For planning engagements, the Advisor will provide a summary of client’s financial situation, observations, and recommendations. For consulting engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Burns-Blackburn whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Burns-Blackburn or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Burns- Blackburn nor Integrated do not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Burns-Blackburn or use the services of Burns-Blackburn in particular. 5  Retirement Plan Consulting Services Burns-Blackburn provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing, and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, including, but not limited to, the following services: Plan Design and Strategy; Plan Fee and Cost Analysis; Plan Review and Evaluation; Retirement Plan Committee Consults; Executive Planning and Benefits; Fiduciary and Compliance; Investment Management and Review; Investment Management and Review; and Legacy Plan Services. As disclosed in the Agreement, certain of the foregoing services are provided by Burns-Blackburn through Integrated as fiduciaries under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of the fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. WRAP Program The Advisor does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client makes an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client makes an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the month completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The fee varies from 40 basis points (.40%) up to 150 basis points (1.50%). In certain instances, the Firm may charge a fixed fee for investment management and wealth management services. These fees are negotiable, but generally range from $1,000 to $30,000 on a fixed fee basis. Investment management fees will be billed quarterly in advance. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. 6  Financial Planning Fees and Retirement Consulting Fees Burns-Blackburn generally charges as fixed project-based fee to provide clients with retirement plan consulting services. Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor, as memorialized in the Agreement. These fees vary, based on the scope of the services to be rendered. In those situations where Burns-Blackburn has agreed to manage a plan’s assets, the Firm may also charge an annual asset-based of 50 and 150 basis points (0.50% – 1.50%), depending upon the amount of assets to be managed. Financial Planning for clients, which includes complex situations, is provided under a fixed fee arrangement agreed upon at the first meeting and billed monthly. These services can either be provided based on a range of $250-$2000 fixed fee or Burns-Blackburn may charge a $200 hourly fee for consultation and planning. FINANCIAL PLANNING Portfolio/Investments/Review Retirement/Financial/Planning Hourly/Consulting/and Planning $250 $250 – $2000 $200 per hour Integrated Fee Disclosures The clients of Burns-Blackburn will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Burns-Blackburn’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Burns-Blackburn’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred because of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisors selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The Advisor, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Advisor will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. 7  If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases, there may be fees charged which are a result of brokered trading activity by associated personnel of the Advisor that is outside of the constructs of the Advisor’s investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client the fees may vary in size depending on the nature of the client’s requests. Conflict of Interest Between Different Fee Structures The Advisor offers several different services detailed in this brochure that compensate the Advisor differently depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Advisor mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Advisor is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $200,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, 8  research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Burns-Blackburn’s Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which 9  may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs, policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rates the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. 10  • Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities, and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. 11  Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interests. In the administration of client accounts, portfolios and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information Burns-Blackburn has not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients before their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations Associated persons of Integrated Advisors Network are registered representatives of a broker-dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated Advisors Network are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors Network. Integrated Advisors Network does not make any representation that the brokerage services are at the lowest cost available and clients may be able to obtain those 12  services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated Advisors Network. Integrated Advisors Network mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Burns- Blackburn. Insurance Affiliations Burns-Blackburn and/or certain associated persons of Burns-Blackburn sell insurance products to advisory clients. Burns-Blackburn offers insurance products that are associated with an insurance company with which Burns-Blackburn has established a relationship. Insurance products include variable annuities, life, health, long term care, and general agency insurance. The Advisor earns commissions on these insurance products in addition to any fees earned from financial planning, investment management or other services offered. The commissions are based on the standard commission schedule of the provider of the insurance products and are generally not negotiable. The clients who purchase insurance related products are informed that Burns-Blackburn or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that Burns-Blackburn and/or the associated persons sells insurance products to clients of Burns-Blackburn and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. Insurance related products are excluded from investment advisory management fees. Burns-Blackburn makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from Burns-Blackburn or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Burns-Blackburn. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. 13  Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Advisor, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Advisor, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage/Custodian Selection and Soft Dollars The Advisor has the authority over the selection of the broker/custodian to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark- downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell 14  securities when instructed to. While we a certain custodian may be recommended, the client will decide whether to do so and will open your account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting 15  Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. 16  • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, • the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as others whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. 17  Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be 18  on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that instructions be submitted to the custodian to remit a specific dollar amount from the account to the designated third- party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Advisors discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet Select Wealth Advisers Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) Nevada Office 2200 Paseo Verde Pkwy STE 210 Henderson, NV 89052 Memphis Office 6075 Poplar Ave. STE 406 Memphis, TN 38119 (702) 888-3280 www.selectwealthadvisers.com March 28, 2025 This brochure provides information about the qualifications and business practices of Select Wealth Advisers (“SWA”). If you have any questions about the contents of this brochure, please contact us at: (702) 888-3280 or by email at: mhorst@swadvisers.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Select Wealth Advisers Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Select Wealth Advisers’ current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update Item 5 – Fees & Compensation was updated effective July 29, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet.............................................................................................................................. 1 Item 2 – Material Changes ..................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................... 3 Item 4 – Advisory Business.................................................................................................................... 4 Item 5 – Fees and Compensation ............................................................................................................ 7 Item 6 – Performance Fees ................................................................................................................... 10 Item 7 – Types of Clients ..................................................................................................................... 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 11 Item 9 – Disciplinary Information ........................................................................................................ 14 Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 14 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 15 Item 12 – Brokerage Practices .............................................................................................................. 16 Item 13 – Review of Accounts ............................................................................................................. 21 Item 14 – Client Referrals and Other Compensation ............................................................................. 21 Item 15 - Custody ................................................................................................................................ 21 Item 16 – Investment Discretion .......................................................................................................... 22 Item 17 – Voting Client Securities ....................................................................................................... 22 Item 18 – Financial Information ........................................................................................................... 22 3  Item 4 – Advisory Business Firm Description Select Wealth Advisers is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter (the “Adviser” or “SWA”). Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC-registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides ongoing investment advisory, asset management, financial planning, and consulting services with respect to investments in securities, financial instruments and/or other assets, to individuals, high net worth individuals, trusts, estates, or charitable organizations, banking or thrift institutions, state or municipal government entities, pension and profit sharing plans, and corporations or other business entities directly, based on their individual needs. The Adviser nor Integrated do not sell securities on a commission basis as part of its advisory services. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Adviser is not affiliated by ownership with entities that sell financial products or securities. The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser does have discretion of client accounts and does not require the consent of each client for all security trades. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Select Wealth Advisers is a dba of Integrated Advisors Network, LLC. All advisory services are offered through Integrated Advisors Network LLC. Mitchell Horst, James Burdett, Mark Bailey and Scott Lipka are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. 4  Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client, which often includes an annual meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service, and they may be terminated by either party in writing at any time. Asset Management Select Wealth Advisers through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. The Adviser is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds, and other share classes), options, exchange-traded funds (“ETFs”), leveraged ETFs, alternative investments, and other securities as chosen by Select Wealth Advisers. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created, and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Financial Planning and Consulting Our Financial Professionals through Integrated may provide advisory services in the form of financial planning or consulting services. Financial planning and/or consulting services do not involve the active management of client accounts. Financial planning can be described as helping individuals determine and set their long-term financial goals through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. Consulting services include consulting clients in the management of their money, investment options and asset reallocation. Consulting services can be narrow in scope and not take into consideration all areas of a client’s financial situation. If you decide to sign up for financial planning or consulting services you will be required to execute the appropriate SWA agreement. Upon execution of the agreement, your Financial Professional will provide verbal or written recommendations, depending on the investment advisory services selected and mutually agreed upon. Financial planning services will take into consideration either individually or a combination of information such as your objectives, overall financial situation, personal and financial goals, risk tolerance and objectives, risks that you are willing to undertake, investment knowledge, net worth, income, age, projected retirement, unusual or material funding requirements, inheritance possibilities, pensions social security, children/relative funding issues, estate issues, and living expenses expressed in today’s dollars requested for retirement. Based on the data and information compilation, financial planning recommendations are made based on your individual needs. Topics included as part of financial planning services provided can include, but are not limited to, one or more of the following: Portfolio Review and Evaluation; Retirement Account Analysis; Cash Flow and Net Worth Analysis; 5  Risk Management Analysis; Budgeting; Planning for Family Member Special Needs; Divorce Planning; Developing a Comprehensive Documented Financial Plan; Retirement Planning; Education Funding Planning; Review of Medical, Disability, and Other Insurance; Estate Analysis and Planning; Financial Planning and Education Seminars. Financial Professionals also provide financial planning services to business entities and groups requesting educational services and financial planning seminars or individual consulting and planning services to be provided to employees or members. If individual planning or consulting services will be provided, each participating employee or member will be required to execute a separate agreement with SWA depending on the services being provided. Financial Professionals are allowed to provide financial planning seminars. Such services are provided on an impersonal basis, which means topics covered are general in nature and do not purport to focus on the individual needs of the seminar participants. Topics covered in a seminar can include the items listed above. Financial Professionals charge a fee for participation in seminars. When fees charged are equal to or in excess of $500/per attendee, each attendee of the seminar will be provided a copy of this Disclosure Brochure. In addition to providing documented financial plans, Financial Professionals provide investment consulting services. Consulting services are provided focusing on your specific areas of concern. These services can include retirement plan consulting services provided to an individual client seeking advice on how their retirement plan investments should be allocated. Financial Professionals may also provide investment consulting services on accounts not managed or maintained by SWA. Only accounts for which a Financial Professional is not the Registered Representative of record or does not have trading authorization on the account are eligible for this service. Such accounts include, but are not limited to, 401(k) accounts and pension plan accounts not held at SWA. You will be responsible for all trade implementation under this service. Financial Professionals will not have access to your funds, securities, or account(s) and therefore will not have authority to rebalance, reallocate or trade in the account(s). If you decide to sign up for this service, your selected accounts will be reviewed based upon your specific needs and desires for future financial goals and/or objectives. General or specific recommendations will be provided by your Financial Professional. Fees can be paid in a variety of options determined between yourself and your Financial Professional. Annuities SWA offers investment management services for various approved annuities. Financial Professionals can manage the sub-accounts of those annuities either on a discretionary or non-discretionary basis. Your Financial Professional will provide ongoing investment advice based on your investment objectives, risk tolerance, options available under the annuity contract, and any other benefits and features under the annuity contract. A conflict of interest is present as your Financial Professional receives a fee for the advice provided to you, however, not all annuity products are approved for investment management services. There could be other annuity products suitable for you that are more or less costly. WRAP Program The Adviser does not sponsor or provides investment management services to WRAP programs. Other IARs under other group names at Integrated do offer wrap programs. Financial Wellness Firms can contract with a Financial Professional to provide financial wellness and services to its employees through Financial Wellness Consulting. When working with the firm’s employees, Financial Professionals provide various services such as assistance and education regarding budgeting and goal setting, financial wellness education presentations and personal financial wellness assessments. 6  If you engage in Financial Wellness Services, you will be required to execute the appropriate SWA agreement. The exact services provided are pre-determined by the employer and further documented and agreed to in the appropriate SWA agreement. Upon execution of the agreement your Financial Professional will provide the services agreed upon in the agreement. Employers contract a Financial Professional to provide individualized recommendations or non-individualized services to employees. The individualized advice can include the following: Personal Financial Wellness Assessments; Retirement Plan Participant Investment Advice. The non-individualized (education) services can include the following: Assistance and Education (Regarding Budgeting, Goal Setting, and Savings Tools); Financial Wellness Education Services. Termination of Agreements Please keep in mind that we have the right to refuse any Agreement submitted for approval. If the appropriate disclosure statement (i.e., this document or a separate written disclosure statement containing the same information as this document) is not delivered to you at least 48 hours prior to entering into a Program Agreement, you have the right to terminate services without penalty (i.e., full refund of all fees paid in advance or in the event fees are billed in arrears, no fees shall be due) within five (5) business days after entering into the Agreement. For purposes of this provision, an Agreement is considered entered into when all parties have executed the Agreement. All services continue in effect until terminated by either party (i.e., you or SWA) by giving notice to the other party. Written notice is required for investment management programs unless all parties mutually agree on an earlier termination date. Any prepaid, unearned fees are promptly refunded to you. If termination of the Program Agreement occurs after five (5) days from account opening, we may retain up to $500 of the prepaid Account Fee for the current quarter. Fee refunds will be determined on a pro rata basis using the number of days services are actually provided during the final period. Fee refunds calculated to be less than $25 generally will not be processed. Upon termination of the Agreement, your account will convert to a brokerage account and transactions in the converted account are processed at normal brokerage rates. Termination of the Agreement does not affect the liabilities or obligations of the parties from transactions initiated prior to termination. Upon actual receipt of notice of termination, our obligation to manage or advise you with respect to the account immediately terminates. This means that unless we receive instructions from you, we will not buy, sell, reallocate, or rebalance Funds in the converted account. IRA and 403(b)(7) accounts remain subject to the provisions and restrictions of regulations, law and the custodial Agreement. Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance; therefore, at termination, any unearned fees as determined on a pro-rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser, and fees for comparable services may be available from other sources. Investment management fees will be billed quarterly in advance. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. 7  FEE SCHEDULE Annualized Investment Management Fees Incremental Account Value From Incremental Account Value To Annual Percentage Fee $0 $249,999 1.75% $250,000 $499,999 1.50% $500,000 $999,999 1.25% $1,000,000 $1,499,999 1.00% $1,500,000 0.90% $1,999,999 Over $2,000,000 Negotiable Annualized Financial Planning Fees with Managed Portfolio Incremental Account Value From Incremental Account Value To Annual Percentage Fee $0 $499,999 0.15% $500,000 $999,999 0.10% Over $1,000,000 No Cost Annualized Financial Planning Fees without Managed Portfolio Plan Construction $1,500.00 Annual Maintenance $700 ($175 drafted quarterly) Strategy Planning $125/hour Financial Planning and Consulting Fees for Financial Planning and Consulting services can be paid through a variety of options determined by you and your Financial Professional. The fee arrangement should be expressed on the appropriate SWA Agreement. The fee options include the following: Flat Fee Agreement The fee will vary depending on a variety of factors, depending on the scope of services provided, complexity of the process undertaken, the types of issues addressed and the frequency of services. Flat fees charged for financial planning services generally do not exceed $25,000 for individuals. Frequency of payment can be one-time, installment or ongoing at a frequency agreed upon by you and your Financial Professional. Hourly Fee Agreement Financial Professionals are generally not allowed to charge more than $500 on an hourly basis. Asset Based Fee Agreement Investment Consulting services provided based on assets held outside of SWA fall under an Asset Based Fee Agreement. The fee for such services will be a percentage of all assets being managed by the Financial Professional. Financial Planning fees described above do not include the fees you will incur for other professionals (i.e. personal 8  attorney, independent Investment Adviser, or accountant) in connection with the financial planning process. In some instances, fees higher than those stated above will be charged if the scope of the project agreed upon warrants a higher fee. All fees are negotiable and are agreed upon prior to entering into a contract. When the contracted services include providing a physical or electronic document, you will generally receive your financial plan within 90 days of entering into a financial planning contract, provided that all information needed to prepare the Financial Plan has been promptly provided by you. Fees for ongoing financial planning services are due in accordance with the timeframe agreed upon between you and your Financial Professional. The exact fee you will be charged is contingent upon the nature and complexity of your overall financial circumstances. The contract will automatically renew on an annual basis, unless agreed upon to be a one-time service. The investment advisory fee will be divided and billed on a quarterly basis. You and your Financial Professional have the option to choose to have a one-time fee instead of the above billing options. Fees are charged in advance or in arrears depending on the specific arrangement. The contract will automatically renew on an annual basis unless agreed upon to be a one-time fee. Certain charges are imposed by third parties other than SWA in connection with investments recommended through consulting arrangements, including but not limited to, mutual fund and custodial fees. Consulting fees charged by SWA are separate and distinct from the fees and expenses charged by investment company securities that are recommended to you. A description of these fees and expenses are available in each investment company product prospectus. Financial Professionals have the option to waive agreed upon financial planning or consulting fees and expenses if you purchase products or enter into agreements for other services with the Financial Professional. You and the Financial Professional preparing the financial plan or providing the consultation services will determine the exact fee and the manner in which the fee is to be paid. Financial Professionals negotiate fees with each of their clients based on the complexity of that client’s personal circumstances, financial situation and the services that will be provided, the scope of the engagement, the client’s income, the experience and standard fees charged by the Financial Professional providing the services, and the nature and total dollar asset value of the asset upon which services will be provided. In addition, fees may be negotiated based on whether or not the client has assets under management with the Financial Professional. A conflict could arise if ongoing compensation paid for services based on assets under management surpass the negotiated or waived financial planning or consulting services fee. Termination Provisions A client may terminate advisory services obtained from Select Wealth Advisers, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with Select Wealth Advisers. Thereafter, the client may terminate investment advisory services with written notice to Select Wealth Advisers. Client will be responsible for any time spent by Select Wealth Advisers. If fees were paid in advance, the client will be refunded a prorated portion of the advisory fee. Integrated Fee Disclosure The clients of SWA will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. SWA’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that SWA’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. 9  The Adviser’s services are charged on a fee-only basis, and no associated persons shall earn compensation based on a securities transaction (i.e., commission), including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisors selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios, so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Adviser is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to individuals, high net worth individuals, trusts, estates, or charitable organizations, banking or thrift institutions, state or municipal government entities, pension and profit-sharing plans, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums SWA typically imposes a minimum investment amount of $25,000. SWA will accept accounts with less than $25,000 in assets if SWA believes that, based on information provided by you to your Financial Professional, investing a lower amount is appropriate for you and is acceptable to the program sponsor. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. 10  Clients will be required to sign investment advisory agreements (and/or other contractual arrangements) that, among other things, set forth the nature and scope of our investment advisory and management authority, specific services, and the investment objectives, guidelines, and restrictions applicable to the management of client accounts. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor, which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive, and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staff. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. SWA’s Investment Activities. The Adviser’s investment activities involve an element of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser may invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. 11  Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies, or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed-income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flow from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. 12  Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. 13  Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel, and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities, where there is a ready market that is traded through an exchange, are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in the price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or LP interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations Associated persons of Integrated Advisors Network are registered representatives of a broker-dealer. They may 14  offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated Advisors Network are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors Network. Integrated Advisors Network does not make any representation that the brokerage services are at the lowest cost available and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated Advisors Network. Integrated Advisors Network mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Insurance Affiliations SWA and /or certain associated persons of SWA sell insurance products to advisory clients. The clients who purchase insurance-related products are informed that SWA or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that SWA and/or the associated persons may sell insurance products to clients of SWA and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. SWA makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from SWA or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by SWA. Our Firm offers services through our network of investment advisor representatives (“Investment Adviser Representatives” or “IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of our Firm, Integrated Advisors Network. The IARs are under the supervision of our Firm, Integrated Advisors Network, and the advisory services of the IAR are provided through our Firm, Integrated Advisors Network. Our Firm, Integrated Advisors Network, has the arrangement described above with the following Advisor Representatives of: Select Wealth Advisers. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest 15  personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers, and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading From time-to-time SWA or one or more of its supervised persons purchases or owns the same securities and investments that SWA recommends to you. The fact that some SWA supervised persons have personal accounts is a conflict of interest due to the potential that a Financial Professional devotes more time to monitoring Financial Professionals personal accounts as opposed to spending that time on the review and monitor of your accounts. In addition, there is a potential that Financial Professionals favor their personal accounts over your accounts. When the recommendation to you involves individual stocks, stock options, bonds and other general securities there can be a conflict of interest with you because the Financial Professional has the potential to engage in practices such as front- running, scalping, and other activities that are potentially detrimental to clients. SWA has adopted policies and procedures to ensure that such conflicts are fully disclosed and that neither SWA, nor its supervised persons trade ahead of or otherwise against the interest of you. It is the policy of SWA that the interest of clients’ accounts are placed ahead of the interests of SWA accounts and personal accounts of SWA Supervised persons. SWA’s supervised persons cannot effect for himself or herself, or his or her immediate family (i.e., spouse, minor children, and adults living in the same household as the associated person), or for trusts for which the supervised person serves as trustee or in which the associated person has a beneficial interest, any transactions in a security which is published on the SWA Restricted Trading List on behalf of any of SWA’s clients without prior approval from the Chief Compliance Officer or his/her designee. The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. The Advisor is not required to negotiate "execution-only" commission rates; thus, the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker, which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies, and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, databases, and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is 16  understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Best Execution As a fiduciary, SWA owes a fiduciary duty to its clients to obtain best execution of their transactions. That duty puts forth that an investment adviser generally must execute securities transactions in such a manner that the total cost or proceeds in each transaction is the most favorable under the circumstances. However, clients must understand that best execution does not necessarily mean the lowest available price. Instead, the totality of the arrangement and services provided by a broker-dealer must be examined to determine a qualitative measure of best execution. Based on these principles, commission and fee structures of various broker-dealers are periodically reviewed by the Best Execution Committee in order to evaluate the execution services provided by Cambridge and all of the unaffiliated broker-dealers and custodians used by SWA. Accordingly, while SWA does consider competitive rates, it does not necessarily obtain the lowest possible commission rates for client account transactions. Therefore, the overall services provided by SWA and all of the unaffiliated broker-dealers and custodians are evaluated to determine best execution. Trade Aggregation Transactions implemented by SWA for client accounts are generally effected independently, unless a Financial Professional decides to purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading or block trading and is used by a Financial Professional when the Financial Professional believes such action proves advantageous to clients. When Financial Professionals aggregate client orders, the allocation of securities among client accounts will be done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to achieve better execution or to allocate orders among clients on a more equitable basis by avoiding differences in prices that might be obtained when orders are placed independently. While there is more than one process for allocating, generally the transactions will be averaged as to price and will be allocated among the Financial Professional’s clients in proportion to the purchase and sale orders placed for each client account on any given day. It should be noted, SWA does not allow Financial Professionals to receive any additional compensation or remuneration as a result of aggregation. Because SWA does not require Financial Professionals to aggregate trades, not all trades are aggregated even when there is an opportunity to do so. When trades are not aggregated, clients will not always see the effects of lower commission per share costs that often occurs as a result of aggregating trades and as a result, pay a higher transaction cost than could be received elsewhere. Finally, it should be noted that SWA does not aggregate mutual fund transactions. Handling of Trade Errors It is SWA’s policy to ensure trading errors are handled and corrected in a timely manner in the best interests of the client affected by the error. Specifically, when SWA causes a trade error to occur in a client account that results in a loss, SWA works with the relevant broker-dealer or custodian in order to reimburse any costs paid by the client, and make whole the client transaction as it should have originally taken place/or not taken place. All trade errors should be corrected within a reasonable period of time following discovery of the error. SWA will not use commissions from client accounts to correct trade errors. It is the strict policy of SWA that Financial Professionals are not permitted to make payments to clients or to client accounts. Research and Other Benefits Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated 17  works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker- dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) 18  • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share 19  price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account, or fund as detailed in any written agreement. No additional compensation shall result from the proposed allocation. No client/investor, account, or fund will be favored over any other client/investor, account, or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts, or funds are required prior to any allocated order. The basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any possible commission discounts that might otherwise be available as a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker-dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage, but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances, a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms that do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts, which may result in less favorable security prices and/or higher transaction costs. 20  Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account, and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals, which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Advisor has entered into agreements where it solicits clients and third-party investment advisers refers clients. The Advisor pays for these referrals. The Advisor is required to present a disclosure to all prospects and clients which details the compensation to the third-party and other general terms of the relationship between the third-party and the Advisor. This disclosure is provided by either the third-party or the Advisor. The agreement between the Advisor and the third-party adviser(s) may be terminated by either party’s written notice. Item 15 - Custody Custody Policy The Adviser does not generally accept or permit the Firm or its associated persons from obtaining custody of client assets, including cash, securities, acting as a trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. Advisor takes custody of assets as it relates to High Timber Vacation Homes, LLC. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated 21  third party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians, and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such a document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may, however, be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of businesses or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used, and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to, and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 22 

Item 1 – Cover Sheet Miller Pacific Financial Advisors Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 80 Sir Francis Drake Blvd. Suite 3A Larkspur, CA 94939 (415) 524-8089 www.millerpacadvisors.com March 28, 2025 This brochure provides information about the qualifications and business practices of Miller Pacific Financial Advisors. If you have any questions about the contents of this brochure, please contact us at (415) 524-8089, or by email at leslie@millerpacadvisors.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Miller Pacific Financial Advisors Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Miller Pacific Financial Advisors’ current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_ Search.aspx, SEC# 801-96203 or upon request through the client’s advisor. Material Changes since the Last Update Item 5, Financial Planning Fees were updated in July 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................8 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................9 Item 9 – Disciplinary Information ............................................................................................................................12 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................13 Item 13 – Review of Accounts .................................................................................................................................17 Item 14 – Client Referrals and Other Compensation ...............................................................................................17 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ...............................................................................................................................18 Item 17 – Voting Client Securities ............................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisory Business Firm Description Miller Pacific Financial Advisors is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser” or “Miller Pacific”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations and corporations, or other business entities directly. The Firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has associated persons who are in other fields where they receive commissions as compensation. The Adviser is not affiliated by ownership with entities that sell financial products or securities. Neither the Adviser nor Integrated act as a custodian of client assets and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s, Integrated, or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Miller Pacific Financial Advisors is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network, LLC. Leslie Miller is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IAR utilizing the Adviser’s programs. Investment Policy Statements may also be created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a 4  client’s financial situation and portfolio through regular contact with the client, which often includes an annual meeting with the client. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided. The fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Miller Pacific through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Miller Pacific is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), exchange-traded funds (“ETFs”), SMAs, options, warrants, real estate investment trusts (“REITs”), alternative investments, and other securities as chosen by Miller Pacific. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load- waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Initial public offerings (IPOs) are not available through Integrated. Financial Planning Miller Pacific through Integrated will typically provide a variety of financial planning services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning, charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Miller Pacific may also refer clients to an accountant, attorney, or other specialist. For financial planning engagements, Adviser will provide a summary of client’s financial situation, observations, and recommendations. For financial consulting engagements, Adviser may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested from or on behalf of the client are provided promptly. There is an inherent conflict of interest for Miller Pacific whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Miller Pacific or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Miller Pacific nor Integrated make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Miller Pacific or use the services of Miller Pacific in particular. Wealth Coaching, Second Opinions & Financial Analysis Fees Miller Pacific may provide coaching services that typically do not include investment advisory or management services, financial planning services, nor the review or monitoring of a client's investment portfolio. The Adviser 5  may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Adviser. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Adviser if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Adviser’s previous recommendations and/or services. WRAP Program The Adviser does not sponsor or provide investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected quarterly in advance; therefore, at termination any unearned fees as determined on a pro rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and lower fees for comparable services may be available from other sources. This fee includes standard financial planning for Households with Assets Under Management above $700,000. Household Assets Under Management Annual Fee $100,000 - $249,000 $250,000 - $499,999 $500,000 - $999,999 $1,000,000 - $1,999,999 $2,000,000 - $4,999,999 Above $5,000,000 1.35% 1.20% 1.00% 0.85% 0.60% Fixed Fee 6  Financial Planning Fees Financial Planning for clients without $700,000+ assets under management and for complex situations is provided under a fixed or hourly fee arrangement agreed upon at the first meeting and based on hourly rates of $300 for professionals, $150 for paraprofessionals, and $40 for administrative services. Twenty-five percent of the fee is payable in advance before the financial planning process is started. The remainder is payable during the engagement. The financial planning fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. Wealth Coaching, Second Opinions & Financial Analysis Fees MPFA provides a range of education, coaching, and analysis services including "second opinions" on existing investment portfolios. These services are provided based on an hourly rate of $300 for professionals, $150 for paraprofessionals, and $40 for administrative services. A retainer fee is payable at initiation of project and the balance is payable monthly as invoiced. Fee Collection Investment management fees will be collected quarterly in advance. Fees are deducted from client accounts as authorized by the investment management agreement. Fees are calculated based on the asset value of accounts on the last day of the previous quarter. Account values are determined based upon information supplied by the client’s third- party qualified custodians, where their accounts are held. Integrated Fee Disclosure The clients of Miller Pacific Financial Advisors will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Miller Pacific Financial Advisors’ fees may be higher or lower than other advisory groups at Integrated and there is no representation that Miller Pacific Financial Advisors fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, individual bonds, private investments and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an 7  initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Adviser is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser generally provides investment advice to investment advisory firms or individual Investment Adviser Representatives (that may be other IARs at Integrated Advisor Network LLC). The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations and corporations, or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than are disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $500,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. 8  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser’s investments substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Miller Pacific’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data, and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness, or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. 9  Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies, or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies, or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds, or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. 10  Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value, or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards. There may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. 11  Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel, and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments, and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information Miller Pacific and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. 12  Item 10 – Other Financial Industry Activities and Affiliations Our firm offers services through our network of investment advisor representatives ("Advisor Representatives" or "IARs"). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The Client should understand that the businesses are legal entities of the IAR and not of our firm Integrated Advisors Network. The IARs are under the supervision of our firm Integrated Advisors Network. Our firm Integrated Advisors Network has the arrangement described above with the following Advisor Representatives: Miller Pacific Financial Advisors does not have any other financial industry activities or affiliations. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer, and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. 13  In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark- downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”), and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While we a certain custodian may be recommended, the client will decide whether to do so and will open your account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.),breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. 14  Products and Services Available Schwab and Fidelity provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab and Fidelity without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waive their fees for some of these services or pay all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits 15  from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any possible commission discounts that might otherwise be available a result of the aggregated trade. 16  Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least an annual basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The Firm does not compensate referring parties for these referrals. 17  Solicitor Referrals The Adviser has entered into agreements where it solicits clients and refers them to third-party investment advisers. The Firm will only refer clients to investment advisers that are registered with the Securities and Exchange Commission (SEC) or with the applicable state(s). The Adviser is required to present a disclosure to all prospects and clients which details the compensation to the Adviser and other general terms of the relationship between the third-party and the Adviser. The Adviser has clients and prospects sign this disclosure and return it to the third- party adviser. The agreement between the Adviser and the third-party adviser(s) may be terminated by either party’s written notice. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons to obtain custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity, or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions 18  in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client and six months or more in advance. 19 

Item 1 – Cover Sheet MILITELLO WEALTH MANAGEMENT Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 650B Pierce Blvd. O'Fallon, IL 62269 (314) 655-2118 www.milwm.com March 28, 2025 This brochure provides information about the qualifications and business practices of Militello Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us by telephone at (314) 655-2118, or by email at rickm@milwm.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Militello Wealth Management Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Militello Wealth Management’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update A change to Militello’s Florida address has been made since the last annual filing on March 31, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet............................................................................................................................................ 1 Item 2 – Material Changes ................................................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................... 3 Item 4 – Advisory Business .................................................................................................................................. 4 Item 5 – Fees and Compensation .......................................................................................................................... 6 Item 6 – Performance Fees ................................................................................................................................... 9 Item 7 – Types of Clients ..................................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................. 9 Item 9 – Disciplinary Information ...................................................................................................................... 13 Item 10 – Other Financial Industry Activities and Affiliations............................................................................. 13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 14 Item 12 – Brokerage Practices............................................................................................................................ 14 Item 13 – Review of Accounts ........................................................................................................................... 18 Item 14 – Client Referrals and Other Compensation ........................................................................................... 18 Item 15 - Custody .............................................................................................................................................. 19 Item 16 – Investment Discretion ......................................................................................................................... 19 Item 17 – Voting Client Securities ...................................................................................................................... 19 Item 18 – Financial Information ......................................................................................................................... 20 3  Item 4 – Advisory Business Firm Description Militello Wealth Management, LLC., is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter "the Advisor" or “Militello Wealth". Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides personalized investment advice primarily to high-net-worth individuals and institutional clients such as pension and profit-sharing plans. The firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has associated persons who are in other fields where they receive commissions as compensation. The Advisor is not affiliated by ownership with entities that sell financial products or securities. The Advisor nor Integrated does not act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor's or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning and consulting matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Militello Wealth is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Richard Militello is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing the Advisor's programs. Investment Policy Statements may also be created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client's financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client's financial situation and portfolio through regular contact with the client which often includes an 4  annual meeting with the client. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. The Advisor may provide limited financial planning or other consulting services as part of its investment management services. To the extent specifically requested by a client, the Advisor may provide limited consultation services to its investment management clients on investment and noninvestment related matters. Any such consultation services, to the extent rendered, shall be rendered exclusively on an unsolicited basis, for which the Advisor will not receive additional compensation. The client is under no obligation to act upon the Advisor’s recommendation. On occasion the Advisor will also provide free seminars related to financial planning, small business ownership, college savings and other financial issues. These programs are designed to educate the public regarding their finances and the service offerings by the Advisor. Militello Wealth through Integrated provides investment advisory services to clients that are tailored to the clients' needs based on their financial situation and investment objectives. Militello Wealth is mindful of each client's financial situation, endeavoring to ensure that the client's investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients' needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts ("REITs"), exchange-traded funds ("ETFs"), alternative investments, and other securities as chosen by Militello Wealth or a third-party manager. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds and ETFs is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Initial public offerings (IPOs) are not available through Integrated. Retirement Plan Consulting Services The Advisor through Integrated offers retirement consulting services to employee benefit plans and their fiduciaries. The services are designed to assist the plan sponsor (the "Company") in meeting its management and fiduciary obligations to the plan under ERISA. Retirement consulting services will consist of general or specific advice, and includes any one or all of the following: 1. Platform Provider Search and Plan Set-up 2. Strategic Planning and Investment Policy Development/Review 3. Plan Review 4. Plan Fee and Cost Review 5. Acting as Third-Party Service Provider Liaison 6. Assessment of Plan Investments and Investment Options 7. Plan Participant Education and Communication 8. Investment Advice to Participants 9. Plan Benchmarking 10. Plan Conversion to New Vendor Platform 11. Assistance in Plan Merger 12. Legislative and Regulatory Updates; Plan Corrections 13. Designed model allocations available to plan participants and ongoing management of the models Andersen Capital Management Weather Mark Long/Short, LLC Associates of Militello offers Weather Mark Long/Short, LLC on a fee-based discretionary managed account service. Militello acts as a distributor for Weather Mark Long/Short. 5  Financial Planning Financial planning services provide analysis and roadmap of a client's management of their financial resources. Generally, financial planning services will involve preparing a financial program for clients based on the client's financial circumstances and objectives. This information normally would cover present and anticipated assets and liabilities, including insurance, savings, investments, and anticipated retirement or other employee benefits. If needed by the client, planning services can include a cash flow analysis and advice as to the rearrangement of cash flow in order to fund certain long-term objectives such as buying a house, planning for college, retirement, etc. The program developed for a client will usually include general recommendations for a course of activity or specific actions to be taken by the client. Further, Militello Wealth develops tax or estate plans for clients or refer clients to an accountant or attorney. Plans are based on your financial situation at the time and are based on financial information disclosed by you to Militello Wealth. You are advised that certain assumptions will be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance. Militello Wealth cannot offer any guarantees or promises that your financial goals and objectives will be met. Further, you must continue to review the plan and update the plan based upon changes in your financial situation, goals, or objectives or changes in the economy. Should your financial situation or investment goals or objectives change, you must notify Militello Wealth promptly of the changes. You are advised that the advice offered by Militello Wealth is limited and is not meant to be comprehensive. Therefore, you need to consider seeking the services of other professionals such as an insurance adviser, attorney and/or accountant. You are not obligated to implement advice through Militello Wealth. Should you implement the plan with Militello Wealth Advisory Representatives commissions or other compensation received in addition to the advisory fee paid to Militello Wealth. WRAP Program The Advisor does not sponsor or provide investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro-rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor's judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client's discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance; therefore, at termination, any unearned fees as determined on a pro-rata basis for the portion of the month completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Advisor, and fees for comparable services may be available from other sources. 6  Annual Fee Managed Assets 1.55% Under $1,000,000 1.30% Over $1,000,000 Negotiable Over $5,000,000 Investment management fees will be billed and deducted quarterly. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client's third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Financial Planning Services You are advised that fees for planning services are strictly for planning services. Therefore, you will pay fees and/or commissions for additional services obtained, such as asset management or products purchased such as securities or insurance. Fees are negotiable. Your fees will be dependent on several factors, including time spent with Militello Wealth, the number of meetings, the complexity of your situation, the amount of research, services requested, and staff resources. Fee Type Maximum Fee Fixed Fee $2,000 to $25,000 Payable A payment schedule will be negotiated and customized to the client. Advisor and client will agree on a fee payment schedule and outline the terms in the advisory agreement between Advisor and client. Client will not be charged more than $500 and six or more months in advance. Hourly Fee $50 to $200 per hour A payment schedule will be negotiated and customized to the client. Advisor and client will agree on a fee payment schedule and outline the terms in the advisory agreement between Advisor and client. Client will not be charged more than $500 and six or more months in advance. Termination Provisions You may terminate advisory services obtained from Militello Wealth, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with Militello Wealth. Thereafter, you may terminate investment advisory services with written notice to Militello Wealth. You will be responsible for any time spent by Militello Wealth. Retirement Plan Consulting Services Militello Wealth will bill the Company for Retirement Plan Consulting Services at a pre-determined fee based upon a percentage of the Plan assets or a flat agreed-upon fee. The exact fee is negotiated in advance of services rendered 7  and is disclosed in the executed written agreement that we sign with the Company. Fees will be billed quarterly in advance. In special circumstances, other fee-paying arrangements are negotiated. Termination Provisions The service will continue until terminated by you. You may terminate advisory services obtained from Militello Wealth, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with Militello Wealth. Thereafter, you may terminate investment advisory services with 30 days written notice to Militello Wealth. If fees were paid in advance, you will be refunded a prorated portion of the advisory fee. Retirement Plan Consulting Services fee schedule is as follows: Value of Plan Assets Up to $2,500,000 $2,500,000 to $5,000,000 $5,000,000 to $10,000,000 Max Annual Fee 0.80% 0.60% 0.50% $10,000,000 to $20,000,000 0.40% $20,000,000 to $30,000,000 $30,000,000 to $50,000,000 0.25% 0.20% Over $50,000,000 0.10% Fee-based on the value of plan assets. Fees are negotiable. Fees for partial quarters will be prorated. Alternatively, the Company can elect to pay a fixed annual fee billed in quarterly installments in advance of each quarter. The fixed fee will not exceed $75,000. Integrated Fee Disclosure The clients of Militello will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Militello’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Militello’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees are based on the service provider's fee schedule(s) at the provider's sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor's services are charged on a fee-only basis, and no associated persons shall earn compensation based on a securities transaction (i.e., commission), including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisers selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients' portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. 8  If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a "spread" to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases, there may be fees charged, which are a result of brokered trading activity by associated personnel of the Advisor that is outside of the constructs of the Advisor's investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client; the fees may vary in size depending on the nature of the client's requests. Commissionable Securities Sales Representatives of our Firm are registered representatives of Purshe Kaplan Sterling Investments, Inc ("PKS"), member FINRA/SIPC. As such, they are able to accept compensation for the sale of securities or other investment products, including distribution or service ("trail") fees from the sale of mutual funds. Clients should be aware that the practice of accepting commissions for the sale of securities presents a conflict of interest and gives our Firm and/or our representatives an incentive to recommend investment products based on the compensation received. Our Firm generally addresses commissionable sales conflicts that arise when explaining to clients these sales create an incentive to recommend based on the compensation to be earned and/or when recommending commissionable mutual funds, explaining that "no-load" funds are also available. Item 6 – Performance Fees The Advisor does not charge performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension, and profit-sharing plans directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor does not have an account minimum. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor, which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive, and each involves a degree of risk. The Advisor will compete with firms, including many 9  of the larger securities and investment banking firms, which have substantially greater financial resources and research staff. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Militello Wealth's Investment Activities. The Advisor's investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it's considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor's investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies, or other instruments underlying them. Price movements of options contracts and payments 10  pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions' value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor's performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the client. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds, or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor's investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the 11  Advisor's foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel, and accountants to determine what restrictions may apply and whether an investment managed by the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby exposes the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Advisor faces inherent conflicts of interest, which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics, which provides that the client's interest is always held above that of the Firm and its associated persons. 12  Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor's efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities, where there is a ready market that is traded through an exchange, are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in the price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or "blue sky" laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets and/or disrupting the fund's investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Advisor and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Insurance Affiliations Militello and /or certain associated persons of Militello sell insurance products to advisory clients. The clients who purchase insurance-related products are informed that Militello or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that Militello and/or the associated persons may sell insurance products to clients of Militello and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. Militello makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from Militello or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Militello. Our Firm offers services through our network of investment advisor representatives (“Investment Adviser Representatives” or “IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of our Firm, Integrated Advisors Network. The IARs are under the supervision of our Firm, Integrated Advisors Network, and the advisory services of the IAR are provided through our Firm, Integrated Advisors Network. 13  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor's Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor's Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor's Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor's Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Advisor may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Advisor on behalf of any client or is being considered for purchase or sale. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage/Custodian Selection and Soft Dollars The Advisor has the authority over the selection of the broker/custodian to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution-only" commission rates; thus, the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker, which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies, and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, databases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation 14  that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark- downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available 15  include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement if any. 16  If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account, or fund as detailed in any written agreement. No additional compensation shall result from the proposed allocation. No client/investor, account, or fund will be favored over any other client/investor, account, or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts, or funds are required prior to any allocated order. The basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker-dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances, a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that Firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the 17  Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts, which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account, and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals, which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate for referring parties for these referrals. Solicitor Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. 18  Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets, including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients' funds or securities when clients have standing authorizations with their custodian to move money from a client's account to a third-party ("SLOA") in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client's written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts are for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor's investment management agreement and/or by a separate limited power of attorney where such document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may, however, be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of businesses or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used, and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the 19  provisions of the Employee Retirement Income Security Act of 1974 ("ERISA"), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to, and the Advisor has not been the subject of a bankruptcy petition in the last ten years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 20 

Item 1 – Cover Sheet MDK Private Wealth Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 1340 Fourth Avenue Suite 5206 Seattle, WA 98101 (206) 310-6994 https://mdkpwm.com March 28, 2025 This brochure provides information about the qualifications and business practices of MDK Private Wealth Management (“MDK”). If you have any questions about the contents of this brochure, please contact us by telephone at (206) 310-6994, or by email at: paul@mdkpwm.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to MDK Private Wealth Management Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 5, 2024, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. MDK Private Wealth Management’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 20, 2025, contains no material changes since our last Brochure update on March 15, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes ........................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................3 Item 4 – Advisory Business ......................................................................................................................................4 Item 5: Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .......................................................................................................................................8 Item 7 – Types of Clients..........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................8 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 .........................13 Item 12 – Brokerage Practices ................................................................................................................................14 Item 13 – Review of Accounts ...............................................................................................................................17 Item 14 – Client Referrals and Other Compensation ..............................................................................................18 Item 15 - Custody ...................................................................................................................................................18 Item 16 – Investment Discretion .............................................................................................................................18 Item 17 – Voting Client Securities .........................................................................................................................19 Item 18 – Financial Information .............................................................................................................................19 3  Item 4 – Advisory Business Firm Description MDK Private Wealth Management is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter the “Advisor” or “MDK”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC-registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides ongoing investment advisory, asset management, financial planning, and consulting services with respect to investments in securities, financial instruments and/or other assets, to individuals, families, trusts, estates, conservatorships, foundations, endowments, corporations, family offices, or business entities, charitable organizations, public funds, investment limited partnerships, 401(k) self-directed accounts, IRAs and retirement plans, based on their individual needs. The Advisor does not sell securities on a commission basis as part of its advisory services. However, Integrated has associated persons who are in other fields where they receive commissions as compensation. The Advisor is not affiliated by ownership with entities that sell financial products or securities. The Advisor nor Integrated does not act as a custodian of client assets, and the client always maintains asset control. The Advisor does have discretion of client accounts and does not require the consent of each client for all security trades. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s, or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change 4  over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s financial situation and portfolio through regular contact with the client, which often includes an annual meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided and the fees for the service. They may be terminated by either party in writing at any time. Asset Management MDK through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. The Advisor is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds, and other share classes), options, exchange- traded funds (“ETFs”), leveraged ETFs, alternative investments, and other securities as chosen by MDK. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created, and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. MDK may, in its discretion, hire and fire third-party money managers to leverage different investment strategies and allocate client assets across different asset classes. Financial Planning MDK through Integrated will typically provide a variety of financial planning services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. In certain circumstances, MDK will conduct financial and wealth planning for clients at no extra charge or fee. Even if a formal plan is not developed, MDK tailors and manages investment portfolios according to the specific financial objectives, taxability, and risk tolerance of the client, gathered through discussions in which goals and objectives based on a client's particular circumstances are established. Client accounts will be managed by MDK in accordance with the investment objectives, strategies, guidelines, restrictions, and limitations set forth in the investment advisory agreement and/or other applicable account documents. MDK does not assume any responsibility for the accuracy of the information provided by the client and is not obligated to verify any information received from the client or the client’s other professionals (e.g., attorney, accountant, or other such professional). Under all circumstances, clients are responsible for promptly notifying the Advisor in writing of any material changes to the client’s financial and investment objectives, taxability, time horizon, or risk tolerance. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, commence or alter retirement savings, or establish education or charitable giving programs. MDK may also refer clients to an accountant, attorney, or other specialists. For planning engagements, Advisor will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, Advisor may not provide a 5  written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. WRAP Program The Advisor does not sponsor or provides investment management services to WRAP programs. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro-rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5: Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance; therefore, at termination, any unearned fees as determined on a pro-rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Advisor, and fees for comparable services may be available from other sources. Investment management fees will be billed quarterly in advance. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. In addition, the management fees for third-party managers will be deducted directly from the client’s accounts at the custodian. FEE SCHEDULE ANNUAL FEE MANAGED ASSETS 1.25% Below $1,000,000 0.75% $3,000,001 - $10,000,000 0.65% $10,000,0001 - $20,000,000 0.55% $20,000,0001 - $40,000,000 Negotiable $40,000,000+ 6  Financial Planning Services The Advisor’s fees for planning services are strictly for planning services and will be based on a percentage of the assets under review. Therefore, clients will pay fees and/or commissions for additional services obtained, such as asset management or products purchased, such as securities. Fees are negotiable. Client fees will be dependent on several factors, including time spent with MDK, the number of meetings, the complexity of client situation, amount of research, services requested, and resources. Consulting Services MDK will bill clients consulting services at a pre-determined fee based upon a percentage of the assets. The exact fee is negotiated in advance of services rendered and is disclosed in the executed written agreement that we sign with the client. Fees will be billed quarterly in advance. In special circumstances, other fee-paying arrangements are negotiated. Termination Provisions A client may terminate advisory services obtained from MDK, without penalty, upon written notice within five (5) business days after entering into the Advisory Agreement with MDK. Thereafter, the client may terminate investment advisory services with 30-days written notice to MDK. Client will be responsible for any time spent by MDK. If fees were paid in advance, the client will be refunded a prorated portion of the advisory fee. Integrated Fee Disclosure The clients of MDK will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. MDK’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that MDK’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee-only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission), including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisors selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios, so there would be no initial or deferred sales charges; however if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. 7  If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Advisor is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Advisor does not act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, trusts, foundations, estates or charitable organizations, family offices, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Account Minimums The Advisor does not require an account minimum for clients. However, at its sole discretion, the Advisor may charge a lesser annual advisory fee or waive the stated client minimums based upon various factors, including, for example, anticipated future earning capacity, anticipated future assets, historical relationship, client investment experience, related accounts, account composition, negotiations with client, accounts referred to Advisor by another professional, etc. Clients will be required to sign investment advisory agreements (and/or other contractual arrangements) that, among other things, set forth the nature and scope of our investment advisory and management authority, specific services, and the investment objectives, guidelines, and restrictions applicable to the management of client accounts. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. 8  Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor, which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive, and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staff. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. MDK’s Investment Activities. The Advisor’s investment activities involve an element of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor may invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. 9  Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies, or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed-income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flow from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. 10  Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel, and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. 11  Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Advisor faces inherent conflicts of interest, which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics, which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities, where there is a ready market that is traded through an exchange, are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in the price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or LP interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information MDK and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations Some associated persons of Integrated are registered representatives of a broker dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors Network. Integrated does not make any representation that the brokerage services are at the lowest cost available and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated. 12  Integrated mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Our Firm offers services through our network of Investment Adviser Representatives (“IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The Client should understand that the businesses are legal entities of the IAR and not of our Firm Integrated Advisors Network. The IARs are under the supervision of our Firm Integrated Advisors Network, and the advisory services of the IARs are provided through our Firm Integrated Advisors Network. Our Firm Integrated Advisors Network has the arrangement described above with the following Adviser Representatives of: MDK Private Wealth Management. Other Business Affiliations Mercer Global Advisors Inc. has entered into an agreement to acquire MDK Private Wealth Management. The transaction closed on February 29, 2024, and resulted in a change of ownership. Mercer Global Advisors Inc. owns one hundred (100%) percent of the operating assets of MDK Private Wealth Management. Due to the Acquisition of MDK Private Wealth Management, the firm has provided notice to affected clients of the assignment to Mercer Global Advisors Inc. (a SEC-registered investment advisor) of such clients’ advisory arrangements with MDK Private Wealth Management to the extent required under applicable law. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Advisor may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Advisor on behalf of any client or is being considered for purchase or sale. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal 13  trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. The Advisor is not required to negotiate "execution-only" commission rates; thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker, which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies, and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, databases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15—Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”), and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While we a certain custodian may be recommended, the client will decide whether to do so and will open your account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. 14  Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would 15  be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account, or fund as detailed in any written agreement. No additional compensation shall result from the proposed allocation. No client/investor, account, or fund will be favored over any other client/investor, account, or fund as a result of the allocation. 16  • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts, or funds are required prior to any allocated order. The basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any possible commission discounts that might otherwise be available as a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker-dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances, a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms that do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts, which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account, and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives 17  and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals, which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets, including cash, securities, acting as a trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Advisor submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians, and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such a document is required. The Advisor has the authority to determine, without 18  obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may, however, be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of businesses or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtainclient approval for the transaction(s). The client authorizes the discretion to select the custodian to be used, and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to, and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet Menlo Oaks Capital Group Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 885 Oak Grove Avenue, Suite 208 Menlo Park, CA 94025 (650) 375-2636 March 28, 2025 This brochure provides information about the qualifications and business practices of Menlo Oaks Capital Group, LLC. If you have any questions about the contents of this brochure, please contact us at (650) 375- 2636, or by email at pwhite@menlooakscapital.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Menlo Oaks Capital Group Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. SEC’s Investment Adviser Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Menlo Oaks Capital Group’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on March 27 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................................. 1 Item 2 – Material Changes ......................................................................................................................................................... 2 Item 3 – Table of Contents ........................................................................................................................................................ 3 Item 4 – Advisory Business ....................................................................................................................................................... 4 Item 5 – Fees and Compensation ............................................................................................................................................... 6 Item 6 – Performance Fees ........................................................................................................................................................ 7 Item 7 – Types of Clients ........................................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................................... 8 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 Item 12 – Brokerage Practices ................................................................................................................................................. 13 Item 13 – Review of Accounts ................................................................................................................................................ 16 Item 14 – Client Referrals and Other Compensation ............................................................................................................... 17 Item 15 - Custody .................................................................................................................................................................... 17 Item 16 – Investment Discretion .............................................................................................................................................. 18 Item 17 – Voting Client Securities........................................................................................................................................... 18 Item 18 – Financial Information .............................................................................................................................................. 18 3  Item 4 – Advisory Business Firm Description Menlo Oaks Capital Group LLC is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Advisor” or “Menlo Oaks Capital Group” or “Menlo Oaks”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. The Firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has associated persons who are in other fields where they receive commissions as compensation. The Advisor is not affiliated by ownership with entities that sell financial products or securities. The Advisor does not act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s, or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Menlo Oaks Capital Group is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Patrick White is an Investment Adviser Representative of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual 4  meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Menlo Oaks Capital Group through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Menlo Oaks Capital Group is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client- imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Menlo Oaks Capital Group. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Menlo Oaks Capital Group may offer/manage a more active options strategy that is based on the fundamental and/or technical evaluation of each company to determine attractive prices to buy or sell options. Initial public offerings (IPOs) are not available through Integrated. Financial Planning Menlo Oaks Capital Group through Integrated will typically provide a variety of financial planning services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning, and charitable planning, education planning, and business planning. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Menlo Oaks Capital Group may also refer clients to an accountant, attorney, or other specialist. For planning engagements, Advisor will provide a summary of client’s financial situation, observations, and recommendations. For consulting engagements, Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Menlo Oaks Capital Group whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Menlo Oaks Capital Group or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Menlo Oaks Capital Group nor Integrated do not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Menlo Oaks Capital Group or use the services of Menlo Oaks Capital Group in particular. 5  WRAP Program The Advisor does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s Fee can range from 1.00% through 2.00%, depending upon the passive or active nature of the portfolio. Financial Planning Fees Financial Planning for clients without $300,000+ under management and for complex situations is provided under a fixed fee arrangement agreed upon at the first meeting and based on an hourly rate ranging between, $100 - $250. Fifty percent of the fee is payable in advance, before the financial planning process is started. The remaining fifty percent is payable at the end of the engagement. Fee Billing Investment management fees will be billed quarterly in advance. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. The clients of Menlo Oaks will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Menlo Oaks’ fees may be higher or lower than other advisory groups at Integrated and there is no representation that Menlo Oaks’ fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service 6  provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisors selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The Advisor, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Advisor will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases there may be fees charged which are a result of brokered trading activity by associated personnel of the Advisor that is outside of the constructs of the Advisor’s investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client the fees may vary in size depending on the nature of the client’s requests. Conflict of Interest Between Different Fee Structures The Advisor offers several different services detailed in this brochure that compensate the Advisor differently depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Advisor mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Advisor is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. 7  Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Menlo Oaks Capital Group’s Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. 8  Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. 9  Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards. There may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in 10  decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. 11  Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information Menlo Oaks and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Insurance Affiliations Some Menlo Oaks Capital Group and/or certain associated persons of Menlo Oaks Capital Group sell insurance products to advisory clients. The clients who purchase insurance related products are informed that Menlo Oaks Capital Group or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that Menlo Oaks Capital Group and/or the associated persons may sell insurance products to clients of Menlo Oaks Capital Group and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. Menlo Oaks Capital Group makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from Menlo Oaks Capital Group or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Menlo Oaks. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer, and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Advisor, managers, members, officers, and employees on the same day purchase or sell the same security, either the clients and the Advisor, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. 12  Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth 13  of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support 14  The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. 15  • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. 16  Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Advisor submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. 17  Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities, and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 18 

ZIMMERMAN WEALTH ADVISORY GROUP LLC FINANCIAL PLANNING • PORTFOLIO MANAGEMENT • CONSULTING Item 1 – Cover Sheet Zimmerman Wealth Advisory Group, LLC. Form ADV Part 2A – Firm Brochure 2950 Buskirk Ave, Suite 300 Walnut Creek, CA 94597 Telephone: (925) 698-3683 www.ZimWAGs.com March 28, 2025 This brochure provides information about the qualifications and business practices of Zimmerman Wealth Advisory Group, LLC. If you have any questions about the contents of this brochure, please contact us at (925) 698-3683, or by email at Info@ZimWAGs.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo@sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Zimmerman Wealth Advisory Group Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Zimmerman Wealth Advisory Group’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update There have been no material changes since the last annual update. 2  Item 3 – Table of Contents Item 1 – Cover Sheet................................................................................................................................... 1 Item 2 – Material Changes .......................................................................................................................... 2 Item 3 – Table of Contents.......................................................................................................................... 3 Item 4 – Advisory Business ........................................................................................................................ 4 Item 5 – Fees and Compensation ................................................................................................................ 9 Item 6 – Performance Fees ....................................................................................................................... 13 Item 7 – Types of Clients .......................................................................................................................... 13 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................. 13 Item 9 – Disciplinary Action..................................................................................................................... 17 Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 17 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 17 Item 12 – Brokerage Practices .................................................................................................................. 18 Item 13 – Review of Accounts.................................................................................................................. 22 Item 14 – Client Referrals and Other Compensation ................................................................................ 22 Item 15 - Custody...................................................................................................................................... 22 Item 16 – Investment Discretion ............................................................................................................... 23 Item 17 – Voting Client Securities............................................................................................................ 23 Item 18 – Financial Information ............................................................................................................... 23 3  Item 4 – Advisory Business Firm Description Zimmerman Wealth Advisory Group, LLC, is a dba of the registered entity Integrated Advisors Network LLC, and collectively known hereinafter as “the Adviser” or “ZWAG LLC”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Advisor is a fee-only investment management firm offering comprehensive financial planning and investment advisory services primarily to high-net-worth individuals, individuals, and their respective families. The Adviser may also occasionally provide services to foundations, endowments, small businesses, and non- profit organizations. Services are offered on a “fee-only” compensation schedule, meaning that compensation for all our work done for clients comes exclusively from our clients in the form of fixed, flat, hourly, or on a percentage of assets under management. The Adviser does not participate in wrap fee programs, nor does it sell any annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or any other commissioned products. The Adviser is not affiliated with any entities that sell financial products or securities. The Adviser does not sell securities on a commission basis as part of its advisory services. However, Integrated has some associated persons who are in other fields where they receive commissions as compensation. The Advisor is not affiliated by ownership with entities that sell financial products or securities. Adviser does not receive any compensation for the use of certain financial instruments in client portfolios. The Adviser does not receive (or pay) any compensation for introductions to (or from) outside professionals or service providers. The Adviser nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Adviser has discretion over client accounts to select securities and to place trades for clients under a limited power of attorney (LPOA). An LPOA allows the Adviser access to client accounts for the purposes of managing, maintaining, and rebalancing client portfolios, but does not permit the Adviser to withdraw funds for any purpose other than the payment of fees to the Adviser for services provided. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Principal Owners of Zimmerman Wealth Advisory Group LLC are as follows: Geoffrey Zimmerman is an Investment Advisor Representative (“IAR”) of Integrated Advisors Network, LLC and is the Principal and sole owner of ZWAG LLC. All advisory services are offered through Integrated Advisors Network LLC. Types of Advisory Services The Adviser provides Financial Planning services, Investment Supervisory services (also known as asset management services), and Consulting services which are more fully described below in Types of Services. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. 4  Tailored Relationships Clients have their own unique goals, considerations, and circumstances. These are discussed during a discovery process through conversation, questionnaires, surveys, and correspondence. The Investment Adviser Representative documents this information in our client relationship management system. The information is used in the financial planning process, and in the creation of an Investment Policy Statement. Clients are encouraged and expected to have a significant degree of participation in the process so that the work done by the Adviser and any advice, recommendations, investment preferences or restrictions are appropriately tailored for the client. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management Discretionary Investment Management services begin with the creation of a personal Investment Policy Statement (“IPS”). The purpose of the IPS is to have a mutual understanding between the client and the Adviser of the objectives for the client’s portfolio. To gain this understanding, we will discuss, review and evaluate each client’s prior investment history; their family composition and background; the client’s risk profile; the parameters under which the Adviser has discretion to act without client preapproval; the client’s current and anticipated tax bracket; any preferences or restrictions on security selection by the Adviser, and other material factors. These topics will be covered through personal discussions, correspondence, and risk questionnaires. If the client elects to engage in financial planning, then analysis from the plan will be considered in the creation of the IPS. We will use this information to design an investment portfolio tailored to our client. The design will include recommended levels of exposure to distinct segments of the financial markets (a.k.a. an “asset allocation”). The IPS will specify the types of securities that may be used (or specifically excluded) from the portfolio. The IPS will outline the roles and responsibilities of the Adviser and of the client. We will not recommend or use non-public securities, derivatives, or commodity contracts for client portfolios. In situations where client already own these types of securities or acquire them of their own volition, we will generally advise the client to hold these securities outside of the managed portfolio as we will not conduct ongoing research or evaluate the viability or desirability of these instruments. We will generally avoid the use of annuities in client portfolios. If a client has an existing annuity contract, we may take into consideration the value of the annuity and the allocation of funds within the annuity in evaluating the client’s overall portfolio. We will not utilize leverage or margin as a portfolio strategy. Clients may choose to enable a margin feature on their brokerage accounts for the rare circumstances such as when the client needs to have access to funds prior to the settlement of trades. The margin feature may help reduce the risk of a mismatch in settlement dates on the sale of one security and simultaneous purchase of another. We will generally not use options as a portfolio strategy except in the rare instance where a client has a concentrated position in a single security and wishes us to utilize covered call writing as part of a planned diversification and income generating strategy. As part of the portfolio review process, we will assess the client’s existing investments and portfolio structure in comparison to the parameters and recommendations in the IPS. During this review, we will consider the unrealized gains (or losses) for investments held outside of tax-sheltered accounts. We will review the location of the current holdings in relation to the tax characteristics and type of account holding the investments. We will also review the risk characteristics of the current investments relative to the time frame in which they are needed and the type of account holding the investments. Based on our assessment, we will work with the client to develop a plan to transition their current portfolio to the recommended implementation in the IPS During the review process, we will review the custodians that the client currently uses. Our preferred custodians are Charles Schwab & Co (“Schwab”) and Fidelity. If a client does not already have accounts with Schwab or Fidelity we will assist the client in establishing like-titled accounts there and arranging the transfer of existing accounts as needed. Under certain circumstances, clients may not be allowed to establish accounts at Schwab or 5  Fidelity (due to the nature of their work or other circumstances). Under these circumstances will work with the client to find alternative solutions. These alternate solutions may involve using a different custodian or the use of account aggregation services (e.g., ByAllAccounts or similar) Once the IPS is created and approved by the client and the Adviser investment operations will commence. Subject to the terms of the IPS, ZWAG LLC will assume the responsibility for the selection, the purchase (or sale) and the ongoing monitoring and evaluation of publicly traded securities in a client’s portfolio, subject to the conditions and restrictions outlined in the client’s Investment Policy Statement (IPS). Trades are initiated at the timing and the discretion of the Adviser. While the Adviser will generally initiate trades without prior consultation with the client, the Adviser may consult with the client prior to placing trades under certain circumstances (e.g., the sale of a security would generate a significant realized capital gain). ZWAG LLC will manage the client’s individually tailored investment portfolio and provide continuous advice regarding the investment of their funds, based on each client’s distinct needs. Fees for Investment Management services will be based on a percentage of assets under management according to the schedule and description in Item 5 of this brochure (Fees & Compensation). Please refer to this section for more detailed information. While there is no minimum account size for ZWAG LLC’s Investment Management services, our standard minimum quarterly fee is $1,000. Fees are negotiable, including the minimum quarterly fee. Client fee schedules will be subject to periodic review in relation to the amount of time devoted to serving the client. Fees will be deducted directly from client accounts after the end of each calendar quarter. In circumstances where deducting fees directly from client accounts is not feasible or available, the client may arrange for fees to be paid from an account where we can directly deduct fees. In rare circumstances, we may arrange for the client to pay fees via a check or by electronic funds transfer, though this practice is strongly discouraged when there are other viable options available. ZWAG LLC will continuously monitor the client's portfolio holdings and its overall asset allocation strategy. Financial planning services, periodic reviews of the portfolio strategy, holdings, results, and alignment with client goals are included as part of the Investment Management service. Investment Review Services Investment Review services provide a consultative assessment of a client’s existing investment portfolio for individuals, endowments, businesses, and non-profit organizations. The assessment will include a review of the risk and return profile of invested mutual funds, ETFs, individual stocks and bonds, retirement plans and overall asset allocation. There is no minimum account size for ZWAG LLC’s Investment Review services. (Please see Item 5 - Fees & Compensation, of this brochure for further information on fees for this service. Financial Planning Services ZWAG LLC through Integrated provides Financial Planning services on a variety of topics. Financial planning is a holistic and comprehensive evaluation of a client’s current and future financial state by using currently known variables to forecast future cash flows, asset values, and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, a wide variety of questions, information, and analysis are considered. We will examine projections of the client’s current trajectory and examine how changes, modifications or alternate strategies may affect the entire financial and life situation of the client. Clients who engage in this service, either as part of an Investment Management engagement or as a standalone service will receive written or electronic reports consisting of a detailed financial plan and recommendations designed to help the client achieve their stated financial goals and objectives. There is no minimum account size for ZWAG LLC’s Financial Planning services. These services are offered as a ‘fee-only’ service and can be done as a project for a fixed fee, or on an hourly schedule for addressing specific questions or situations. Please refer to Item 5 of this brochure (Fees & Compensation) for further information on fees for this service. 6  In general, the Financial Plan will address any or all of the following areas of concern. The client and Advisor Representative will work together to select the specific areas to cover. These areas may include, but are not limited to, the following: • Current Financial Position, Cash Flow & Debt Management - We will create a net worth statement to help us understand our client’s current resources and the current structure of their personal balance sheet. We will examine the amount of liquid versus illiquid assets; the current allocation to tax deferred accounts versus accounts that may be more easily accessed; the amount of debt, the cost to service the existing debt, and other factors. We will conduct a review of a client’s current and projected income and expenses to determine their current surplus or deficit along with how these surpluses or deficits might affect the client’s future net worth. We will offer advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed a client’s income. If debt reduction is a goal for the client or if debt reduction is otherwise desirable we will offer advice which debts to pay off first based on factors such as the interest rate of the debt, potential income tax ramifications, and the impact on the client’s liquid versus illiquid assets. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. • Financial Goals - We will help clients identify financial goals, identify what actions may be needed to achieve the stated goals and develop a plan to reach them. We will identify what a client plans to accomplish, what resources are required to achieve the goal, how much time will be needed to reach the goal, and how much should be budgeted for the goal. In the event that the client’s current and projected resources might fall short of their stated goals, we will work with the client to prioritize their goals and/or modify their goals to help improve the chances of achieving the high priority goals. • Investment Analysis - This may involve developing an asset allocation strategy to meet a client’s financial goals and risk tolerance, providing information on investment vehicles and strategies. If a client has equity compensation instruments (stock options, restricted stock, stock appreciation rights, etc.) we will review and advise on these instruments as part of our service. For clients choosing to engage ZWAG for investment management services, we will prepare an investment policy statement during this phase of the planning, if there is not already one in place. If the client is already an investment management client, we will review the existing IPS in relation to the desired risk/reward profile from the financial plan and update the existing IPS if necessary. • Retirement Planning - Our retirement planning services typically include projections of the likelihood of achieving financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than desired results, we may make recommendations, including those that may affect the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments, or prioritizing retirement over other goals. If a client is near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to alter spending during retirement years adversely. ‐ ‐ • Risk Management - A risk management review includes an analysis of client exposure to major risks that could have a significant adverse impact on their financial picture (such as premature death, disability, property and casualty losses, or the need for long term care planning). Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self insuring”). In situations where a client needs and desires additional insurance, we will work with the client and their existing professionals to find and implement appropriate solutions. In situations where a client does not have an existing professional, we may provide the client with contact information for insurance agents or brokers who specialize in the appropriate area of expertise if the client wishes to hire someone for such purposes. 7  • Tax Planning Strategies - Advice may include ways to minimize current and future income taxes as a part of an overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with the consideration that there is always a possibility of future changes to federal, state, or local tax laws and rates that may impact a client’s situation. ZWAG LLC recommends that clients consult with a qualified tax professional before initiating any tax planning strategy. We will coordinate and work with the client’s existing tax professional as desired by the client and make ourselves available to participate in meetings with the client’s professional team. In situations where a client does not have an existing professional, we may provide clients with contact information for accountants or attorneys who specialize in this area if they wish to hire someone for such purposes. • Estate Planning Services – Our estate planning services typically include an interactive discussion with the client about their estate planning goals. Topics may include client objectives related to the management of the client’s estate in situations involving the incapacity or the death of the client and (if applicable) their spouse. We will seek to understand the client’s wishes related to the disposition of their estate to beneficiaries, charities, and the potential to incur estate taxes. We will seek to gain an understanding of whom the client wishes to name for the various roles in the estate plan – executor, trustee, powers of attorney for finance and health care, primary and contingent beneficiaries, etc. During the estate review process, we will examine the client’s existing documents (if applicable) in relation to the client’s stated goals and objectives. If we believe that there is misalignment between the client’s current plan and their stated goals, we will refer the client to their attorney for more specific advice and action. In situations where a client does not have existing documents and/or does not have an existing professional, we may provide clients with contact information for attorneys who specialize in this area if they wish to hire someone for such purposes. Consulting Services ZWAG LLC may provide consulting services on an hourly basis for projects tangential to or outside the areas noted above. Examples may include research projects, single-issue or narrow focus planning advice, expert witness testimony, client education consultations, and a variety of other topics that may fall within the Adviser’s area of expertise. These services will be billed at an hourly rate described more fully in section 5 (Fees & Compensation). Educational Seminars & Speaking Engagements ZWAG LLC may provide seminars on an “as announced” basis for groups seeking general advice on investments and other areas of personal finance. The content of these seminars will vary depending upon the needs of the attendees. These seminars are purely educational and do not involve the sale of any investment products. The information presented will not be based on any individual’s person’s need, nor does ZWAG LLC provide individualized investment advice to attendees during these seminars. ZWAG LLC may provide this service at no charge, or for a fee. Fees for seminars and speaking engagements may be charged either to participants, through a pre-determined ticket price, or to a sponsoring company via a flat fee. ERISA Account Advice ZWAG LLC provides investment advice to advisory clients that are employee benefit plans or other retirement accounts (i.e., IRAs) for a level fee. Advisory services for this category of assets are affected by the Department of Labor (“DOL”) Fiduciary Rule. As such, we are considered fiduciaries under the Employee Retirement Income and Securities Act ("ERISA") and regulations under the Internal Revenue Code of 1986 (the "Code"), which requires that we abide by the Impartial Conduct Standards, as defined by ERISA. To comply with these standards, our firm and our investment advisor representatives provide advice that is in our clients’ best interest and charge no more than reasonable compensation [within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)]. We make no misleading statements about investment transactions, compensation, conflicts of interest, or any other matters related to investment decisions. 8  By our business practices outlined above, we believe ourselves to be a ‘Level Fee Fiduciary’ under the DOL’s Rule. As a Level-Fee Fiduciary, we maintain a non-variable compensation structure that is based on either a fixed percentage of the value of assets or a set fee that does not vary with the particular investment recommended, as opposed to a commission or other transaction-based fee. As a “Level Fee Fiduciary,’ while we are held to the DOL fiduciary standards of care, we are subject to fewer disclosures and reporting requirements than advisors operating under a different business model. Employee Benefit Plan Services ZWAG LLC may also provide advisory services to participant-directed employee retirement benefit plans. ZWAG LLC will analyze such plan's current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered, and restrictions that may be imposed. ZWAG LLC will recommend investment options it believes will best achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. We will also recommend changes in the plan's investment vehicles as may be appropriate from time to time and will review the plan's investment vehicles and investment policy as necessary. WRAP Program ZWAG LLC does not sponsor nor provides investment management services to a wrap program. ZWAG LLC does not use wrap programs in client portfolios. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A Client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management Investment Management Services Fee Calculations Advisory Fees charged are based on a percentage of the client’s assets under management and are established on a client-by-client basis. The specific ways ZWAG LLC charges its fees are established in each client’s written Investment Advisory Contract. Generally, clients will be invoiced in arrears at the end of each calendar quarter based upon the average daily value of their assets under management (market value based on independent third- party sources, or fair market value in the absence of market value) during the calendar quarter. Investment Management service fees are based on assets under management (“AUM”) and will be calculated at the annualized rates reflected below and charged quarterly. The standard Investment Management services annual fee will be charged as a percentage of assets under management, according to the tiered schedule below: 9  $ - $ 1,000,000.01 $ 2,500,000.01 $ 5,000,000.01 $ 7,500,000.01 $ 10,000,000.01 to to to to to and $ 1,000,000.00 $ 2,500,000.00 $ 5,000,000.00 $ 7,500,000.00 $ 10,000,000.00 over 1.00% 0.75% 0.50% 0.25% 0.10% 0.00% The fee schedule operates as a tiered schedule, meaning that fees are charged at the level indicated for the assets in each range. For example, a client who enlists ZWAG LLC to manage a portfolio of $2,600,000 would pay us 1% of the first $1 million, 0.75% of the next $1.5 million and 0.50% on the remaining $100,000. Our standard minimum quarterly fee is $1,000. Investment Management service fees (including the minimum quarterly fee) are negotiable. New accounts are charged a prorated fee for the remainder of the quarter in which investment operations begin as determined by the date of the first trade in client accounts under management. In most circumstances, this will occur after the date the IPS is signed and the date that client accounts are fully or partially funded. Investment Management Services Fee Billing ZWAG LLC’s clients agree to pay an asset-based fee (advisory fee) calculated according to the tiered Fee Schedule above, calculated on the average daily balance of assets under management during the quarterly billing period. ZWAG LLC will request authority from the client to receive its quarterly payment advisory fees directly from the client's account held at their independent qualified Custodian. The client’s independent qualified Custodian will maintain actual custody of their assets. While ZWAG LLC requires its clients to authorize it to deduct fees from their account(s) held by their Custodian, clients must provide ZWAG LLC with written limited authorization to allow the Investment Adviser to withdraw management fees from their account. Clients may elect to have their quarterly fees charged to either one account or split between their other accounts. Under rare circumstances, clients may be given the option to pay fees directly to the Adviser via check or by electronic funds transfer. Advisors’ fees are due and will be debited (if not paid by check), from the client’s Custodial account(s), in the first month following the end of the quarter (January, April, July, October). Clients will receive Custodial statements showing ZWAG LLC’s advisory fees being debited from their account. To bill an account, ZWAG LLC will: • Obtain written authorization from the client, permitting ZWAG LLC to be paid directly from the client’s account, held by their Custodian. • • Send the client an invoice specifying and itemizing any fees assessed, while concurrently sending a copy of the client’s invoice details to their Custodian. (Note: For many Custodians, the invoice information will be presented in the form of a data sheet reflecting client invoice details, an uploaded to deduct fees, not a copy of the actual invoice the client received.) Instruct the Custodian to send the client statements at least quarterly, to the email or postal mailing address the client provided to the Custodian, showing all disbursements for the account, including the amounts of any assessed Advisory fees. Investment Management Account Terminations A client Investment Advisory Agreement (“Advisory Agreement”) may be cancelled at any time, by either party, for any reason upon receipt of 10 days written notice. Upon termination of any account at any time after the required 10  10-day notice, a pro-rated invoice for services provided through termination date will be sent to the client. The client has the right to terminate their Advisory Agreement without penalty within five (5) business days after executing their Advisory Agreement. Effective with the date of termination, ZWAG LLC shall refrain, without liability or obligation, from taking any further action in a client’s account(s). From the date of termination, ZWAG LLC will cease to be entitled to receive fees. Cancellation will be subject to any changes related to the settlement of transactions in progress. Any unearned pre-paid fees will be refunded to the client on a pro-rata basis, based on the date of termination. Employee Benefit Plan Services Fees Note: Employee Benefit Retirement Plan Services annual fees are charged as a percentage of assets within the plan, according to the above-quoted fees for Investment Management Services fees, for ongoing management of assets. For a review of plans that does not include management of assets, a negotiable fixed fee will be charged. Employee Benefit Plan Services Fee Billing Employee Benefit Plan Services Billing follows the same procedures as “Investment Management Account Billing,” above for management of assets. Please refer to that section, for billing specifics. For an Investment Review of an Employee Benefit Plan, a negotiable fixed fee applies. Investment Review Fees Investment Reviews will generally be offered on a fixed fee basis. Fees are negotiable and must be paid by electronic funds transfer or by check at the end of the service; cash is not accepted. Investment Review Fee Billing Clients will receive an invoice for Investment Review fees due upon the delivery of the financial plan and a review of results with the client. Payment is due within 30 days of invoice receipt; cash is not accepted. Financial Planning Fees Financial Planning will generally be offered on a fixed fee basis. This will usually be in the form of a fixed fee for a defined engagement. Clients who wish to initiate and maintain an ongoing financial planning advisory relationship with ZWAG LLC but do not wish to engage in discretionary investment management may be given the option to engage us on an annual retainer with fees billed each calendar quarter. Fees are negotiable and must be paid by electronic funds transfer or by check; cash is not accepted. Financial Planning Fee Billing If a Financial Planning fixed fee program is chosen, clients will be asked to pay an initial retainer fee equal to $1,000 or 25% of the project fee, whichever is greater. Clients will receive invoices for the remaining fee outstanding in three equal installments in 3-month intervals until all fees have been paid or until the work is completed. Once the financial plan is complete, delivered, and reviewed with the client, the client will receive an invoice for the remainder of any outstanding fees. Fees for this service may be paid by electronic funds transfer or check. Fees are negotiable and are payable within 30 days of invoice receipt. If a client chooses to engage ZWAG LLC for investment management services after initiating a financial planning engagement, ZWAG LLC may choose to waive some or all of the unpaid financial planning fees as of the onset of the Investment Management engagement. If a client prefers to engage ZWAG LLC for an ongoing financial planning relationship and pay an annual retainer, the client will be asked to pay an initial start-up fee of up to one quarter (25%) of the annualized fee at the beginning of the relationship and will be subsequently invoiced at three month intervals for one quarter (25%) of the annualized 11  retainer. If the client chooses to discontinue services mid quarter, the client will be refunded the prorated portion of the fee that was paid but not yet earned. Fees for this service must be paid by electronic funds transfer, credit card or by check; cash is not accepted. Consultation Fees Fees for hourly consulting work will be billed at a rate of $300 per hour, unless otherwise described in the engagement letter. There is a three (3) hour minimum for consulting work. Consultation Fee Billing Clients will receive a monthly invoice for hourly consulting fees. Fees for consulting services may be paid by electronic funds transfer or check. Fees are negotiable and are payable within 30 days of invoice receipt. Integrated Fee Disclosure The clients of ZWAG LLC will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. ZWAG LLC’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that ZWAG LLC’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee-only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisors selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. Fees and expenses for mutual funds, annuity products, ETFs, other managed products or partnerships are described in each mutual funds, ETF’s, or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge to the fund’s sponsor. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some rare cases there may be fees charged which are a result of brokered trading activity by associated personnel of the Adviser that is outside of the constructs of the Adviser’s investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client and the fees may vary in size 12  depending on the nature of the client’s requests. In the rare circumstance where this activity is requested or necessary, the Adviser does not receive any portion of these fees. The Adviser does not offer any proprietary investment products and does not intend to do so. Conflict of Interest between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees ZWAG LLC does not charge fees or receive compensation that is based on a share of the capital gains or capital appreciation of managed securities. These types of fees are frequently a characteristic of ‘hedge’ funds. In the unlikely event the Adviser was to employ these types of investments that do charge a performance fee, the Adviser does not participate in these fees. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description ZWAG LLC provides services primarily to high-net-worth individuals and their families, as well as to individuals and their families. ZWAG may occasionally provide services to institutions, foundations and endowments, businesses, and non-profit organizations. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums There is no minimum account size for ZWAG LLC’s fee-only Investment Management, Financial Planning, or Investment Review services. ZWAG LLC will charge investment management clients a minimum annual fee as described in section 5 (Fees and Compensation) and as documented in the Investment Management engagement letter. Fees may be negotiated. There are no ongoing contribution requirements for client accounts. . Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. 13  Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including the potential for complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor, which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. Security prices, particularly equity prices can fall rapidly in response to developments affecting a specific company, or industry. Changing economic, political or market conditions can materially and adversely affect pricing in the equity, fixed income, real estate, currency, and other financial markets. ZWAG LLC’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser may invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline 14  in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. 15  Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest: In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity: Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have 16  a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency: 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. Lack of Registration: Funds or LP interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital: The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Action The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade manes and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of ZWAG LLC. Financial Affiliations Mr. Zimmerman currently does not participate in any outside business activities or volunteer work. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. 17  Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage/Custodian Selection and Soft Dollars The Adviser has the authority over the selection of the broker/custodian to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark- downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell 18  securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data 19  • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each Client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many Clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. 20  • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No Client/investor, account or fund will be favored over any other Client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating Client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the Client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the Client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other Clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a Client's account, the Adviser may be precluded from aggregating that Client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. 21  Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients with managed portfolios receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and percentage current holdings, current portfolio allocation versus targets, and other portfolio details. Financial planning clients periodically receive reports of progress toward financial goals net worth, cash flow and other planning reports and action checklists prior to or during client meetings. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals, which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in 22  place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Advisers discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the Client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 23 

Item 1 – Cover Sheet Yorkshire Wealth Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 16935 W. Bernardo Court, Suite 170 San Diego, CA 92127 (858) 798-5616 yorkshirewealthmanagement.com March 28, 2025 This brochure provides information about the qualifications and business practices of Yorkshire Wealth Management, Inc. If you have any questions about the contents of this brochure, please contact us at (858) 798- 5616, or by email at douglas.shultz@ywmgmt.com Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222 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 the Advisor is available on the SEC’s website at www.adviserinfo@sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Yorkshire Wealth Management Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Yorkshire Wealth Management’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through at Adviser adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update Item 5 – Fees and Compensation Effective February 1, 2025, Financial Planning Fees have been updated. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisor Business ..........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................8 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8- Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................8 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 ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................13 Item 13 – Review of Accounts .................................................................................................................................17 Item 14 – Client Referrals and Other Compensation ...............................................................................................18 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................18 Item 17 – Voting Client Securities ...........................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisor Business Firm Description Yorkshire Wealth Management Inc. is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser” or “Yorkshire Wealth”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management and financial planning firm. The Adviser provides personalized investment advice primarily to individuals and high net worth individuals directly. The firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Yorkshire Wealth is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Douglas Shultz and Phil Bell are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations 4  according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Yorkshire Wealth through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Yorkshire Wealth is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Yorkshire Wealth. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds and ETFs is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Initial public offerings (IPOs) are not available through Integrated. Financial Planning Yorkshire Wealth through Integrated will typically provide a variety of financial planning services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate and charitable planning, education planning, and business planning. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Yorkshire Wealth may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of client’s financial situation, observations, and recommendations. For consulting engagements, Adviser may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Yorkshire Wealth whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Yorkshire Wealth or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Yorkshire Wealth does not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Yorkshire Wealth or use the services of Yorkshire Wealth in particular. Wealth Coaching, Second Opinions & Financial Analysis Fees Yorkshire Wealth may provide coaching services that typically do not include investment advisory or management services, financial planning services, nor the review or monitoring of a client's investment portfolio. The Adviser may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Adviser. If the client engages 5  any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Adviser if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Adviser’s previous recommendations and/or services. WRAP Program The Adviser does not sponsor or provides investment management services to a WRAP program. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the month completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. The Adviser’s Fee generally can range from .85% through 1.25%, depending upon the passive or active nature and size of the portfolio. Assets Under Management Annual Fee Up to $499,999.99 1.25% $5,000,000 to $999,999.99 1.00% $1,000,000 to $1,749,999.99 0.85% $1,750,000.00 + Negotiable Investment management fees will be billed monthly in advance. Advisory fees are billed and deducted at 1/12th the annual rate. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Financial Planning Fees Financial Planning for clients, which includes complex situations, is provided under a fixed fee arrangement agreed upon at the first meeting and billed monthly. These services can either be provided based on a range of $250 - $4000 fixed fee or Yorkshire Wealth may a charge a $250 hourly fee for consultation and planning. 6  FINANCIAL PLANNING Portfolio/Investments Review $250 Retirement Planning $250 Financial Plan Standard $2,000 Financial Plan Advanced $4,000 Hourly Consulting and Planning $250 per hour Integrated Fee Disclosure The clients of Yorkshire Wealth will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Yorkshire Wealth fees may be higher or lower than other advisory groups at Integrated and there is no representation that Yorkshire Wealth fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. 7  If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases, there may be fees charged which are a result of brokered trading activity by associated personnel of the Adviser that is outside of the constructs of the Adviser’s investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client the fees may vary in size depending on the nature of the client’s requests. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $200,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8- Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, 8  research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Yorkshire Wealth’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which 9  may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. 10  • Enforcing legal rights in some foreign countries is difficult, costly and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards. There may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. 11  Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Yorkshire Wealth. Insurance Affiliations Yorkshire Wealth and/or certain associated persons of Yorkshire Wealth may sell insurance products to advisory clients. Yorkshire Wealth offers insurance products that are associated with an insurance company with which Yorkshire Wealth has established a relationship. Insurance products include variable annuities, life, health, long 12  term care, and general agency insurance. The Adviser earns commissions on these insurance products in addition to any fees earned from financial planning, investment management, or other services offered. The commissions are based on the standard commission schedule of the provider of the insurance products and are generally not negotiable. The clients who purchase insurance-related products are informed that Yorkshire Wealth or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that Yorkshire Wealth and/or the associated persons may sell insurance products to clients of Yorkshire Wealth and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. Yorkshire Wealth makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from Yorkshire Wealth or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Yorkshire Wealth. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer, and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage Firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. 13  In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. 14  Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific 15  custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/Investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/Investor accounts and the proposed method to allocate the order among the clients/Investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded 16  from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage, but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. 17  Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions 18  in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. The Adviser will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Page Archer Bay Capital Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 1990 Main Street, Suite 750 Sarasota, FL 34236 (617) 453-8789 www.archerbaycapital.com March 28, 2025 This brochure provides information about the qualifications and business practices of Archer Bay Capital, LLC. If you have any questions about the contents of this brochure, please contact us at (617) 453-8789 or by email at: tcampbell@archerbaycapital.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at (855) 729-4222 or compliance@integratedadvisorsnetwork.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 the Advisor is available on the SEC’s website at www.adviserinfosec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Archer Bay Capital’s Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Adviser Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at (855) 729-4222 or by email at compliance@integratedadvisorsnetwork.com. Archer Bay Capital’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment at www.adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s Investment Advisor Representative (tcampbell@archerbaycapital.com). Material Changes since the Last Update There are no material changes since the last update March 2024. 2  Item 3 – Table of Contents Item 1 – Cover Page ...................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees & Compensation ..................................................................................................................................7 Item 6 – Performance Fees .......................................................................................................................................10 Item 7 – Types of Clients .........................................................................................................................................10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................10 Item 9 – Disciplinary Information ............................................................................................................................14 Item 10 – Other Financial Industru Activities and Affiliations ................................................................................14 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................14 Item 12 – Brokerage Practices ..................................................................................................................................15 Item 13 –Review of Accounts ..................................................................................................................................18 Item 14 – Client Referrals and Other Compensation ...............................................................................................19 Item 15 - Custody .....................................................................................................................................................19 Item 16 – Investment Discretion ..............................................................................................................................19 Item 17 Voting Client Securities ..............................................................................................................................20 Item 18 – Financial Information ...............................................................................................................................20 3  Item 4 – Advisory Business Firm Description Archer Bay Capital, LLC, is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter (“the Advisor” or “Archer Bay Capital”). Integrated Advisors Network, LLC was founded in 2015 and is an SEC-registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides services to institutions, individuals, high net worth individuals, foundations and endowments, businesses, and non-profit organizations. The Firm does not sell securities on a commission basis as an investment adviser. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. Neither the Advisor nor Integrated act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. he control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services, described below in Types of Services. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Archer Bay Capital is a dba of Integrated Advisors Network LLC. All Advisory services are offered through Integrated Advisors Network LLC. Terri Campbell and Kerstin Ramstrom are Investment Adviser Representatives (“IAR”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IAR utilizing Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management Investment Management services involve Archer Bay Capital assuming the responsibility for buying and selling publicly traded securities in a client’s portfolio, on a discretionary basis. Archer Bay Capital will manage the client’s individually tailored investment portfolio and provide continuous advice regarding the investment of their funds based on each client’s distinct needs. Through personal discussions in which goals and objectives based on each client’s specific circumstances are established, we will work with a client to design a personal Investment Policy Statement (“IPS”), with an asset allocation target. The risk/return profile of each client will be determined through interviews with the client and 4  defined together. We will then create and manage a portfolio based on the agreed upon personal IPS and its allocation targets. All research and monitoring of publicly traded securities will be conducted in-house by trained professionals. Non-public securities, derivatives, annuities, options, and commodity contracts will not be a part of a client’s portfolio. Neither will leverage, margin, or wrap fee accounts. During our review, we will also evaluate and discuss each client’s prior investment history, as well as their family composition and background. We will assess the client’s existing investments given their newly created IPS and will work with them to develop a plan to transition from their existing portfolio to a revised portfolio recommended by us, consistent with their updated personal IPS. There is no minimum account size for Archer Bay Capital’s fee-based Investment Management services and fees are negotiable. Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation, growth, income, or growth, and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors, and the fees for this service will be explained and established. (Please see Item 5 - Fees & Compensation, of this brochure for further information on fees for this service.) The Advisor’s representatives will continuously monitor the client’s portfolio holdings and its overall asset allocation strategy. Financial planning and reviews of existing portfolios are included as part of the Investment Management service. Investment Review Services Investment Review services provide a consultative assessment of a client’s existing investment portfolio for individuals, endowments, businesses, and non-profit organizations. The assessment will include a risk/reward profile of invested mutual funds, ETFs, individual stocks and bonds, retirement plans, and overall asset allocation. There is no minimum account size for Archer Bay Capital’s Investment Review services. (Please see Item 5 - Fees & Compensation of this brochure for further information on fees about this service.) Financial Planning Services Archer Bay Capital provides financial planning services on a variety of topics. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to forecast future cash flows, asset values, and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they affect and are affected by the entire financial and life situation of the client. Clients purchasing this service will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve their stated financial goals and objectives. There is no minimum account size for Archer Bay Capital’s fee-based financial planning services. (Please see Item 5 – Fees & Compensation, of this brochure for further information on fees about this service.) In general, the Financial Plan will address any or all the following areas of concern. The client and Advisor Representative will work together to select the specific areas to cover. These areas may include, but are not limited to, the following: • Cash Flow & Debt Management - We will conduct a review of a client’s income and expenses to determine their current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed a client’s income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. • Financial Goals - We will help clients identify financial goals and develop a plan to reach them. We will identify what a client plans to accomplish, what resources are required to achieve the goal, how much time will be needed to reach the goal, and how much should be budgeted for the goal. 5  • Investment Analysis - This may involve developing an asset allocation strategy to meet a client’s financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting in the establishment of an investment account at a selected broker/dealer or custodian. • Retirement Planning - Our retirement planning services typically include projections of the likelihood of achieving financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). If a client is near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to alter spending during retirement years adversely. ‐ • Risk Management - A risk management review includes an analysis of client exposure to major risks that could have a significant adverse impact on their financial picture (such as premature death, disability, property and casualty losses, or the need for long term care planning). Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self insuring”). ‐ • Tax Planning Strategies - Advice may include ways to minimize current and future income taxes as a part of an overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with the consideration that there is always a possibility of future changes to federal, state, or local tax laws and rates that may impact a client’s situation. (Archer Bay Capital recommends that clients consult with a qualified tax professional before initiating any tax planning strategy. We may provide clients with contact information for accountants or attorneys who specialize in this area if they wish to hire someone for such purposes. We will be glad to participate in meetings or phone calls between the client and their tax professional, if needed.) Educational Seminars & Speaking Engagements Archer Bay Capital may provide seminars on an “as announced” basis for groups seeking general advice on investments and other areas of personal finance. The content of these seminars will vary depending upon the needs of the attendees. These seminars are purely educational and do not involve the sale of any investment products. Information presented will not be based on any individual’s person’s need, nor does Archer Bay Capital provide individualized investment advice to attendees during these seminars. Fees may be charged either to participants, through a pre-determined ticket price, or to a sponsoring company via a flat fee. ERISA Account Advice Archer Bay Capital provides investment advice to Advisory clients that are employee benefit plans or other retirement accounts (i.e., IRAs) for a level fee; assets affected by the Department of Labor (“DOL”) Fiduciary Rule. As such, we are considered fiduciaries under the Employee Retirement Income and Securities Act (“ERISA”) and regulations under the Internal Revenue Code of 1986 (the “Code”), which requires that we abide by the Impartial Conduct Standards, as defined by ERISA. To comply with these standards, our Firm and our investment advisor representatives provide advice that is in our clients’ best interest and charge no more than reasonable compensation [within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)]. We make no misleading statements about investment transactions, compensation, conflicts of interest, or any other matters related to investment decisions. By our business practices outlined above, we believe ourselves to be a “Level Fee Fiduciary” under the DOL’s Rule. As a Level-Fee Fiduciary, we maintain a non-variable compensation structure provided either based on a fixed percentage of the value of assets or a set fee that does not vary with the particular investment recommended, as opposed to a commission or other transaction-based fee. As a “Level Fee Fiduciary”, while we are held to the DOL fiduciary standards of care, we are subject to fewer disclosures and reporting requirements than Advisors operating under a different business model. 6  Employee Benefit Plan Services Archer Bay Capital also provides Advisory services to participant-directed employee retirement benefit plans. Archer Bay Capital will analyze such plan’s current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered, and restrictions that may be imposed. Archer Bay Capital will recommend investment options it believes will best achieve the plan’s objectives, provide participant education meetings, and monitor the performance of the plan’s investment vehicles. We will also recommend changes in the plan’s investment vehicles as may be appropriate from time to time and will review the plan’s investment vehicles and investment policy as necessary. WRAP Program The Advisor does not sponsor nor provides investment management services to a WRAP program. Other IARs under other group names at Integrated offer WRAP programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro-rata for services provided through to the date of termination. If the client made an advance payment, the Advisor will refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, the Advisor will refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees & Compensation Investment Management Investment Management Services Fee Calculations Advisory fees charged are based on a percentage of the client’s assets under management and are established on a client-by-client basis. The specific ways Archer Bay Capital charges its fees are established in each Client Agreement. Generally, clients will be invoiced in advance at the beginning of each calendar quarter based upon the value of their assets under management (market value based on independent third-party sources, or fair market value in the absence of market value). The standard Investment Management Services annual fee will be charged as a percentage of assets under management. Assets Under Management Annual Fee Up to $5,000,000 0.75% $5,000,001 to $10,000,000 0.65% Over $10,000,000 0.55% Note: Lower fees for comparable services can at times be available from other sources. Investment Management service fees are negotiable. Investment Management service fees are based on assets under management (“AUM”) and will be calculated per annum, charged quarterly, according to the schedule above. New 7  accounts are charged a pro-rated fee for the remainder of the quarter in which the account is incepted (date of first trade). Investment Management Services Fee Billing Archer Bay Capital’s clients agree to pay an asset-based fee (Advisory fee) calculated according to the tiered Fee Schedule above, calculated on assets under management at their end-of-quarter account value. Quarterly fees between 0.125% and 0.3125% will be assessed. Archer Bay Capital will request authority from the client to receive its quarterly payment Advisory fees directly from the client’s account held at their independent qualified Custodian. The client’s independent qualified Custodian will maintain actual custody of their assets. While Archer Bay Capital requires its clients to authorize it to deduct fees from their account(s) held by their Custodian, clients must provide Archer Bay Capital with written limited authorization to allow the Investment Advisor to withdraw management fees from their account. Clients may elect to have their quarterly fees charged to either one account or split between their other accounts. The Advisor’s fees are due and will be debited, from the client’s Custodial account(s), in the first month following the end of the quarter (January, April, July, October). Clients will receive Custodial statements showing Archer Bay Capital’s Advisory fees being debited from their account. To bill an account, Archer Bay Capital will: • Obtain written authorization from the client, permitting Archer Bay Capital to be paid directly from the • client’s account, held by their Custodian. Instruct the Custodian to send the client statements at least quarterly, to the email or postal mailing address the client provided to the Custodian, showing all disbursements for the account, including the amounts of any assessed Advisory fees. Investment Management Account Terminations A Client Investment Management Agreement (“Advisory Agreement”) may be canceled at any time, by either party, for any reason upon receipt of written notice. Upon termination of any account at any time after the required notice, a pro-rated invoice for services provided through the termination date will be sent to the client. The client has the right to terminate their Advisory Agreement without penalty within five (5) business days after executing their Advisory Agreement. Effective with the date of termination, Archer Bay Capital shall refrain, without liability or obligation, from taking any further action in a client’s account(s). From the date of termination, Archer Bay Capital will cease to be entitled to receive fees. Cancellation will be subject to any changes related to the settlement of transactions in progress. Any unearned pre-paid fees will be refunded to the client on a pro-rata basis based on the date of termination. Employee Benefit Plan Services Fees Note: Employee Benefit Retirement Plan Services annual fees are charged as a percentage of assets within the plan, according to the above-quoted fees for Investment Management Services fees, for ongoing management of assets. For a review of plans that does not include management of assets, a negotiable fixed fee will be charged. Employee Benefit Plan Services Fee Billing Employee Benefit Plan Services Billing follows the same procedures as “Investment Management Account Billing,” above for management of assets. Please refer to that section, for billing specifics. For an Investment Review of an Employee Benefit Plan, a negotiable fixed fee applies. Investment Review Fees Investment Reviews will generally be offered on a fixed fee basis. Fees are negotiable and must be paid by electronic funds transfer or by check at the end of the service; cash is not accepted. 8  Investment Review Fee Billing Clients will receive an invoice for Investment Review fees due upon the delivery of the financial plan and a review of results with the client. Payment is due within 30 days of invoice receipt; cash is not accepted. Financial Planning Fees Financial Planning will generally be offered on a fixed fee basis. Fees are negotiable and must be paid by electronic funds transfer or by check; cash is not accepted. Financial Planning Fee Billing If a Financial Planning fixed fee program is chosen, clients will receive an invoice for the delivery of their financial plan and a review of results with the client. Fees for this service may be paid by electronic funds transfer or check. Fees are negotiable and are payable within 30 days of invoice receipt. Integrated Fee Disclosure The clients of Archer Bay Capital will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. IARs of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Archer Bay Capital’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Archer Bay Capital’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee-only basis, and no associated persons shall earn compensation based on a securities transaction (i.e., commission), including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-Advisers selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The Advisor, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent, the client’s separately managed portfolio includes such proprietary products, the Advisor will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. No-load or load-waived mutual funds may be used in client portfolios, so there would be no initial or deferred sales charges; however if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the Advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases, there may be fees charged, which are a result of brokered trading activity by associated personnel of the Advisor that is outside of the constructs of the Advisor’s investment advisory portfolios and are thus not included 9  in the management fee. These trades are generally at the request of the client. The fees may vary in size, depending on the nature of the client’s requests. Conflict of Interest Between Different Fee Structures The Advisor offers several different services detailed in this brochure that compensate the Advisor differently depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Advisor mitigates this conflict through its procedures to review client accounts relative to the client’s or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Advisor is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated who do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, foundations and endowments, businesses, and non-profit organizations. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums There is no minimum account size for Archer Bay Capital’s fee-based financial planning or investment review services. There is not an account minimum for investment management accounts and fees are negotiable. The annual investment management fee includes financial planning services at no additional charge. There are no ongoing contribution requirements for client accounts. Other advisory groups of Integrated have minimum account sizes. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor, which are described below: 10  Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staff. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Archer Bay Capital’s Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor may invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. 11  Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed-income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flow from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds, or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task 12  management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel, and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Advisor faces inherent conflicts of interest, which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities, where there is a ready market that is traded through an exchange, are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in the price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial 13  withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Advisor and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Archer Bay Capital. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer, and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Advisor may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Advisor on behalf of any client or is being considered for purchase or sale. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal 14  trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage/Custodian Selection and Soft Dollars The Advisor has the authority over the selection of the broker/custodian to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, the Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. The Advisor is not required to negotiate “execution-only” commission rates. Thus the client may be deemed to be paying for research and related services (i.e., “soft dollars”) provided by the broker, which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies, and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, databases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that are managed and/or advised on (see Item 15—Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). The client should consider these conflicts of interest when selecting a custodian. When considering whether the terms that custodians provide are, overall, most advantageous to the client when compared with other available providers and their services, Archer Bay Capital takes into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for client accounts), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to Archer Bay Capital and its clients, and the availability of other products and services that benefit Archer Bay Capital. 15  Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. Archer Bay Capital is not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although Archer Bay Capital is not required to execute all trades through the custodian selected, Archer Bay Capital has determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer, clients may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide Integrated and its clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through Integrated. The custodians also make available various support services. Some of those services help Integrated manage or administer clients' accounts, while others help Archer Bay Capital manage and grow its business. The support services are generally available on an unsolicited basis (Integrated doesn't have to request them) and at no charge to Integrated . Some of these support services are as follows: Services that benefit the client: Institutional 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 Integrated might not otherwise have access or that would require a significantly higher minimum initial investment by clients. The services described in this paragraph generally benefit clients and their accounts. Services that do not directly benefit the client: Other products and services that benefit Integrated but do not directly benefit clients or client accounts are also available. These products and services assist Integrated in managing and administering its clients' accounts and operating the firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waive their fees for some of these services or pay all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would 16  be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavor at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon Integrated committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that Integrated receives these benefits from a specific custodian is an incentive for the firm to recommend the use of said custodian rather than making such a decision based exclusively on clients’ interests in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendation of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts, or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor’s written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor’s transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor’s, account’s or fund’s participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account, or fund as detailed in any written agreement. No additional compensation shall result from the proposed allocation. No client/investor, account, or fund will be favored over any other client/investor, account, or fund as a result of the allocation. 17  • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. The basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker-dealers or third-parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances, a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms that do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client’s account, the Advisor may be precluded from aggregating that client’s transaction with other accounts, which may result in less favorable security prices and/or higher transaction costs. Item 13 –Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client’s current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account, and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client’s financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. 18  Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals, which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate for referring parties to these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing letters of authorization with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Advisor submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisors to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such a document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be 19  bought or sold. The Advisor’s discretionary authority regarding investments may, however, be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of businesses or industries. All such restrictions are to be agreed upon in writing at the account’s inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to, and the Advisor has not been the subject of a bankruptcy petition in the last ten years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 20 

Item 1 – Cover Sheet Mosaic Financial Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 40 Philadelphia Drive, Suite 101 Chico, CA 95973 (307) 256-6931 www.mosaicfinancialsolutions.com March 28, 2025 This brochure provides information about the qualifications and business practices of Mosaic Financial Solutions, LLC. If you have any questions about the contents of this brochure, please contact us at: (307) 256-6931, or by email at: anna@mosaicfinancialsolutions.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Mosaic Financial Solutions Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Mosaic Financial Solutions’ current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure at Adviser through adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update Item 5 – Fees & Compensation has been updated since the last update March 27, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................3 Item 4 – Advisory Business .....................................................................................................................................4 Item 5 - Fees and Compensation ..............................................................................................................................6 Item 6 – Performance Fees .......................................................................................................................................7 Item 7 – Types of Clients .........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................8 Item 9 – Disciplinary Information ............................................................................................................................9 Item 10 – Other Financial Industry Activities and Affiliations ..............................................................................10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .........................10 Item 12 – Brokerage Practices................................................................................................................................11 Item 13 – Review of Accounts ...............................................................................................................................14 Item 14 – Client Referrals and Other Compensation .............................................................................................14 Item 15 – Custody ..................................................................................................................................................14 Item 16 – Investment Discretion ............................................................................................................................15 Item 17 – Voting Client Securities .........................................................................................................................15 Item 18 – Financial Information .............................................................................................................................15 3  Item 4 – Advisory Business Firm Description Mosaic Financial Solutions, LLC, is a dba of the registered entity Integrated Advisors Network LLC, hereinafter collectively referred to as “the Adviser” or “Mosaic Financial” or “Mosaic”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only financial planning firm. The Adviser provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. The Firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has associated persons who are in other fields where they receive commissions as compensation. The Adviser is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated do not act as a custodian of client assets and the client always maintains asset control. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s, Integrated’s, or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides financial planning services and may furnish advice to clients on matters not involving securities. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Mosaic Financial is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network, LLC. Anna Nelson is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment policy statements may also be created that reflect the stated goals and objective. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual 4  meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Mosaic through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Mosaic is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITS”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Mosaic. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no- load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Mosaic may offer/manage a more active options strategy that is based on the fundamental and/or technical evaluation of each company to determine attractive prices to buy or sell options. Initial public offerings (IPOs) are not available through Integrated. Financial Planning Mosaic Financial through Integrated will typically provide a variety of financial planning services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning, charitable planning, education planning, and business planning. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Adviser may also refer clients to an accountant, attorney, or other specialist. For planning engagements, Adviser will provide a summary of client’s financial situation, observations, and recommendations. For consulting engagements, Adviser may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Mosaic Financial whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Adviser or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Adviser does not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Mosaic Financial or use the services of Mosaic Financial. 5  Termination of Agreements A client may terminate any of the agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser may terminate any of the agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 5 - Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in arrears. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s fee can range from .60% to 1.0% depending upon the underlying factors of each portfolio. The Advisor is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Advisor does not act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Financial Planning /Tangible Property Fees The Financial Planning fee will be determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. As our fee is based on each client's personal situation, complexity of the service, and time commitment required, we will provide an estimate of the total fee at the start of the advisory relationship. Financial planning fees are negotiable but generally fees are charged at the rate of $50 to $200 an hour or by a monthly subscription fee that generally ranges from $100 to $300. The Adviser may also provide general non‐ securities advice on topics that may include tax and budgetary planning, estate planning and business planning. This is considered an integral part of the financial planning process and does not generate a separate fee. On occasion, the Adviser may enter into an agreement to offer financial consultation at a similar hourly rate as the financial planning rate. Clients of the Adviser, however, are under no obligation to act upon any recommendations of the Adviser or to affect any transactions through the Adviser if they decide to follow the Adviser’s recommendations. Fee Billing Financial Planning Fixed Fee Financial Planning will generally be offered on a fixed fee basis. Financial Planning consists of an upfront set- up fee ranging from $500.00 - $2,500.00. There will be an ongoing monthly fee which will range from $100.00 - $300.00, per month, in advance. The fixed fee is determined by the complexity of the client’s needs and financial plan and will be agreed upon before the start of any work. In the event of early termination, the client will be billed for 6  the hours worked at a rate of $200.00 per hour. If the initial deposit is greater than the amount billed, then the client will be refunded the difference. If the initial deposit is less, then the client will be billed the difference. Financial Planning Hourly Fee Financial Planning fee is an hourly rate between $50 to $200 per hour. The fee may be negotiable in certain cases and is due at the completion of the engagement. In the event of early termination by client, any fees for the hours already worked will be due. Integrated Fee Disclosure The clients of Mosaic will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Mosaic’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Mosaic’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. Mosaic Financial is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), respectively. As such, our Firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, Mosaic Financial, LLC may only charge fees for investment advice about products for which our Firm and/or our related persons do not receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our Firm and/or our related persons receive commissions or 12b-1 fees, however, only when such fees are used to offset Mosaic Financials’ advisory fees. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investors’ personal financial situation to ensure the financial planning service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. 7  Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums The Adviser in general, does not require a minimum dollar amount to open and maintain an advisory account. Pre- existing advisory client are subject to Mosaic Financial, LLC's minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our Firm's minimum account requirements will differ among clients. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness, or accuracy of such information and data, and in some cases, complete and accurate information is not available. 8  Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Adviser and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. 9  Item 10 – Other Financial Industry Activities and Affiliations Affiliations Neither Mosaic Financial nor any of its management persons has any material relationship or arrangement with any related financial industry participant. Mosaic Financial has recommended other investment advisers, when Mosaic Financial determined that it was in the best interest of the client. Mosaic Financial Prudent Portfolios, LLC endeavors at all times to put the interest of its clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps to address this conflict: • We disclose to clients the existence of all material conflicts of interest; • We disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies; • We collect, maintain, and document accurate, complete and relevant client background information, including the client’s financial goals, objectives, and risk tolerance; • Our Firm's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances; • We require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed; • We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our Firm; and • We educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. On occasion, the Adviser (a related person) may act as a consultant to government, public and private entities concerning their pension and profit-sharing plans. In this capacity the Adviser provides general investment advice about the merits and risks of the investment alternatives available. The plan fiduciary is free to seek independent advice about the appropriateness of any investment for the plan. The Adviser may act as a consultant to government, public, and private entities concerning their pension and profit shared plans, primarily participant education. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. 10  Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement 11  directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting 12  Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage, but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. 13  Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and its registered Investment Adviser Representatives who review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 – Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated 14  third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 15 

Item 1 – Cover Sheet Capital City Financial Partners, LLC Form Adv Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 6208 Garners Ferry Road, Suite A Columbia, South Carolina 29209 250 Berryhill Road, Suite 510 Columbia, SC 29210 124 Verdae Blvd, Suite 403 Greenville, SC 29607 1200 Ridgefield Boulevard, Suite 261 Asheville, NC 28806 (803) 782-0671 https://capitalcityfinancialpartners.com March 28, 2025 This brochure provides information about the qualifications and business practices of Capital City Financial Partners, LLC. If you have any questions about the contents of this brochure, please contact us at: (803) 782-0671, or by email at: katherine@capitalcityfp.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Capital City Financial Partners Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure dated March 28, 2025, has been prepared according to the SEC disclosure requirements. SEC’s Investment Adviser Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Capital City Financial Partners’ current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request. Material Changes since the Last Update There have been no material changes since the last update dated March 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................7 Item 7 – Types of Clients ...........................................................................................................................................8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................8 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 ...........................13 Item 12 – Brokerage Practices ..................................................................................................................................13 Item 13 – Review of Accounts .................................................................................................................................17 Item 14 – Client Referrals and Other Compensation ...............................................................................................17 Item 15 - Custody .....................................................................................................................................................18 Item 16 – Investment Discretion ..............................................................................................................................18 Item 17 – Voting Client Securities ...........................................................................................................................19 Item 18 – Financial Information ...............................................................................................................................19 3  Item 4 – Advisory Business Firm Description Capital City Financial Partners, LLC, is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Advisor” or “Capital City”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. The firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has associated persons who are in other fields where they receive commissions as compensation. The Advisor is not affiliated by ownership with entities that sell financial products or securities. The Advisor nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s, or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Capital City is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. There are multiple Investment Adviser Representatives (“IARs”) who work under Capital City. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment policy statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a 4  client’s financial situation and portfolio through regular contact with the client, which often includes an annual meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Capital City through Integrated provides investment advisory services to Clients that are tailored to the Clients’ needs based on their financial situation and investment objectives. Capital City is mindful of each Client’s financial situation, endeavoring to ensure that the Client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of Clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITS”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Capital City. For some Clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load- waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Capital City may offer/manage a more active options strategy that is based on the fundamental and/or technical evaluation of each company to determine attractive prices to buy or sell options. Initial public offerings (IPOs) are not available through Integrated. Financial Planning Capital City through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning, and charitable planning, education planning, and business planning. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Capital City may also refer clients to an accountant, attorney or other specialist. For planning engagements, Advisor will provide a summary of Client’s financial situation, observations, and recommendations. For consulting engagements, Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Capital City whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Capital City or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Capital City nor Integrated do not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Capital City or use the services of Capital City in particular. 5  WRAP Program The Advisor does not sponsor or provide investment management services to a wrap program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A Client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, the Advisor will refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s Fee can range from .3% through 2.00%, depending upon the passive or active nature of the portfolio. In some cases, due to an acquisition of Wall & Co. in 2020, fees are charged quarterly in arrears at the rate of one quarter of the annual fee and are due within the first 15 days following the end of the prior quarter. Financial Planning Fees Financial Planning for clients without $300,000+ under management and for complex situations is provided under a fixed fee arrangement agreed upon at the first meeting and based on an hourly rate ranging between $100 -$250. Fifty percent of the fee is payable in advance, before the financial planning process is started. The remaining fifty percent is payable at the end of the engagement. In some cases, there are flat-fee agreements that are to be paid quarterly. Fee Billing Investment management fees will be billed quarterly in advance or in some cases as indicated in the Investment Management section ay be charged in arrears. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s 3rd party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Financial planning fees are able to be deducted from another specified client account as authorized by the investment management agreement or financial planning agreement. Integrated Fee Disclosure The clients of Capital City will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Capital City’s fees may be higher or lower than 6  other advisory groups at Integrated and there is no representation that Capital City’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisors selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The Advisor, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Advisor will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases there may be fees charged which are a result of brokered trading activity by associated personnel of the Advisor that is outside of the constructs of the Advisor’s investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client the fees may vary in size depending on the nature of the client’s requests. Conflict of Interest Between Different Fee Structures The Advisor offers several different services detailed in this brochure that compensate the Advisor differently depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Advisor mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Advisor is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. 7  There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Capital City’s Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to 8  initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s 9  performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. 10  It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest: In the administration of client accounts, portfolios and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity: Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency: 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. Lack of Registration: Funds or LP interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital: The ability to withdraw funds from the funds or LP interests is usually restricted in 11  accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through our network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of our firm Integrated. The IARs are under the supervision of our firm Integrated, and the advisory services of the IAR are provided through our firm Integrated. Integrated has the arrangement described above with the following Advisor Representatives. Brokerage Affiliations Associated persons of Integrated Advisors Network are registered representatives of a broker-dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated Advisors Network are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors Network. Integrated Advisors Network does not make any representation that the brokerage services are at the lowest cost available and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated Advisors Network. Integrated Advisors Network mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Insurance Affiliations Capital City and /or certain associated persons of Capital City sell insurance products to advisory clients. The clients who purchase insurance-related products are informed that Capital City or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that Capital City and/or the associated persons may sell insurance products to clients of Capital City and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. Capital City makes no assurance that the insurance products are offered at the lowest available cost and it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from Capital City or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Capital City. 12  Other Financial Affiliations CCFP Tax Solutions: CCFP Tax Solutions is a branch of Capital City Financial Partners that provides traditional accounting and tax preparation services. It is anticipated that some of the advisory clients will also be clients of CCFP Tax Solutions. However, clients of Capital City are not required to use the accounting/tax services offered by CCFP Tax Solutions. Capital City does not make any representation that the accounting/tax services are at the lowest cost available, and clients may be able to obtain those services and/or products at a more favorable rate from other firms. The accounting and tax preparation activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated Advisors Network. Services provided by CCFP Tax Solutions shall be pursuant to a separate engagement letter between the client and CCFP Tax Solutions and shall be based on the normal fee structure of the CCFP Tax Solutions. Item 11 – Code of Ethics, Participation or Interest In Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer, and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Advisor, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Advisor, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Advisor and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. 13  In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark- downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. 14  Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of 15  business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each Client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many Clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No Client/investor, account or fund will be favored over any other Client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating Client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the Client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the Client will be precluded 16  from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other Clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a Client's account, the Advisor may be precluded from aggregating that Client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Advisor Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these referrals. 17  Promoter Referrals The Advisor has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Advisor submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the Client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). 18  The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure March 28, 2025 Copper Crest Advisors LLC 5330 Carroll Canyon Rd Suite 100 San Diego, CA 92121 619-350-1944 (phone) 619-937-3705 (fax) firm@coppercrestcapital.com FORM ADV PART 2A – FIRM BROCHURE ITEM 1 – COVER PAGE Form ADV Part 2, our “Disclosure Brochure” or “Brochure”, is required by the Investment Advisers Act of 1940 and is a very important document between a client and their investment adviser. This Part 2A provides information on the Investment Adviser that will be providing advisory services. Integrated Advisors Network, LLC (“Integrated”) offers services through our network of investment advisor representatives (“Advisor Representatives” or “IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The Clients should understand that the businesses are legal entities of the IAR and not of our firm. The IARs are under the supervision of Integrated. The advisory services of the IARs are provided through Integrated. Integrated has the arrangement described above with the following IARs at Copper Crest Advisors LLC: Michael Stephenson, Mason Tucker, Jeff Stephenson and David Foster. This Brochure provides information about the qualifications and business practices of Copper Crest Advisors LLC. Any questions about the contents of this Brochure should be directed to the Adviser by phone at 619-350-1944 or by email at firm@coppercrestcapital.com. Alternatively, contact the Chief Compliance Officer of Integrated, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call 855-729-4222. 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 the Adviser is also available on the SEC’s website at www.adviserinfo.sec.gov. Page | 1  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure ITEM 2 – MATERIAL CHANGES ANNUAL UPDATE This section describes material changes to Copper Crest Advisors Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the Chief Compliance Officer by Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Copper Crest Advisors LLC’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. MATERIAL CHANGES SINCE THE LAST UPDATE There have been no material changes since the last annual updating amendment on March 28, 2024. Page | 2  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure ITEM 3 – TABLE OF CONTENTS Form ADV Part 2A – Firm Brochure .........................1 Item 1 – Cover Page .........................................1 Item 2 – Material Changes ...............................2 Annual Update .............................................2 Material Changes since the last Update ........2 Item 3 – Table of Contents ...............................3 Item 4 – Advisory Business ...............................4 Firm Description ..........................................4 Types of Advisory Services ...........................4 Item 5 – Fees and Compensation .....................5 Fees .............................................................5 Fee Billing ....................................................5 Integrated Fee Disclosure .............................6 Other Fees ...................................................6 Wrap Fee Program .......................................6 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.......................................................... 10 Code of Ethics............................................ 10 Participation or Interest in Client Transactions .............................................. 10 Personal Trading........................................ 10 Item 12 – Brokerage Practices ....................... 11 Brokerage Selection and Soft Dollars ......... 11 Research and Other Benefits ..................... 11 Order Aggregation ..................................... 13 Directing brokerage for Client Referrals ..... 13 Directed Brokerage.................................... 13 Item 13 – Review of Accounts ........................ 13 Periodic Reviews ....................................... 13 Review Triggers ......................................... 14 Regular Reports ......................................... 14 Item 6 – Performance-Based Fees and Side-By- Side Management ............................................6 Item 7 – Types of Clients ..................................6 Description ..................................................6 Account Minimums ......................................6 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ...............................7 Method of Analysis ......................................7 Investment Strategies ..................................7 Risk of Loss ..................................................7 Item 9 – Disciplinary Information ................... 10 Item 10 – Other Financial Industry Activities and Affiliations ..................................................... 10 Brokerage Affiliations ................................. 10 Other Financial Industry Affiliations ........... 10 Item 14 – Client Referrals and Other Compensation ............................................... 14 Related Party Referrals .............................. 14 Solicitor Referrals ...................................... 14 Referrals to Third Parties ........................... 14 Other Compensation ................................. 14 Item 15 – Custody ......................................... 14 Account Statements .................................. 15 Performance Reports................................. 15 Item 16 – Investment Discretion .................... 15 Item 17 – Voting Client Securities .................. 15 Proxy Voting .............................................. 15 Other Corporate Actions ............................ 15 Our Receipt of Materials ............................ 15 Item 18 – Financial Information ..................... 16 Page | 3  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure ITEM 4 – ADVISORY BUSINESS FIRM DESCRIPTION Integrated Advisors Network, LLC was organized as a Limited Liability Company in the State of Delaware in 2015 and is an SEC registered investment adviser (such registration does not imply that the Integrated Advisors Network, LLC has attained a certain level of skill or training). Copper Crest Advisors LLC (dba Copper Crest Capital) is an investment advisory practice group whose principals are Investment Adviser Representatives (“IARs”) associated with Integrated Advisors Network, LLC (“Integrated”). Each investment advisory practice group with Integrated provides their own unique Forms ADV Part 2 (consisting of Parts A and B), customized for their investment advisory style. As such, this Brochure relates to the investment styles, techniques, fees and other disclosures directly related to the practice group, Copper Crest Advisors LLC. The term “Adviser” from this point on shall refer to Copper Crest Advisors LLC investment advisory practice group as it does business through Integrated. The Adviser provides investment management services to clients on a separate account management basis. The Adviser does not sell securities on a commission basis as part of its advisory services. However, Integrated has associated persons who are in other fields where they receive commissions as compensation. Except for the association with Copper Crest CPAs LLP and Copper Crest Insurance Services LLC, Adviser is not affiliated by ownership with entities that sell financial products or securities. Neither Adviser nor Integrated act as a custodian of client assets. Clients will always maintain asset control. The Adviser generally has discretion over client accounts and places trades under a limited power of attorney. If non-discretionary assets are accepted, the Adviser will seek client approval prior to placing a trade on behalf of the client. The Adviser does have discretion over which brokerage firms to trade with and the resulting commissions to be paid and/or where the accounts are held in custody and the resulting expenses related to that custodianship. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Any conflicts of interest arising out of Adviser relationships, or those of its associated persons, are disclosed in this brochure. Integrated Advisors Network, LLC’s principal owner is TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co-Founder & Chief Relationship Officer. The Investment Adviser Representatives of the investment advisory practice group Copper Crest Advisors LLC are Michael Stephenson, Mason Tucker, David Foster and Jeff Stephenson. Details with respect to each of the principals of Copper Crest Advisors LLC can be found in the supplemental Form ADV Part 2B provided under a separate document. TYPES OF ADVISORY SERVICES The Adviser offers the following services under their umbrella of wealth management. Clients are not required to utilize all services. Asset Aggregation Services. The Adviser desires to establish and maintain aggregated financial data for its clients. This means the Adviser will attempt to consolidate all client investment assets into a single source for reporting and analysis. The Adviser believes the highest level of planning and investing is dependent on having access to timely, accurate and comprehensive data. Aggregation is provided in one of two ways, and then generally a combination of both methods is utilized: • Automated Aggregation. Our preference is to use aggregation software to access client financial accounts electronically and automatically. This provides an efficient method to have timely financial data at the Adviser’s fingertips. In most cases, the Adviser can access this data with special, view-only login credentials. • Manual Aggregation. The alternative to automated aggregation is to manually pull financial information from monthly statements. This can be streamlined by exporting and importing certain portions of the data. The aggregated data will assist the Adviser in answering ongoing client inquiries on a timely basis. In certain cases, some form of data aggregation might be required to provide asset allocation and management services. Asset Allocation and Management. The Adviser works directly with each client and/or their families to determine their investment objectives, time horizon and risk tolerance. As part of this process, the Adviser also considers cash flow needs, investment philosophy, asset allocation style, unique circumstances and tax considerations. Client input is valuable to this process Page | 4  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure and forms the basis for designing a written investment policy statement tailored to specific client desires. This investment policy statement will also include any reasonable restrictions clients may impose on investing in certain securities or certain types of securities. The Adviser often finds that many of its clients have significant market knowledge and want to provide input in developing the investment policy statement. The Adviser will encourage client involvement every step of the way. Once the investment policy statement is approved, it becomes the basis for the investment plan. After review and assessment of clients' needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts ("REITs"), exchange-traded funds ("ETFs"), alternative investments, and other securities as chosen by Copper Crest or a third-party manager. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds and ETFs is most appropriate. In these situations, a portfolio of mutual funds and ETFs will be created and client assets will be allocated among these funds and ETFs taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. The tax consequences and the timing of the transition are appropriately addressed in this process. Going forward, the Adviser periodically reviews investment performance and asset allocation. The Adviser uses periodic meetings with clients to determine whether changes are needed to their investment policy statement and related asset allocation. Automatic rebalancing may occur during the year based on parameters preset in the investment policy statement. Special Projects. The Adviser is also available to assist in analyzing investments that clients hold outside of the managed accounts, as well as other tasks clients may desire regarding securities in general. If the Adviser determines that such services require significant time on their part, a separate engagement letter for this work will be proposed. The Adviser will endeavor to complete the work upon a client’s acceptance of an engagement letter in accordance with the underlying terms. Termination of Services. A client may terminate any of the aforementioned services at any time by notifying the Adviser in writing. The Adviser may terminate any of the aforementioned services at any time by notifying the client in writing. Regardless of who terminates the services, clients shall be charged pro rata for services provided through to the date of termination. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non-discretionary basis. ITEM 5 – FEES AND COMPENSATION FEES The fee structure the Adviser has adopted for the services described in Item 4, starting on page 4 is as follows: Asset Aggregation Services. The fees the Adviser charges for aggregation services are based on an estimated time commitment multiplied by hourly rates in the range of $200-$500 depending on the nature and complexity of the tasks. These fees are generally estimated and agreed upon at the beginning of each year. This fee and payment terms will be stated in the advisory contract. Clients may also be charged account processing fees to reflect service fees charged by certain automated data providers. If these fees are included in the advisory contract, the Adviser will pass these fees through at their cost. Asset Allocation and Management Services. The Advisor sets a fee structure separately for each client that takes into consideration the number and complexity of accounts, the anticipated client interaction, and the assets under management for the total relationship. The fees are charged as a percentage of assets under management and generally do not exceed 1% annually. All fees and payment terms will be stated in the advisory contract. Special Projects. For special projects, the Adviser generally bills at an hourly rate associated with the individuals that will be doing the work. Such hourly rates will range from $200-$500 per hour. The Adviser will attempt to estimate its time and the resultant fee in a separate engagement letter. The fee and payment terms will be stated in the engagement letter. The above Asset Allocation and Management Services fees, when combined, are subject to a monthly minimum of $500 per client. The fee and payment terms will be stated in the advisory contract. Husband, wife, and related family trusts are generally considered one client for the fee assessment and the minimum fee rule. All fees, including the minimum fee and the aggregation fee, are negotiable. FEE BILLING The Adviser bills all fees monthly, in arrears. The Adviser never requires fees to be paid in advance. Accounts initiated or terminated during a calendar month will be charged a prorated fee. Integrated generally deducts the fees from one or more of Page | 5  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure the client’s investment accounts. Written authorization to deduct fees from this account (or accounts) is included as part of the advisory contract. INTEGRATED FEE DISCLOSURE The clients of Copper Crest Advisors LLC will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure of each advisory group for specific details. Copper Crest’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Copper Crest’s fees are the lowest available for similar services. OTHER FEES In addition to paying the Adviser’s direct fees, clients will bear a proportionate amount of the aggregate fees and expenses of ETFs, mutual funds and other securities in which they are invested. Mutual funds and ETFs may also charge fees when clients purchase or redeem their funds, known as a “load” or transaction fee, as well as internal management fees and deferred sales charges. Details about these fees are disclosed in the funds’ prospectuses. Additionally, the Adviser’s fees are exclusive of brokerage commissions, transaction fees, third-party management fees and other related costs and expenses imposed by broker- dealers and custodians. Adviser’s general recommendations of ETFs and no-load mutual funds tend to keep fees and costs relatively low. The Adviser may, however, recommend mutual funds that charge a transaction fee upon the purchase or redemption of shares therein when they believe the fund’s historic performance and future prospects justify paying such a fee. Direct fees are the only compensation the Adviser receives for investment advisory services. It does not charge nor receive any portion of commissions, load fees, sales charges or mark-ups on securities recommend for client portfolios. WRAP FEE PROGRAM The Adviser does not offer any form of wrap fee program or similar fee structures for its services. Other IARs under other advisory groups at Integrated do offer wrap programs. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT The Adviser does not charge fees or receive compensation that is based on a share of the capital gains or capital appreciation of managed securities. These types of fees are frequently a characteristic of private investment funds. In the unlikely event the Adviser were to employ these types of investments that do charge a performance fee, it would not participate in these fees. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. ITEM 7 – TYPES OF CLIENTS DESCRIPTION The Adviser provides services to high-net-worth individuals, institutions, certain retirement plans, trusts, estates, charitable organizations, corporations or other business entities directly. Client relationships vary in scope and degree of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. ACCOUNT MINIMUMS While there is no minimum size account or relationship requirement, the Firm does have a minimum monthly fee for investment advisory services as described at Item 5, page 5 of this Brochure. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Page | 6  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS METHOD OF ANALYSIS Security analysis methods may include fundamental analysis, technical analysis and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses and filings with the Securities and Exchange Commission. INVESTMENT STRATEGIES Copper Crest Advisors LLC believes that an investment strategy based on a well-diversified asset allocation and a long-term view consistent with a client’s investment objectives is the best way to achieve investment goals. The Adviser believes it is generally difficult, if not impossible, to effectively time the market in the short-term by attempting to predict market or security price lows and highs as a means of buying and selling investments for profit. It also believes that frequent trading of securities elevates risk and increases transaction costs that we generally seek to minimize. For the asset allocation process, the Adviser prefers to use some form of aggregated data, which would include both managed and held-away investment assets. This allows the entire investment picture to be considered when allocating client’s managed accounts. The Adviser knows this approach makes it a little unique, and indeed requires a little more effort. However, the Adviser believes providing a diversified asset allocation plan for a managed account in isolation can completely over-weight sectors that the client may hold outside of the Adviser’s control. Efforts are made to mitigate this effect by taking into consideration most, if not all, of the client’s investment assets. Though common in the industry, the Adviser does not simply group clients into risk tolerance buckets and then assign them a standard portfolio. The Adviser feels that reviewing resultant risk/reward profiles (performance curves and variance/drawdown analyses) along-side the client as it tweaks asset class allocations is a better approach to gauging client risk tolerance. From there, the asset allocation is developed, accommodating the constraints that have been developed together. Assigning standard, risk- based portfolios is also impractical because of the aggregated asset approach. To achieve a high degree of diversification within each asset class, the Adviser primarily utilizes ETFs and mutual funds that mimic the underlying indices that were used in reviewing the risk/reward profiles with the client. When appropriate and reasonably available, the Adviser may also purchase specific fixed income instruments when enough diversification can be achieved. The Adviser evaluates existing positions within client accounts when devising their personalized investment plan. In many cases, due to client desires or tax consequences, the Adviser may recommend such holdings remain in the portfolio. Because of this, client portfolios may also include a broader range of mutual funds and individual securities than would normally be recommended. Individual securities may include common or preferred stocks, bond debentures, U.S. Government issues, notes, commercial paper, etc. This is not an all-inclusive list. RISK OF LOSS In developing a client’s investment policy statement and recommending asset allocation, the Adviser will rely on information provided by clients, software vendors and certain websites. When research and analyses are based upon commercially available software, rating services, general market and financial information, the Adviser is relying upon the accuracy and validity of the information or capabilities being provided by these vendors. The Adviser will make a reasonable effort to isolate obvious errors in the information received but cannot verify the validity of all information provided. Such errors, those going unnoticed, may or may not affect the advice given to the client. Investing in securities involves risk of loss that the client should be prepared to bear. While the Adviser believes its strategies and investment recommendations are designed to produce reasonable returns for a given level of risk, it cannot guarantee that all client investment objectives or planning goals will be achieved. Past performance is not necessarily indicative of future results. Some investment decisions may result in loss, including loss of the original principal invested. The following are investment risks faced by clients and all investors alike (this list is not all-inclusive): Market Risks Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staff. Page | 7  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non- public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. Although rare, the Adviser may attempt to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage-backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5- year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Regulatory Risks Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Page | 8  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Artificial Intelligence Risks We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information— input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality. Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Security Specific Risks Depending on the nature of the investment management service selected and the securities used to implement the investment strategy, clients will be exposed to risks that are specific to the securities in their particular investment portfolio. Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Clients can review more information about the risks of any representative stock, ETF or mutual fund by reviewing the underlying prospectuses. The Adviser will provide the prospectuses, in PDF format, for any of the securities utilized in their investment plan upon request. Most of the investments recommended are not insured against loss by any governmental agency. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Page | 9  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure ITEM 9 – DISCIPLINARY INFORMATION Copper Crest Advisors LLC, nor any of their principals or employees, have ever been involved in any legal or disciplinary events related to past or present investment advisory clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS BROKERAGE AFFILIATIONS None of the associated persons of the Adviser are registered representatives of any broker-dealer and will never receive a commission or other transactional compensation related to such purchase and sale of products through a broker/dealer. OTHER FINANCIAL INDUSTRY AFFILIATIONS Copper Crest Advisors LLC is affiliated, and has common principals, with two other financial services firms: Copper Crest CPAs LLP. Many of the principals of Copper Crest Advisors LLC are certified public accountants whose licenses are associated with Copper Crest CPAs LLP (the “CPA Firm”). The CPA Firm provides traditional accounting and tax services as well as estate planning and consulting in the same offices as the Adviser. It is anticipated that some of the advisory clients will also be clients of the CPA Firm. Services provided by the CPA Firm shall be pursuant to a separate engagement letter between the client and the CPA Firm and shall be based on the normal fee structure of the CPA Firm. Copper Crest Insurance Services LLC. Mason Tucker and Michael Stephenson, principals of Copper Crest Advisors LLC, are also principals of Copper Crest Insurance Services LLC (the “Insurance Firm”). The Insurance Firm provides brokerage services for property, casualty, commercial, life, health and disability insurance products in the same offices as the Adviser. It is anticipated that some of the Firm’s clients will also be clients of the Insurance Firm. Services provided by the Insurance firm shall be based on the normal commission or fee structure customary for these products and services. Clients are not required to receive services from the CPA Firm, nor are they required to receive services or purchase products from the Insurance Firm, in order to obtain investment advisory services from the Adviser. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING CODE OF ETHICS The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer as well as requiring the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS The Adviser does not affect any principal or agency cross securities transactions on the client’s behalf. PERSONAL TRADING Various ETFs, mutual funds and other securities the Adviser recommends for purchase or sale may be suitable for multiple clients as well as its owners and employees. The Adviser anticipates that in the ordinary course of business, it may buy or sell securities in client accounts that its owners and employees and/or other clients, directly or indirectly, have a position. Subject to satisfying its Code of Ethics and applicable laws, officers, directors and employees of Copper Crest Advisors LLC may trade for their own accounts in the same securities recommended or executed for clients. Adviser’s Code of Ethics does not generally require pre- clearance of employee transactions. Nevertheless, the Adviser’s Code of Ethics is designed to assure that the personal securities Page | 10  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure transactions, activities and interests of its employees, will not interfere with their decision making in the best interest of advisory clients. The Adviser, its members and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which may not be deemed appropriate to buy or sell for any client. The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. ITEM 12 – BROKERAGE PRACTICES BROKERAGE SELECTION AND SOFT DOLLARS The Adviser generally has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, the Adviser will seek to achieve the best execution possible. However, this does not require that the Adviser solicit competitive bids, nor does it have an obligation to seek the lowest available commission cost. The Adviser is not required to negotiate "execution only" commission rates, therefore the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with software, data bases and other technical services utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. RESEARCH AND OTHER BENEFITS Neither Integrated nor the Adviser maintain custody of client assets that are managed and/or advised on (see Item 15—Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client will decide whether to do so and will open your account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange- traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. Page | 11  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer, you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 that we might not otherwise have access to or that would require a significantly higher minimum initial investment by clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: Provide access to client account data (such as duplicate trade confirmations and account statements) Facilitate trade execution and allocate aggregated trade orders for multiple client accounts Provide pricing and other market data Facilitate payment of our fees from our clients' accounts Assist with back-office functions, recordkeeping, and client reporting • • • • • Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: Educational conferences and events Consulting on technology and business needs Consulting on legal and compliance related needs Publications and conferences on practice management and business succession Access to employee benefits providers, human capital consultants, and insurance providers • • • • • • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Adviser and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Adviser because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody. The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, Page | 12  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. ORDER AGGREGATION A client’s investment plan is unique and developed independent of other clients. Although more than one investment plan may be developed simultaneously, it is unlikely that any two plans would be implemented or rebalanced on the same date and thus warrant the use of trade aggregation. Transactions for client accounts will therefore will generally executed independently, and this may result in less favorable transaction rates or greater price spreads than in situations where trades for multiple accounts could have been aggregated. When working large orders among multiple accounts, the Adviser may choose to aggregate the same transaction in the same securities for the multiple accounts. Accounts in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement if any. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system based on the following: • • • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation worksheet created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd-lot that is less than 1 share for an account, the allocation will be rounded up to a whole share. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. • No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. In general, the Adviser will infrequently aggregate orders for average price execution among accounts. Even when aggregation would be available for a particular anticipated trade, Adviser may not elect to aggregate the execution in Advisor’s sole discretion. In no case shall Advisor’s decision to aggregate or not aggregate a trade be done with the intention of favoring any account over another. DIRECTING BROKERAGE FOR CLIENT REFERRALS The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. DIRECTED BROKERAGE Although the Adviser allows Clients to direct brokerage, the Adviser does not require clients to direct brokerage. In the event a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts, average pricing or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in lower or higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts that are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms that do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other Clients whose accounts are not so restricted. ITEM 13 – REVIEW OF ACCOUNTS PERIODIC REVIEWS Account reviewers are members of the firm, CCO and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each Page | 13  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure security will contribute to the investment objectives of the client. Client accounts are reviewed by one of the Investment Adviser Representative responsible for the account and the Chief Compliance Officer also performs random reviews. REVIEW TRIGGERS Accounts are reviewed annually or more frequently when market conditions dictate or if provided for in the advisory contract. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. REGULAR REPORTS Clients will receive periodic reports as determined by their advisory contract. The written reports may include account valuation, performance (stated in dollars and as a percent), portfolio holdings and other reports that we agree to provide at the client’s direction. Clients will also receive statements of account positions and activity no less than quarterly directly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but as often as monthly. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION RELATED PARTY REFERRALS As discussed at Item 10, page 10 of this Brochure, Copper Crest Capital LLC is closely associated, through ownership and affiliation, to a CPA Firm and an Insurance Firm. Recommendations to clients of the Adviser for services of either of those related entities will provide an indirect benefit to the principals of the Firm. Likewise, a recommendation from the CPA Firm or the Insurance Firm to the Adviser shall result in an indirect benefit to the principals of the CPA Firm and/or the Insurance Firm. Any fees charged by these related entities for services provided are customary and separate from fees charged by the Adviser. SOLICITOR REFERRALS The Adviser does not engage in solicitation activities as defined by statute. REFERRALS TO THIRD PARTIES The Adviser may also provide clients with referrals to various other third-party professionals, such as attorneys or real estate agents, as a complementary service. The Adviser does not have an agreement with or receive referral fees from these professionals for these informal referrals. OTHER COMPENSATION The only compensation the Adviser receives from the client for investment advisory services are those fees pursuant to the advisory contract. These fees are described at Item 5, page 5 of this Brochure. The Adviser does not receive any additional compensation, direct or indirect, related to providing investment advisory services. ITEM 15 – CUSTODY The Adviser does not accept or permit the Firm, or its associated persons in their capacity as investment adviser representatives, from obtaining custody of advisory client assets including access to cash, securities, acting as trustee, provide direct bill paying services, having password access to control financial account activity or any other similar form of advisory client asset control. All checks or wire transfers to fund client accounts are required to be made out to/sent to the advisory account custodians. All Advisers are generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) if the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser believes they have met the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Page | 14  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure ACCOUNT STATEMENTS All assets are held with qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. PERFORMANCE REPORTS Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. ITEM 16 – INVESTMENT DISCRETION The Adviser generally obtains limited discretionary authority to transact portfolio securities accounts on the client’s behalf. Discretionary authority is granted either through the advisory contract and/or by a separate limited power of attorney where such document is required by the custodian. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. Adviser may also have authority to choose a third-party manager on client’s behalf when asset allocation of a portion of client’s portfolio to third-party managers has been adopted as part of the client’s investment program. The Adviser’s discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of businesses or industries. All such restrictions are to be agreed upon in writing at the account's inception. Certain clients may make recommendations for securities they wish to see included in their accounts. Accounts with such client directed trading activity may outperform or underperform the securities Adviser would traditionally utilize for the related asset class. Assuming we are able to properly categorize such securities into our asset allocation models, we generally follow the client’s request; however, if such trading activity becomes too active, Adviser will provide an updated advisory agreement with an appropriate fee structure for the higher activity trading style. Certain client relationships/accounts do not have discretionary authority. The Adviser will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). Through the advisory contract, clients give the Adviser discretion to select the custodian to be used and the commission rates paid on their accounts. The Adviser does not receive any portion of the transaction fees or commissions paid by client accounts to the custodian on securities transactions. ITEM 17 – VOTING CLIENT SECURITIES PROXY VOTING The Adviser will not vote, nor advise clients how to vote, proxies for securities held in their accounts. The client maintains the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. OTHER CORPORATE ACTIONS The Adviser will have no power, authority, responsibility, or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in a client’s account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving their assets. OUR RECEIPT OF MATERIALS Clients will receive proxies or other solicitations directly from their selected custodian or transfer agent. If the Adviser receives correspondence relating to the voting of client securities, class action litigation, or other corporate actions, it will forward the correspondence to the client’s address of record or to another entity such as the client’s attorney if directed to do so. Page | 15  Copper Crest Advisors LLC Form ADV Part 2A Firm Brochure ITEM 18 – FINANCIAL INFORMATION The Adviser does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to, and the Adviser has never been the subject of a bankruptcy petition. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. Page | 16 

Item 1 – Cover Sheet Open Network Financial Consulting Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 106 Fordham Road West Newton, MA 02465 (617) 797-7617 March 28, 2025 This brochure provides information about the qualifications and business practices of Open Network Financial Consulting. If you have any questions about the contents of this brochure, please contact us at (617) 797-7617, or by email at: marklublin@opennetworkfinancial.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Open Network Financial Consulting Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. the SEC’s Investment Public Disclosure website Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Open Network Financial Consulting’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure at Adviser through adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update Item 5 – Financial Planning Fees has been updated since the last update March 27, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ........................................................................................................................................... 1 Item 2 – Material Changes ................................................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................... 3 Item 4 – Advisory Business ................................................................................................................................. 4 Item 5 – Fees and Compensation .......................................................................................................................... 6 Item 6 – Performance Fees ................................................................................................................................... 8 Item 7 – Types of Clients ..................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................. 8 Item 9 – Disciplinary Information ...................................................................................................................... 12 Item 10 Other Financial Industry Activities and Affiliations ............................................................................... 12 Item 11 – Code of Ethics.................................................................................................................................... 13 Item 12 – Brokerage Practices............................................................................................................................ 13 Item 13 – Review of Accounts ........................................................................................................................... 17 Item 14 – Client Referrals and Other Compensation ........................................................................................... 18 Item 15 - Custody .............................................................................................................................................. 18 Item 16 – Investment Discretion ........................................................................................................................ 18 Item 17 – Voting Client Securities ..................................................................................................................... 19 Item 18 Financial Information ............................................................................................................................ 19 3  Item 4 – Advisory Business Firm Description Open Network Financial Consulting is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser” or “Open Network”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Adviser does not have discretion of client accounts and requires the consent of each client for all security trades. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Adviser’s or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Open Network Financial Consulting is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Mark B. Lublin is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment Policy Statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual 4  meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Open Network through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Open Network is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Open Network. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load- waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Initial public offerings (IPOs) are not available through the Adviser. Financial Planning Open Network will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning, and charitable planning, education planning, and business planning. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Open Network may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of client’s financial situation, observations, and recommendations. For consulting engagements, Adviser may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Open Network whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Open Network or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Open Network nor Integrated do not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Open Network or use the services of Open Network in particular. Wealth Coaching, Second Opinions & Financial Analysis Fees Open Network may provide coaching services that typically do not include investment advisory or management services, financial planning services, nor the review or monitoring of a client's investment portfolio. The Adviser may recommend the services of other professionals for implementation purposes. The client is under no obligation 5  to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Adviser. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Adviser if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Adviser’s previous recommendations and/or services. WRAP Program The Adviser does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. The Adviser’s Fee can range from .50% through 2.00%, depending upon the passive or active nature of the portfolio. Investment management fees will be billed quarterly in advance. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Financial Planning Fees Financial Planning for clients, which includes complex situations is provided under a fixed fee arrangement agreed upon at the first meeting and billed monthly. These services can be provided based on either (a) an hourly rate of up to $350/hr.; (b) a range of $1500-$7500 for one off calculations or plans, or (c) through an annual subscription to wealth management, account aggregation and financial planning for those without assets under management, billed monthly up to $500 per person in the household. These rates are increased depending on the complexity and time involved with the engagement. Certain financial plans require fifty percent of the fee payable in advance before the financial planning process is started. The remaining fifty percent is then payable at the end of the engagement. Advisor will not charge a prepayment of more than $1200 in fees more than 6 months in advance. 6  Wealth Coaching, Second Opinions & Financial Analysis Fees Open Network provides a range of education, coaching and analysis services including "second opinions" on existing investment portfolios. These services can be provided based on either (a) an hourly rate of $200/hr.; (b) a range of $500-$2500 for one off calculations or plans, or (c) through an annual subscription to wealth management, account aggregation & financial planning for those without assets under management, billed monthly at $1,200 annually per person in the household. Open Network may require that fifty percent of the fee be payable in advance, before the financial planning process is started. The remaining fifty percent is then payable at the end of the engagement. Integrated Fee Disclosure The clients of Open Network will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Open Network’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Open Network’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Adviser is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets, and the client always maintains 7  asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Adviser may employ certain types of investments that do charge a performance fee in which the Adviser does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $250,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: 8  Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Open Network’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly 9  volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Adviser may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Adviser may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Adviser’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Adviser’s investments to decline. Some foreign 10  currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Adviser’s foreign currency holdings. If the Adviser enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Adviser enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards. There may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. 11  Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 Other Financial Industry Activities and Affiliations Brokerage Affiliations No members of Open Network are registered representatives of a broker dealer. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Open Network. Insurance Affiliations Open Network and/or certain associated persons of Open Network may sell insurance products to advisory clients. The clients who purchase insurance related products are informed that Open Network or the associated person will be compensated for a fee or commission at the time that the product is accepted. A conflict of interest exists in that Open Network and/or the associated persons may sell insurance products to clients of Open Network and earn a commission on the sale of that product in addition to receiving compensation for providing investment management services. Open Network makes no assurance that the insurance products are offered at the lowest available cost and 12  it is not mandatory that the client purchase insurance products, nor is it mandatory that products be purchased from Open Network or its affiliated personnel. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Open Network. Our Firm offers services through our network of investment advisor representatives (“Investment Adviser Representatives” or “IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of our Firm, Integrated Advisors Network. The IARs are under the supervision of our Firm, Integrated Advisors Network, and the advisory services of the IAR are provided through our Firm, Integrated Advisors Network. Item 11 – Code of Ethics Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for 13  trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark- ups or mark- downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer 14  you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance 15  consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. 16  In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage, but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. 17  Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Solicitor Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be 18  bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 19 

Item 1 – Cover Sheet Ely Prudent Portfolios Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 40 Philadelphia Drive, Suite 101 Chico, CA 95973 (530) 895-0636 http://elyportfolios.com March 28, 2025 This brochure provides information about the qualifications and business practices of Ely Prudent Portfolios, LLC. If you have any questions about the contents of this brochure, please contact us at: (530) 895-0636, or by email at: gtely@elyportfolios.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Ely Prudent Portfolios Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025 has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Ely Prudent Portfolios’ current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801- 96203 or upon request through the client’s IAR. Material Changes since the Last Update Item 5 – Fees and Compensation The Investment Management Fees have been updated effective February 2025. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................3 Item 4 – Advisory Business .....................................................................................................................................4 Item 5 – Fees and Compensation .............................................................................................................................7 Item 6 – Performance Fees .......................................................................................................................................9 Item 7 – Types of Clients .........................................................................................................................................9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................10 Item 9 – Disciplinary Information ..........................................................................................................................13 Item 10 – Other Financial Industry Activities and Affiliations ..............................................................................14 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .........................14 Item 12 – Brokerage Practices................................................................................................................................15 Item 13 – Review of Accounts ...............................................................................................................................19 Item 14 – Client Referrals and Other Compensation .............................................................................................19 Item 15 – Custody ..................................................................................................................................................19 Item 16 – Investment Discretion ............................................................................................................................20 Item 17 – Voting Client Securities .........................................................................................................................20 Item 18 – Financial Information .............................................................................................................................20 3  Item 4 – Advisory Business Firm Description Ely Prudent Portfolios, LLC, is a dba of the registered entity Integrated Advisors Network LLC, hereinafter collectively referred to as “the Advisor” or “EPP” was founded in 2007. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides personalized investment advice primarily to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Firm is not affiliated by ownership with entities that sell financial products or securities. The Advisor nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s, or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. EPP is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Guerdon Ely is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IAR utilizing Integrated’s programs. Investment policy statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual 4  meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management EPP through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. EPP is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITS”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by EPP. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no- load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. EPP may offer/manage a more active options strategy that is based on the fundamental and/or technical evaluation of each company to determine attractive prices to buy or sell options. Initial public offerings (IPOs) are not available through Integrated. Financial Planning EPP through Integrated will typically provide a variety of financial planning services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning, charitable planning, education planning, and business planning. The 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 clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. The Advisor may also refer clients to an accountant, attorney, or other specialist. For planning engagements, the Advisor will provide a summary of client’s financial situation, observations, and recommendations. For consulting engagements, Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for EPP whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. The Advisor or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. The Advisor nor Integrated do not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of EPP or use the services of EPP. 5  Defined Contribution Plan or Defined Benefit Plan The Advisor determines, reviews, and changes the allocation and diversification of the Plan’s Securities Portfolio and executes asset allocation software models using variables suitable for the Plan in order to maintain the relative percentages of asset classes within the parameters set forth in the IPS on a quarterly basis. The Advisor purchases, retains, and sells securities consistent with the investment objectives and asset allocation needs set forth in the IPS. The Advisor reports the investment results of the Plan’s Securities Portfolio at least monthly and review the reports and accompanying graphics concerning the investment performance of the Plan’s Securities Portfolio with the client at least semi-annually to assist it in understanding their contents. The Advisor conducts meetings with the client, as needed, to discuss the performance of the Plan's Securities Portfolio against the benchmarks and parameters set forth in the IPS. The Advisor recommends to the client changes in the IPS that are consistent with the purposes of the Plan and that are not in conflict with the ERISA fiduciary duties of the parties under this Agreement. The Advisor agrees, if so requested by the client, to conduct the participant education and enrollment meetings that may be required in connection with the start-up of the Plan, or in connection with the enrollment of newly eligible participants. The Advisor assists the client in its determination of all fees and expenses paid out of the Plan’s Securities Portfolio, and whether such fees and expenses are reasonable. It remains the client’s responsibility to promptly notify the Advisor if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Advisor’s previous recommendations and/or services. Participant Directed Defined Contribution Plan The Advisor determines, reviews, and changes the allocation and diversification of the Plan’s Securities Portfolio and executing asset allocation software models using variables suitable for the Plan in order to maintain the relative percentages of asset classes within the parameters set forth in the IPS on a quarterly basis. The Advisor purchases, retains, and sells securities consistent with the investment objectives and asset allocation needs set forth in the IPS. The Advisor reports the investment results of the Plan’s Securities Portfolio at least monthly and reviews the reports and accompanying graphics concerning the investment performance of the Plan’s Securities Portfolio with the client at least semi-annually to assist it in understanding their contents. The Advisor conducts meetings with the Administrator at the Administrator's offices or by telephone, as needed to discuss the performance of all Investment Options. The Advisor conducts participant education and enrollment meetings at locations designated by the Administrator, on such basis and at such times as are reasonably requested by the Administrator for the purpose of providing Plan participants with sufficient information and education to enable them to exercise control over the assets in their participant accounts. The Advisor will agree to conduct the participant education and enrollment meetings that may be required in connection with the start-up of the Plan, or in connection with the enrollment of newly eligible participants, if so requested by the Administrator. The Advisor assists the Administrator in its determination of all fees and expenses paid out of Plan assets, and whether such fees and expenses are reasonable WRAP Program The Advisor does not sponsor or provide investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. 6  Termination of Agreements A client may terminate any of the agreements at any time by notifying the Advisor in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Advisor may terminate any of the agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated would refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in arrears. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s fee can range from .60% to 1.0% depending upon the underlying factors of each portfolio. The Advisor is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Advisor does not act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Investment Management Fees Incremental Account Value From Incremental Account Value To Quarter Percentage Fee Annualized Percentage Fee $ 1,000,000 0.25% $ 0.00 1.00% $ 1,000,000 $ 5,000,000 0.1500% 0.600% 0.0625% 0.250% >$ 5,000,000 ---- ERISA Fee Guideline Incremental Account Value From Incremental Account Value To Quarter Percentage Fee Annualized Percentage Fee $ 1,000,000 0.3125% 1.25% $ 0.00 $ 1,000,000 $ 10,000,000 0.2500% 1.00% $ 10,000,000 $ 20,000,000 0.1875% 0.750% > $20,000,000 negotiable 7  Financial Planning /Tangible Property Fees The Financial Planning fee will be determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. As our fee is based on each client's personal situation, complexity of the service, and time commitment required, we will provide an estimate of the total fee at the start of the advisory relationship. Financial planning fees are negotiable but generally fees are charged at the rate of $200 to $300 an hour or for a fixed fee that generally ranges from $1,000 to $25,000. The Advisor may also provide general non‐ securities advice on topics that may include tax and budgetary planning, estate planning and business planning. This is considered an integral part of the financial planning process and does not generate a separate fee. On occasion, the Advisor may enter into an agreement to offer financial consultation at a similar hourly rate as the financial planning rate. When both investment management and financial planning services are offered, there is a conflict of interest since there is an incentive for the party offering financial planning services to recommend itself to be the investment manager. Clients of the Advisor, however, are under no obligation to act upon any recommendations of the Advisor or to affect any transactions through the Advisor if they decide to follow the Advisor’s recommendations. Fee Billing Investment management fees will be billed quarterly in arrears. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Integrated Fee Disclosure The clients of EPP will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. EPP’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that EPP fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisers selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The Advisor, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Advisor will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment 8  partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases, there may be fees charged which are a result of brokered trading activity by associated personnel of the Advisor that is outside of the constructs of the Advisor’s investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client the fees may vary in size depending on the nature of the client’s requests. EPP is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), respectively. As such, our Firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, Ely Prudent Portfolios, LLC may only charge fees for investment advice about products for which our Firm and/or our related persons do not receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our Firm and/or our related persons receive commissions or 12b-1 fees, however, only when such fees are used to offset EPP’s advisory fees. Conflict of Interest Between Different Fee Structures The Advisor offers several different services detailed in this brochure that compensate the Advisor differently depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Advisor mitigates this conflict through its procedures to review client accounts relative to the client or investors’ personal financial situation to ensure the investment management service provided is appropriate. Further, the Advisor is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. client relationships vary in scope and length of service. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Pre-existing advisory clients are subject to Ely Prudent Portfolios, LLC's minimum 9  account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our Firm's minimum account requirements will differ among clients. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. EPP’s Investment Activities. The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness, or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve 10  a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor’s investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls, and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies, or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs, policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies, or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates, and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage-backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all 11  but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards. There may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory 12  requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel, and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. 13  Item 10 – Other Financial Industry Activities and Affiliations Affiliations Neither EPP nor any of its management persons has any material relationship or arrangement with any related financial industry participant. EPP has recommended other investment advisers, when EPP determined that it was in the best interest of the client. EPP Prudent Portfolios, LLC endeavors at all times to put the interest of its clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps to address this conflict: • We disclose to clients the existence of all material conflicts of interest; • We disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies; • We collect, maintain, and document accurate, complete and relevant client background information, including the client’s financial goals, objectives, and risk tolerance; • Our Firm's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances; • We require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed; • We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our Firm; and • We educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. On occasion, the Advisor (a related person) may act as a consultant to government, public and private entities concerning their pension and profit-sharing plans. In this capacity the Advisor provides general investment advice about the merits and risks of the investment alternatives available. The plan fiduciary is free to seek independent advice about the appropriateness of any investment for the plan. The Advisor acts, when hired, as a consultant to government, public, and private entities concerning their pension and profit shared plans, primarily participant education. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of EPP. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. 14  Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Advisor may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Advisor on behalf of any client or is being considered for purchase or sale. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The obtaining may recommend brokerage firms as qualified custodians and for trade execution. The obtaining does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, obtaining will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. obtaining is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, databases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction, and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with 15  the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts 16  • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. 17  • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/Investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. 18  Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the firm, CCO, and its associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 – Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. 19  Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 20 

Item 1 – Cover Sheet Evoque Investments, Inc. Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 198 Main St. Suite 7 Great Barrington, MA 02130 (413) 854 - 8096 www.evoque-investments.com March 28, 2025 This brochure provides information about the qualifications and business practices of Evoque Investments, Inc. If you have any questions about the contents of this brochure, please contact us at (413) 854-8096, or by email at melissa@evoque.investments. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Evoque Investments Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Evoque Investments’ current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801-96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on March 27, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................3 Item 4 – Advisory Business ........................................................................................................................................4 Item 5 – Fees and Compensation ................................................................................................................................6 Item 6 – Performance Fees .........................................................................................................................................7 Item 7 – Types of Clients ...........................................................................................................................................7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................8 Item 9 – Disciplinary Information ............................................................................................................................11 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........................12 Item 12 – Brokerage Practices ..................................................................................................................................13 Item 13 – Review of Accounts .................................................................................................................................16 Item 14 – Client Referrals and Other Compensation ...............................................................................................17 Item 15 - Custody .....................................................................................................................................................17 Item 16 – Investment Discretion ..............................................................................................................................18 Item 17 – Voting Client Securities ...........................................................................................................................18 Item 18 – Financial Information ...............................................................................................................................18 3  Item 4 – Advisory Business Firm Description Evoque Investments Inc. is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter (“the Advisor” or “Evoque” or “Evoque Investments”). Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Advisor is a fee-only investment management firm. The Advisor provides personalized investment advice primarily to high-net-worth individuals and individual Clients. The Firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has associated persons who are in other fields where they receive commissions as compensation. The Advisor is not affiliated by ownership with entities that sell financial products or securities. The Advisor nor Integrated do not act as a custodian of client assets and the client always maintains asset control. The Advisor does have discretion of client accounts and places trades for clients without their approval. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor’s, Integrated’s, or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning and consulting matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Evoque Investments is a DBA of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Melissa Mae and Jessica Bartle are Investment Adviser Representatives of Integrated Advisors Network LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system by the IARs utilizing Integrated’s programs. Investment policy statements may also be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, numerous aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives 4  change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client’s financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. The Advisor may provide limited financial planning or other consulting services as part of its investment management services. To the extent specifically requested by a client, the Advisor may provide limited consultation services to its investment management clients on investment and noninvestment related matters. The client is under no obligation to act upon the Advisors recommendation. On occasion the Advisor will also provide free seminars related to financial planning, small business ownership, college savings, and other financial issues. These programs are designed to educate the public regarding their finances and the service offerings by the Advisor. Evoque Investments provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. Evoque Investments is mindful of each client’s financial situation, endeavoring to ensure that the client’s investment objectives are met on an ongoing basis, and that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by Evoque Investments or a third party manager. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds and ETFs is most appropriate. In these situations, a portfolio of no-load or load-waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. Initial public offerings (“IPOs”) are not available through Integrated. Financial Planning Financial planning services provide an analysis and roadmap of a client’s management of their financial resources. Generally, financial planning services will involve preparing a financial program for clients based on the client’s financial circumstances and objectives. This information normally would cover present and anticipated assets and liabilities, including insurance, savings, investments, and anticipated retirement or other employee benefits. If need by the client, planning services can include a cash flow analysis and advice as to the rearrangement of cash flow in order to fund certain long-term objectives such as buying a house, planning for college, retirement, etc. The program developed for a client will usually include general recommendations for a course of activity or specific actions to be taken by the client. Further, Evoque develops tax or estate plans for clients or refer clients to an accountant or attorney. Plans are based on your financial situation at the time and are based on financial information disclosed by you to Evoque Investments. You are advised that certain assumptions will be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance. Evoque Investments cannot offer any guarantees or promises that your financial goals and objectives will be met. Further, you must continue to review the plan and update the plan based upon changes in your financial situation, goals, or objectives or changes in the economy. Should your financial situation or investment goals or objectives change, you must notify Evoque promptly of the changes. You are advised that the advice offered by Evoque is limited and is not meant to be comprehensive. Therefore, you need to consider seeking the services of other professionals such as an insurance adviser, attorney and/or accountant. 5  You are not obligated to implement advice through Evoque. WRAP Program The Advisor does not sponsor and provide investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro rata for services provided through to the date of termination. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. The Advisor reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Item 5 – Fees and Compensation Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. Fees are collected either in advance or in arrears. The investment management fees and collection schedule are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The fee varies from 50 basis points (.50%) up to 250 basis points (2.50%) Investment management fees will be billed and deducted quarterly. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Financial Planning Services You are advised that fees for planning services are strictly for planning services. Therefore, you will pay fees and/or commissions for additional services obtained such as asset management or products purchased such as securities or insurance. Fees are negotiable. Your fees will be dependent on several factors including time spent with Evoque Investments, number of meetings, complexity of your situation, amount of research, services requested and staff resources. Financial Planning for clients, which includes complex situations, is provided under a fixed fee arrangement agreed upon at the first meeting and billed monthly. These services can be provided based on either (a) an hourly rate of up to $500/hr.; (b) a range of $500-$25,000 for one off calculations or plans, or (c) through an annual subscription to wealth management, account aggregation and financial planning for those without assets under management, billed monthly up to $500 per person in the household. These rates are increased depending on the complexity and time involved with the engagement. Certain financial plans require fifty percent of the fee payable in advance before the financial planning process is started. The remaining fifty percent is then payable at the end of the engagement. Advisor will not charge a prepayment of more than $1200 in fees more than 6 months in advance. 6  Termination Provisions You may terminate advisory services obtained from Evoque Investments, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with Evoque Investments. Thereafter, the client or the investment manager may terminate an Agreement by written notice to the other party. You will be responsible for any time spent by Evoque Investments. The annual services fee will be pro-rated through the termination date. At termination, after the prior full billing period, the portfolio value will be used as the basis for the fee computation, adjusted for the number of days during the billing period before termination. Based on the termination date, any pre-paid, unearned fees will be promptly refunded to the client on this pro-rata basis. The clients of Evoque will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Evoque’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Evoque fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Advisor. The Advisor’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisers selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. In some cases, there may be fees charged which are a result of brokered trading activity by associated personnel of the Advisor that is outside of the constructs of the Advisor’s investment advisory portfolios and are thus not included in the management fee. These trades are generally at the request of the client the fees may vary in size depending on the nature of the client’s requests. Item 6 – Performance Fees The Advisor does not charge performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor provides services to individuals and high net worth individuals directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. 7  Account Minimums To open and maintain a portfolio management account, the Advisor does not have an account minimum. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition: The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility: The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Evoque Investments’ Investment Activities: The Advisor’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information: By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information: The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Small Companies: The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading 8  may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage: When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments: The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions: Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk: The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the client. Fixed Income Call Option Risk: Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk: Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments: From time to time, the Advisor may invest and trade a portion of assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, 9  social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. 10  Regulatory Risks: Strategy Restrictions: Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel and accountants to determine what restrictions may apply and whether an investment managed by the Advisor is appropriate. Trading Limitations: For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby exposes the Advisor to potential losses. Conflicts of Interest: In the administration of client accounts, portfolios and financial reporting, the Advisor faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations: The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity: Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency: 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. Lack of Registration: Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital: The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. 11  Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations Some associated persons of Integrated are registered representatives of a broker dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors Network. Integrated does not make any representation that the brokerage services are at the lowest cost available and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated. Integrated mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Evoque. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised. persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Advisor may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Advisor on behalf of any client or is being considered for purchase or sale. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. 12  Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. Item 12 – Brokerage Practices Brokerage/Custodian Selection and Soft Dollars The Advisor has the authority over the selection of the broker/custodian to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth 13  of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available TD Ameritrade, Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers 14  • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Advisor may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Advisor may also aggregate the same transaction in the same securities for many clients for whom the Advisor has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Advisor is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Advisor will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Advisor must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Advisor's written agreements. • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. 15  • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Advisor's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Advisor. In cases where the client has negotiated the commission-rate directly with the broker, the Advisor will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the firm, CCO, the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts are reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. 16  Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Advisor submit instructions to the custodian to remit a specific dollar amount from the account to the designated third party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. 17  Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor does contract for limited discretionary authority to transact portfolio securities accounts on behalf of clients. The Advisor does have the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Advisor’s authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor may advise clients how to vote proxies for securities held in client accounts. Upon request the Advisor will provide copies of its policies and procedures for proxy voting: • Copy of each proxy statement that it receives regarding client securities (it may rely on a third party providing the agreement between the Advisor and third party specifies responsibility for record- keeping) • Record of each vote cast by the Advisor on behalf of a client • Copy of any supporting documentation created by the Advisor that was material to making a voting decision • Copy of each client request for information on how the Advisor voted proxies including the Advisor's response Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 18 

Item 1 – Cover Sheet SF – IAN Firm ADV Part 2A- Firm Brochure (CRD #171991 / SEC #801-96203) Integrated Advisors Network, LLC 304 4th Street Sausalito, CA 94965 (415) 999-2162 www.SF-ian.com March 28, 2025 This brochure provides information about the qualifications and business practices of SF-IAN. If you have any questions about the contents of this brochure, please contact us at: (415) 999-2162 or the Chief Compliance Officer at (855) 729-4222. 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 the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to SF - IAN Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure, dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. SF – IAN’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801- 96203 or upon request through the client’s IAR. Material Changes since the Last Update This Brochure dated March 28, 2025, contains no material changes since our last Brochure update on March 27, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet................................................................................................................................... 1 Item 2 – Material Changes .......................................................................................................................... 2 Item 3 – Table of Contents.......................................................................................................................... 3 Item 4 – Advisory Business ........................................................................................................................ 4 Item 5 – Fees and Compensation ................................................................................................................ 6 Item 6 – Performance Fees ......................................................................................................................... 7 Item 7 – Types of Clients ............................................................................................................................ 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 8 Item 9 – Disciplinary Information ............................................................................................................ 10 Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 11 Item 12 – Brokerage Practices .................................................................................................................. 12 Item 13 – Review of Accounts.................................................................................................................. 16 Item 14 – Client Referrals and Other Compensation ................................................................................ 16 Item 15 - Custody...................................................................................................................................... 16 Item 16 – Item Discretion ......................................................................................................................... 17 Item 17 – Voting Client Securities............................................................................................................ 17 Item 18 – Financial Information ............................................................................................................... 17 3  Item 4 – Advisory Business Firm Description SF – IAN does business under the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”. Integrated Advisors, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. The Adviser is a fee-only investment management firm. The Adviser provides investment advice and management to individually managed accounts that is tailored to the needs of individual clients, on a discretionary or non- discretionary basis. For discretionary clients, the Adviser, under a limited power of attorney, has discretion over the selection and the amount of securities to be bought or sold without obtaining specific client consent. Clients may impose restrictions on their investments upon request. These restrictions may include prohibitions or limits on individual securities, security types, asset classes, allocation, liquidity, credit quality and income. For non-discretionary accounts, the Adviser generally does not have discretion with respect to any of the assets. It is understood that the client is relying on the Adviser for general investment advice and client is under no obligation to act on any investment advice provided by the Adviser. The Adviser is given the ability to debit client accounts for advisory fees. The Adviser does not have discretion to move funds without the client’s consent. For these clients, the Adviser can only act on behalf of clients upon their express instructions. In such case, the Adviser cannot act on the clients’ behalf in the event of a volatile market with price swings that affect, negatively or positively, the values of the clients’ holdings. The Firm does not sell securities on a commission basis as part of its advisory services. However, Integrated has associated persons who are in other fields where they receive commissions as compensation. The Adviser is not affiliated by ownership with entities that sell financial products or securities. The Adviser nor Integrated do not act as a custodian of client assets and the client always maintains asset control. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co- Founder & Chief Relationship Officer. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. As of December 31, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Charles “Bruce” Woodward is an Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Services Investment Management As part of the investment management service, all aspects of the client’s financial affairs are reviewed, realistic and measurable goals are set, and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial 4  situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management SF-IAN through Integrated provides investment advisory services to clients that are tailored to the clients’ needs based on their financial situation and investment objectives. SF-IAN is mindful of each client’s financial situation, ensuring that the client’s investment objectives are met on an ongoing basis, and ensuring that investment recommendations are suitable and comply with any client-imposed investment restrictions. After review and assessment of clients’ needs, portfolios are designed and managed using a mix of investments including stocks, bonds, mutual funds (stock funds, bond funds and other share classes), options, warrants, real estate investment trusts (“REITS”), exchange-traded funds (“ETFs”), alternative investments, and other securities as chosen by SF-IAN. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate. In these situations, a portfolio of no-load or load- waived mutual funds will be created and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. SF-IAN may utilize third-party managers (“Money Manager”) to manage either a portion or a client’s entire portfolio. SF-IAN’s recommendation that a Money Manager manage a client’s account will be based on the Money Manager’s investment philosophy and policies, its record as an investment adviser, and SF-IAN’s determination that the investment style of the Money Manager is consistent with the client’s financial needs, risk tolerance and objectives. To ensure that Money Managers are still appropriate for a client, SF-IAN performs reviews of the Money Manager’s portfolios and financial standing and SF-IAN also updates the client’s financial objectives as necessary. SF-IAN may remove and replace Money Managers at its discretion when it believes a Money Manager is no longer consistent with the client’s needs and objectives or where, in the estimation of SF-IAN, the Money Manager’s portfolio is underperforming relative to its asset class or is poorly positioned relative to current market conditions. Access to certain Money Managers, platforms and programs may be limited to certain types of accounts and may be subject to account minimums, which will vary and may be negotiable depending upon the Money Managers, platforms and programs selected. Certain platforms and programs administered by SF-IAN and/or made available to clients by SF-IAN may be available through other independent investment advisers, and in certain instances, directly via the custodian or other third-party administering the platform or program. In addition, clients may be able to access certain Money Managers directly. As such, clients may be able to access such Money Managers, platforms and programs at a lower cost through other channels. Further, it may be possible for a client to access Money Managers directly or through other platforms or programs for an “unbundled” fee that is lower than the “bundled” fee that is available through SF-IAN. Initial public offerings (IPOs) are not available through Integrated. WRAP Program The Adviser does not sponsor or provides investment management services to a WRAP program. Other IARs under other group names at Integrated do offer wrap programs. 5  Item 5 – Fees and Compensation Fees are negotiable and may vary, but generally will be based on an annual percentage rate of 1% of assets under management. Fees are payable quarterly at the beginning of each calendar quarter based on the market value of the assets under management at the close of the prior quarter. Fees on additions or withdrawals are pro-rated. A client may terminate an investment advisory agreement with five (5) business days advance written notice. On termination, clients may receive a refund of advisory fees on a pro-rated basis. Adviser prefers to have management fees deducted from client accounts. There are some legacy clients of Adviser that are invoiced and pay separately. Adviser believes that its fees are competitive with fees charged by other investment advisers for comparable services, but comparable services may be available from other sources for lower fees than those charged by Adviser. Adviser’s fees for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and exchange-traded funds (“ETFs”) to shareholders. Clients invested in mutual funds or ETFs will pay advisory fees to Adviser and will pay additional advisory, brokerage, custodial and administrative fees as a shareholder of the applicable mutual fund or ETF. These mutual fund or ETF fees and expenses are described in each fund’s prospectus. Adviser’s fees are also separate and distinct from custodial, accounting, legal and other fees incurred by clients. Integrated Fee Disclosure The clients of SF - IAN will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. SF – IAN’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that SF – IAN’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers, as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. 6  If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Adviser is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. The annual services fee will be pro-rated through the termination date. At termination, after the prior full billing period, the portfolio value will be used as the basis for the fee computation, adjusted for the number of days during the billing period before termination. Based on the termination date, any pre-paid, unearned fees will be promptly refunded to the client on this pro-rata basis. The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Item 6 – Performance Fees Adviser does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $250,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. 7  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Adviser provides its clients with individualized investment advice tailored to the investment objectives and financial situation of each client. Adviser’s methods of analysis include fundamental analysis, charting and technical analysis. Adviser offers advice on the following types of securities: equities (exchange listed, over the counter and foreign issues); warrants; corporate debt securities; municipal securities; United States government securities and Certificates of Deposit; and ETFs and mutual funds. These investments bear the risk of loss at any time due to unforeseen market, economic, interest rate, liquidity, or other risks. When appropriate to the needs of the client, Adviser may recommend the use of trading (securities sold within 30 days), margin transactions, short sales and/or option writing as investment strategies. Because these investment strategies may involve increased risk of loss, they are only recommended when consistent with the client’s stated tolerance for risk. Market, Security and Regulatory Risks Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. SF-IAN’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Options and Other Derivative Instruments. The Adviser may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities 8  held by the Adviser. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs, policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. 9  Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or LP interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations There are no affiliations or activities to disclose specifically to SF-IAN, but associated persons of Integrated Advisors Network are registered representatives of a broker dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of Integrated Advisors 10  Network are not required to use the brokerage services offered by the registered representatives associated with Integrated Advisors network. Integrated Advisors Network does not make any representation that the brokerage services are at the lowest cost available, and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated Advisors Network. Integrated Advisors Network mitigates these conflicts through its procedures to review client accounts relative to the client or investors personal financial situation to ensure the investment management service provided is appropriate. Further, Integrated Advisors Network is committed to its obligation to ensure associated persons adhere to the firm’s Code of Ethics and to ensure that the firm and its associate persons fulfill their fiduciary duty to clients or investors. Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of SF-IAN. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Adviser may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Adviser on behalf of any client or is being considered for purchase or sale. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. 11  Potential Conflicts of Interest Related to Non-Discretion The Adviser provides non-discretionary investment management services, pursuant to which we may advise a client with respect to purchasing, selling, holding, valuing, or exercising rights associated with particular investments. In these circumstances, we generally do not execute purchases or sales on behalf of the client or a client may require that the Adviser seek the client’s approval prior to executing any buy or sell transactions for the client’s account. Discretionary and non-discretionary clients may hold the same or similar instruments. Where the Adviser is given authority to execute transactions upon the approval of a non-discretionary client, there may be timing differences related to the provision of advice to a non-discretionary client for consideration and that client’s determination of whether to act on the advice. As a result, trades may be executed for discretionary clients in advance of executions for non-discretionary clients, potentially disadvantaging the non-discretionary clients. Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. The Adviser does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, Adviser will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Adviser is not required to negotiate "execution only" commission rates, thus the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Adviser to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Adviser may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Adviser makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Adviser will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. 12  When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting 13  Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The Adviser may purchase and/or sell the same security for many accounts, even though each client account is individually managed. When possible, the Adviser may also aggregate the same transaction in the same securities for many clients for whom the Adviser has discretion to direct brokerage. Clients in aggregated transactions each receive the same price per unit, although they may pay differing brokerage commissions depending upon the nature of their directed brokerage arrangement, if any. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If the Adviser is unable to fill an aggregated transaction completely, but receives a partial fill of the aggregated transaction, the Adviser will allocate the filled portion of the transaction to clients based on an equitable rotational system as follows: • The Adviser must ensure that adequate and full disclosure of its allocation and bunching practices has been made prior to the transaction. • All clients/investors, accounts or funds participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rata basis. • Aggregate transactions must not be executed unless the intended and resultant aggregation is consistent with its duty to seek best execution and any terms found in the Adviser's written agreements. 14  • Aggregated orders filled in their entirety shall be allocated among clients/investors, accounts or funds in accordance with an allocation statement created prior to the execution of the transaction(s); partially filled orders shall be allocated pro-rata based on the allocation statement and the variance from the modeled allocation of a security. Where this method prescribes an odd lot that is less than 100 shares for an account, the allocation will be rounded up to a whole lot. Client/investor funds held collectively for the purpose of completing the transaction may not be held in this commingled manner for any longer than is practical to settle the transaction. • Each client/investor, account or fund that participates in an aggregated order will participate at the average share price for all the Adviser's transactions in that security on a given business day, with transaction costs shared pro-rata based on each client/investor's, account's or fund's participation in the transaction. • Investments resulting from any aggregated order must be consistent with the specific investment objective(s) of each client/investor, account or fund as detailed in any written agreements. No additional compensation shall result from the proposed allocation. No client/investor, account or fund will be favored over any other client/investor, account or fund as a result of the allocation. • Pre-allocation statement(s) specifying the participating client/investor accounts and the proposed method to allocate the order among the clients/investors, accounts or funds are required prior to any allocated order. Basis for establishing pre-allocations may include pro-rata of account assets to assets for the specific strategy, executing broker and variance from modeled position holding as factors. Should the actual allocation differ from the allocation statement, such trade may only be settled with the approval of the CCO or another appropriately qualified and authorized principal of the Adviser. In cases where the client has negotiated the commission-rate directly with the broker, the Adviser will not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any, possible commission discounts that might otherwise be available a result of the aggregated trade. Directing Brokerage for Client Referrals The Adviser and its associated persons do not receive client referrals from broker dealers or third parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Adviser allows clients to direct brokerage, but the Adviser does not require clients to direct brokerage. In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct the Adviser to use a particular broker or dealer and other clients who do not direct Adviser to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Adviser may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Adviser to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms which do not permit the Adviser to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Adviser may be precluded from aggregating that client's transaction with other accounts which may result in less favorable security prices and/or higher transaction costs. 15  Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the Firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts reviewed by the Investment Adviser Representative responsible for the account and the CCO also performs random reviews. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is generally considered to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) in which the Adviser may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in 16  place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Adviser meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Item Discretion The Adviser contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Adviser’s investment management agreement and/or by a separate limited power of attorney where such document is required. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of business or industries. All such restrictions are to be agreed upon in writing at the account's inception. Other advisory groups at Integrated have client relationships/accounts where they do not have discretionary authority. Those groups and Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used and the commission rates paid to the Adviser. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Adviser promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Adviser does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to and the Adviser has not been the subject of a bankruptcy petition in the last 10 years. 17  The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 18 

Item 1 – Cover Sheet Financial Foundations, Inc. Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 602 Center Street, Suite 105 Mt. Airy, MD 21771 (301) 829-8610 www.financialfoundationsinc.com March 28, 2025 This brochure provides information about the qualifications and business practices of Financial Foundations Inc. If you have any questions about the contents of this brochure, please contact us by telephone at (301) 829-8610, or by email at admin@financialfoundationsinc.com . Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 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 the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Annual Update This section describes material changes to Financial Foundations, Inc. Part 2A of Form ADV (“Part 2A Brochure” or this “Brochure”) since its last annual amendment. This Brochure dated March 28, 2025, has been prepared according to the SEC disclosure requirements. Additionally, in lieu of providing clients with an updated Part 2A Brochure each year, we typically provide existing advisory clients with this summary describing any material changes occurring since the last annual amendment. In these instances, we will make this delivery to existing clients within 120 days of the close of the fiscal year, which ends December 31st. Clients receiving the summary of material changes who wish to receive a complete copy of our then-current Part 2A Brochure may request a copy at no charge by contacting the Chief Compliance Officer by telephone at: 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. Financial Foundation’s current Part 2A Brochure is also available through Integrated Advisor’s Network, LLC disclosure through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx, SEC# 801- 96203 or upon request through the client’s IAR. Material Changes since the Last Update No material changes have occurred since the last annual updating amendment on March 27, 2024. 2  Item 3 – Table of Contents Item 1 – Cover Sheet................................................................................................................................... 1 Item 2 – Material Changes .......................................................................................................................... 2 Item 3 – Table of Contents.......................................................................................................................... 3 Item 4 – Advisory Business ........................................................................................................................ 4 Item 5 – Fees and Compensation ................................................................................................................ 6 Item 6 – Performance Fees ......................................................................................................................... 7 Item 7 – Types of Clients ............................................................................................................................ 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 8 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 ........... 13 Item 12 – Brokerage Practices .................................................................................................................. 14 Item 13 – Review of Accounts.................................................................................................................. 16 Item 14 – Client Referrals and Other Compensation ................................................................................ 17 Item 15 - Custody...................................................................................................................................... 17 Item 16 – Investment Discretion ............................................................................................................... 18 Item 17 – Voting Client Securities............................................................................................................ 18 Item 18 – Financial Information ............................................................................................................... 18 3  Item 4 – Advisory Business Firm Description Financial Foundations Inc. is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter "the Advisor" or "Financial Foundations". Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC-registered investment adviser. The Advisor is dually registered with a broker-dealer and offers both fee-only investment management and commission business. The Advisor also offers financial planning services. The Advisor provides personalized investment advice and financial planning to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or other business entities. The Firm does not sell securities on a commission basis. However, there are some associated persons who are in other fields where they receive commissions as compensation. Integrated is not affiliated with entities that sell financial products or securities. The Advisor nor Integrated do not act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. The Advisor does act as a sponsor and does provide investment advice to a WRAP program. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as- needed basis. Any conflicts of interest arising out of the Advisor's or its associated persons are disclosed in this brochure. Principal Owners of Integrated Advisors Network LLC are as follows: Integrated’s Principal Owner is TX-HI, LLC. The control persons of the Firm are Michael A Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder & Managing Partner, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Principal Owner of Financial Foundations Inc. is as follows: Eric Meushaw 100%. Financial Foundations Inc. is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Eric Meushaw and Mark Huber Jr. are Investment Adviser Representatives of Integrated Advisors Network LLC. Types of Advisory Services The Advisor provides investment supervisory services, also known as asset management services. Also, on more than an occasional basis, the Advisor may furnish advice to clients on matters not involving securities, such as financial planning matters. As of February 29, 2024, Integrated Advisors Network collectively managed approximately $4.334 billion in assets on a discretionary basis and $251 million on a non- discretionary basis. Financial Foundations, Inc is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Eric Meushaw and Mark Huber, Jr. are Investment Adviser Representatives of Integrated Advisors Network, LLC. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system. Investment policy statements are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. 4  Types of Services Investment Management As part of the investment management service, all aspects of the client's financial affairs are reviewed, and realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Advisor periodically reviews a client's financial situation and portfolio through regular contact with the client, which often includes an annual meeting with the client. The Advisor makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Financial Planning Services The Financial Plan may include, but is not limited to: a net worth statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations. Financial planning may be the only service provided to the client and does not require that the client use or purchase the investment advisory services offered by the Advisor or any of the insurance products or other products and services offered by the associated persons of the Advisor. There is an inherent conflict of interest for the Advisor whenever a financial plan recommends the use of professional investment management services or the purchase of insurance products or other financial products or services. The Advisor or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. The Advisor does not make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of the Advisor or use the services of the Advisor in particular. Asset Management Investments may include equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), U. S. government securities, options contracts, futures contracts, and interests in partnerships. Assets in mutual funds and exchange-traded funds are invested in no-load or low-load, usually through brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Brokerages may charge a transaction fee for the purchase of some funds which the client will pay unless in a WRAP program. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades, which the client will pay unless in a WRAP program. The Advisor does not receive any compensation, in any form, from fund companies. Initial public offerings (IPOs) are not available through Integrated. WRAP Program The Advisor is a sponsor and provides investment management services to a wrap program that is under the name of Vineyard Global Advisors Managed Account Program ("VGA MAP"). Under this WRAP program, one fee called a WRAP fee is charged for a bundle of services, which may include management fees, custodial fees, trading expenses, reporting, and administrative costs. As the programs sponsor and investment manager, the Advisor receives management fees and a portion of the WRAP fee related to administrative services the Advisor performs 5  from the payment of the WRAP fee. For a complete description of the WRAP program, the WRAP fee, and what services are included in the WRAP fee, refer to the program brochure, which may be obtained from the WRAP program sponsor. Termination of Agreements A client may terminate any of the aforementioned agreements at any time by notifying the Advisor in writing. Clients shall be charged pro-rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Advisor reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Advisor's judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded. Item 5 – Fees and Compensation Investment Management The Advisor bases its fees on a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client's discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance; therefore, at termination, any unearned fees as determined on a pro-rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Advisor, and fees for comparable services may be available from other sources. Financial Foundations client's management fees range from 1.50% - 2.25%. The fee is comprised of a fee to the Advisor for its services and a fee to program's used to implement the investment strategy. The exact fee is based on the strategy(ies) the client and the Advisor determine best suits the client's situation. At the sole discretion of the Advisor, fees are negotiable for the different program service levels, and lower fees may be charged to clients affiliated with the Advisor. Financial Planning The fee for a financial plan is not charged at this time. Fee Billing Investment management fees are billed quarterly, in advance, meaning that we invoice you before the three- month billing period has begun. Payment in full is expected upon invoice presentation. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Fees for financial plans are not charged at this time. Integrated Fee Disclosure The clients of Financial Foundations will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Financial Foundations’ fees may be higher or lower than other advisory groups at Integrated and there is no representation that Financial Foundations fees are the lowest available for similar services. 6  Other Fees Unless the client portfolio account is in a WRAP program, the client will likely incur fees from brokerages, custodians, administrators, and other service providers. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider's fee schedule(s) at the provider's sole discretion. These fees are separate and distinct from any fees charged by the Advisor. Through the advisory business, the Advisor's services are charged on a fee-only basis, and no associated persons shall earn compensation based on a securities transaction (i.e., commission), including asset-based sales charges or service fees from the sale of mutual funds. The Advisor or the sub-advisers selected by the Advisor may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients' portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Advisor. The Advisor, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent, the client's separately managed portfolio includes such proprietary products, the Advisor will adjust the client's fee associated with the client's separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Advisor. These fees and expenses are described in each mutual fund's or underlying annuity fund's prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios, so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Advisor. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over the counter securities, the client may pay a mark-up or mark-down or a "spread" to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. The Advisor is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there are associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Advisor does not act as a custodian of client assets, and the client always maintains asset control. The Advisor has discretion of client accounts and places trades for clients under a limited power of attorney. Conflict of Interest Between Different Fee Structures The Advisor offers several different services detailed in this brochure that compensate the Advisor differently depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel to recommend the services that offer a higher level of compensation to the Firm through either higher management fees or reduced administrative expenses. The Advisor mitigates this conflict through its procedures to review client accounts relative to the client's or investor's personal financial situation to ensure the investment management service provided is appropriate. Further, the Advisor is committed to its obligation to ensure associated persons adhere to the Firm's Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Fees are not based on a share of the capital gains or capital appreciation of managed securities. However, the Advisor may employ certain types of investments that do charge a performance fee in which the Advisor does not participate. 7  For these investments, refer to their offering or private placement memorandum for an explanation and amounts of the performance fees. There are advisory groups at Integrated that do charge performance fees. These fees are discussed in the ADV Part 2A and in the investment management agreement for those advisory groups that do charge performance fees. Item 7 – Types of Clients Description The Advisor generally provides investment advice to individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates, or charitable organizations, and corporations or business entities. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $500,000. At the Advisor's discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Investment Strategies Strategies may include long-term purchases, short-term purchases, trading, short sales, margin transactions, and option writing (including covered options, uncovered options, or spreading strategies). The primary investment strategy used on client accounts is strategic asset allocation utilizing a core and satellite approach. This means that we use passively managed index and exchange-traded funds as the core investments, and then add actively managed funds where there are greater opportunities to make a difference. Portfolios are globally diversified to control the risk associated with traditional markets. The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. Each client executes an Investment Policy Statement that documents their objectives and their desired investment strategy. The Advisor's strategies do not involve frequent trading. Market, Security and Regulatory Risks Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor, which are described below: Market Risks: Competition. The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely competitive, and each involves a degree of risk. The Advisor will compete with firms, including many 8  of the larger securities and investment banking firms, which have substantially greater financial resources and research staff. Market Volatility. The profitability of the Advisor substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Financial Foundations' Investment Activities. The Advisor's investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political, competitive, technological, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Advisor to realize profits. Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information. The Advisor selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Advisor by the issuers or through sources other than the issuers. Although the Advisor evaluates all such information and data and sometimes seeks independent corroboration when it's considered appropriate and reasonably available, the Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Advisor intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Advisor's investments may not adequately compensate for the business and financial risks assumed. Small Companies. The Advisor may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage. When deemed appropriate by the Advisor and subject to applicable regulations, the Advisor may incur leverage in its investment program, whether directly through the use of borrowed funds or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls, and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Options and Other Derivative Instruments. The Advisor may invest, from time to time, in options and other derivative instruments, including, but not limited to, the buying and selling of puts and calls on some of the securities held by the Advisor. The prices of many derivative instruments, including many options and swaps, are highly volatile. The values of options and swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies, or other instruments underlying them. Price movements of options contracts and payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand 9  relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Options on highly volatile securities, currencies or other assets may be more expensive than options on other investments. Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions' value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Advisor is not obligated to establish hedges for portfolio positions and may not do so. Market or Interest Rate Risk. The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Advisor holds a fixed-income security to maturity, the change in its price before maturity may have little impact on the Advisor's performance; however, if the Advisor has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Advisor. Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Advisor is exposed to reinvestment rate risk – the Advisor will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Inflation Risk. Inflation risk results from the variation in the value of cash flow from a security due to inflation, as measured in terms of purchasing power. For example, if the Advisor purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds, or floating rate bonds, the Advisor is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Investments in Non-U.S. Investments. From time to time, the Advisor may invest and trade a portion of its assets in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such risks may include: • Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or transfer of portfolio assets. • Enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes special problems enforcing claims against foreign governments. • Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect the Advisor's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor's investments to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of the Advisor's foreign currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging 10  purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward contracts for the purpose of increasing return, it may sustain losses. • Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about the operations of issuers in such markets. Regulatory Risks: Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel, and accountants to determine what restrictions may apply and whether an investment in the Advisor is appropriate. Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate positions and thereby expose the Advisor to potential losses. Conflicts of Interest. In the administration of client accounts, portfolios, and financial reporting, the Advisor faces inherent conflicts of interest, which are described in this brochure. Generally, the Advisor mitigates these conflicts through its Code of Ethics which provides that the client's interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations. The Advisor, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with Firm and client objectives. Despite the Advisor's efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients will be exposed to risks that are specific to the securities in their particular investment portfolio. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality. Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, 11  to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Security Specific Risks: Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities, where there is a ready market that is traded through an exchange, are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in the price level in a liquidation situation. Currency. 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. Lack of Registration. Funds or Limited Partnership (“LP”) interests have neither been registered under the Securities Act nor under the securities or "blue sky" laws of any state and, therefore, are subject to transfer restrictions. Withdrawal of Capital. The ability to withdraw funds from the funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets and/or disrupting the fund's investment strategy. Item 9 – Disciplinary Information The Firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other IARs of Integrated have been involved in disciplinary events related to past investment clients previous to their association with Integrated. Item 10 – Other Financial Industry Activities and Affiliations Brokerage Affiliations Some associated persons of the Advisor are registered representatives of a broker-dealer. They may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation they may earn and may not necessarily be in the best interests of the client. However, clients of the Advisor are not required to use the brokerage services offered by the registered representatives associated with the Advisor. The Advisor does not make any representation that the brokerage services are at the lowest cost available, and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. The brokerage activities provided by these individuals are entirely separate and distinct from the advisory services provided by the Advisor. The Advisor mitigates these conflicts through its procedures to review client accounts relative to the client's or investors' personal financial situation to ensure the investment management service provided is appropriate. Further, the Advisor is committed to its obligation to ensure associated persons adhere to the Firm's Code of Ethics and to ensure that the Firm and its associated persons fulfill their fiduciary duty to clients or investors. 12  Affiliations IARs of the Advisor are licensed to sell insurance products through various independent insurance agencies. In some instances, certain investment adviser representatives may sell insurance products through their independently owned insurance agency. In either case, these investment adviser representatives, in their capacity as independent insurance agents, may sell insurance products to advisory clients. These individuals will receive normal and customary commissions as a result of selling insurance as well as advisory fees for providing advisory services through the Advisor. Clients are hereby advised that such commissions and advisory fees are separate and apart from the fees charged by the Firm. Clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through these associated persons in their separate capacities as insurance agents and/or advisory representatives of the Advisor. However, if the client freely chooses to implement the plan through such individuals, the investment adviser used will be the Advisor, and commissions/fees will be earned in addition to any fees paid for advisory services provided by the Firm. Not all IARs of Integrated sell or offer insurance products. For those that do, the commissions may be higher or lower for products similar to those offered by Financial Foundations. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Advisor's Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Advisor's Compliance Officer. Each supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Advisor's Code of Ethics by contacting the Compliance Officer of the Advisor. Participation or Interest in Client Transactions Under the Advisor's Code of Ethics, the Advisor and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. The Advisor may decline any proposed trade by an employee that involves a security that is being or has been purchased or sold by the Advisor on behalf of any client or is being considered for purchase or sale. The Advisor and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Advisor does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Advisor or his/her designee shall review all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the Firm receive preferential treatment. 13  Item 12 – Brokerage Practices Brokerage Selection and Soft Dollars The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified custodians and for trade execution. The Advisor does not receive fees or commissions from any of these arrangements. In selecting brokers or dealers to execute transactions, the Advisor will seek to achieve the best execution possible, but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. The Advisor is not required to negotiate "execution-only" commission rates; thus, the client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the broker, which are included in the commission rate. Research and related services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies, and forecasts; financial publications; statistical and pricing services, as well as discussions with research personnel, along with hardware, software, databases and other technical and telecommunication services and equipment utilized in the investment management process. It is the policy and practice of the Advisor to strive for the best price and execution for costs and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended. Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e), and the Advisor makes no warranty or representation regarding compensation paid on transactions. In negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers, although the client may not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Research and Other Benefits Neither Integrated nor the Advisor maintain custody of client assets that managed and/or advised on (see Item 15— Custody, below). Assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Integrated works with multiple custodians. A few of these custodians include, but are not limited to, Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments, Inc. (“Fidelity) (aka “the custodian”, “custodians”) registered broker-dealers, members SIPC. Integrated is independently owned and operated and is not affiliated with the custodians utilized. The custodian chosen will hold client assets in a brokerage account and buy and sell securities when instructed to. While a certain custodian may be recommended, the client can choose whether to use that custodian or another and will open their account with said custodian by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. When considering whether the terms that custodians provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: combination of transaction execution services and asset custody services (generally without a separate fee for custody), capability to execute, clear, and settle trades (buy and sell securities for your account), capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.), quality of services, reputation, financial strength, security and stability, prior service to us and our clients, availability of other products and services that benefit us. 14  Brokerage and Custody Costs For Integrated and the Advisor’s clients' accounts that certain custodians maintain, the custodian generally does not charge the client separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the client account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through the custodian selected, we have determined that having the custodian execute most trades is consistent with Integrated and the Advisor’s duty to seek "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. Products and Services Available Fidelity and Schwab provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. The custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. The support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Some of these support services are as follows: Services that benefit the client: Institutional 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 clients. The services described in this paragraph generally benefit you and your account. Services that do not directly benefit the client: Other products and services that benefit us but do not directly benefit you or your account are also available. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both the custodian’s own and that of third parties. Integrated uses this research to service all or a substantial number of our clients' accounts. In addition to investment research, also available is software and other technology that: Provide access to client account data (such as duplicate trade confirmations and account statements) Facilitate trade execution and allocate aggregated trade orders for multiple client accounts Provide pricing and other market data Facilitate payment of our fees from our clients' accounts Assist with back-office functions, recordkeeping, and client reporting • • • • • Services that generally benefit only Integrated and/or the Advisor: The custodians also offer other services intended to help us manage and further develop our business enterprise. These services include: Educational conferences and events Consulting on technology and business needs Consulting on legal and compliance related needs Publications and conferences on practice management and business succession Access to employee benefits providers, human capital consultants, and insurance providers Marketing consulting and support • • • • • • The custodian provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Integrated. Custodians also discount or waives its fees for some of these services or pays all or a 15  part of a third party's fees. The custodian also provides Integrated with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with the custodian chosen, Integrated would be required to pay for those services from our own resources. The benefits received by Integrated or its personnel do not depend on the amount of brokerage transactions directed to the specific custodian. As a part of the fiduciary duties to clients, the Advisor and Integrated endeavors at all times to put the interest of clients first. The availability of these services benefits Integrated and the Advisor because we do not have to produce or purchase them. Certain custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on Integrated’s behalf once the value of our clients' assets in accounts at the specific custodian reaches certain thresholds. [These services are not contingent upon us committing any specific amount of business to the custodian in trading commissions or assets in custody.] The fact that we receive these benefits from a specific custodian is an incentive for us to recommend the use of said custodian rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Integrated believes, however, that taken in the aggregate our recommendations of a specific business as custodian and broker is in the best interests of clients. Order Aggregation The nature of the clients and/or trading activity on behalf of client accounts are such that trade aggregation does not garner any client benefit (in regard to mutual fund or exchange-traded funds, for example). Directing Brokerage for Client Referrals The Advisor and its associated persons do not receive client referrals from broker-dealers or third-parties as consideration for selecting or recommending brokers for client accounts. Directed Brokerage The Advisor allows clients to direct brokerage, but the Advisor does not require clients to direct brokerage. In the event that a client directs the Advisor to use a particular broker or dealer, the Advisor may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. In addition, under these circumstances, a disparity in commission charges may exist between the commissions charged to clients who direct the Advisor to use a particular broker or dealer and other clients who do not direct Advisor to use a particular broker or dealer which may result in higher trading expenses to the client who directs brokerage. The Advisor may place orders for transactions in certain securities initially only for those accounts which are held in custody at banks or at brokerage firms that permit the Advisor to place trades for accounts held in custody at that firm with other brokerage firms. Therefore, accounts held in custody at firms that do not permit the Advisor to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In cases where trading or investment restrictions are placed on a client's account, the Advisor may be precluded from aggregating that client's transaction with other accounts, which may result in less favorable security prices and/or higher transaction costs. Item 13 – Review of Accounts Periodic Reviews Account reviewers are members of the firm, CCO, and the associated IARs. Collectively, they review accounts not less than once a year. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Client accounts reviewed by the Investment Adviser Representative responsible for the account, and the CCO also performs random reviews. 16  Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's financial or personal situation. Regular Reports Clients receive periodic reports on at least a quarterly basis. The written reports may include account valuation, performance stated in dollars and as a percent, net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. For our advisory business, Clients receive statements of account positions no less than quarterly from the account custodian. Other IARs of Integrated have different reporting procedures that are at least quarterly but may be as often as monthly. Item 14 – Client Referrals and Other Compensation Incoming Client Referrals The Advisor receives client referrals, which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. The Firm does not compensate for referring parties for these referrals. Promoter Referrals The Advisor has not entered into any promoter (formerly known as solicitor) relationship. Referrals to Third Parties The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15 - Custody Custody Policy The Advisor does not accept or permit the Firm or its associated persons from obtaining custody of client assets, including cash, securities, acting as a trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Advisor is generally considered to have custody of clients' funds or securities when clients have standing authorizations with their custodian to move money from a client's account to a third-party ("SLOA") in which the Advisor may have some discretion in transferring the funds on behalf of the client. These SLOAs have been put in place upon the client's written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Advisor requesting that the Advisor submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). The Advisor meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations. Account Statements All assets are held at qualified custodians, and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. 17  Performance Reports Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Advisor with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16 – Investment Discretion The Advisor contracts for limited discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted either by the Advisor's investment management agreement and/or by a separate limited power of attorney where such a document is required. The Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Firm's discretionary authority regarding investments may however, be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the client on transactions in certain types of businesses or industries. All such restrictions are to be agreed upon in writing at the account's inception. The Advisor will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used, and the commission rates paid to the Advisor. The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Item 17 – Voting Client Securities The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 ("ERISA"), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy voting information to the clients or their representatives. Item 18 – Financial Information The Advisor does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. The Advisor meets all net capital requirements that it is subject to, and the Advisor has not been the subject of a bankruptcy petition in the last 10 years. The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 18