Overview

Assets Under Management: $593 million
Headquarters: PALO ALTO, CA
High-Net-Worth Clients: 123
Average Client Assets: $5 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (PALO ALTO WEALTH ADVISORS, LLC DISCLOSURE BROCHURE, BROCHURE SUPPLEMENTS, AND PRIVACY POLICY)

MinMaxMarginal Fee Rate
$0 $1,000,000 0.90%
$1,000,001 $2,000,000 0.80%
$2,000,001 $4,000,000 0.70%
$4,000,001 $8,000,000 0.60%
$8,000,001 $15,000,000 0.50%
$15,000,001 $25,000,000 0.40%
$25,000,001 and above 0.30%

Minimum Annual Fee: $10,000

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $37,000 0.74%
$10 million $65,000 0.65%
$50 million $205,000 0.41%
$100 million $355,000 0.36%

Clients

Number of High-Net-Worth Clients: 123
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 100.00
Average High-Net-Worth Client Assets: $5 million
Total Client Accounts: 692
Discretionary Accounts: 612
Non-Discretionary Accounts: 80

Regulatory Filings

CRD Number: 285326
Last Filing Date: 2024-03-15 00:00:00
Website: https://www.linkedin.com/company/palo-alto-wealth-advisors/

Form ADV Documents

Primary Brochure: PALO ALTO WEALTH ADVISORS, LLC DISCLOSURE BROCHURE, BROCHURE SUPPLEMENTS, AND PRIVACY POLICY (2025-03-13)

View Document Text
Palo Alto Wealth Advisors, LLC Form ADV Part 2A – Disclosure Brochure Effective: March 13, 2025 This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Palo Alto Wealth Advisors, LLC (“Palo Alto” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (650) 656-9800. Palo Alto is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information through Palo Alto to assist you in determining whether to retain the Advisor. Additional information about Palo Alto and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 285326. Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Palo Alto. For convenience, the Advisor has combined these documents into a single disclosure document. Palo Alto believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Palo Alto encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes There have been no material changes to this Disclosure Brochure since the last annual amendment filing on March 15, 2024. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations, or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of Palo Alto. At any time, you may view the current Disclosure Brochure online at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 285326. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (650) 656-9800. Page 2 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................. 1 Item 2 – Material Changes ....................................................................................................................... 2 Item 3 – Table of Contents ....................................................................................................................... 3 Item 4 – Advisory Services ...................................................................................................................... 4 A. Firm Information ............................................................................................................................................ 4 B. Advisory Services Offered .............................................................................................................................. 4 C. Client Account Management .......................................................................................................................... 6 D. Wrap Fee Programs ...................................................................................................................................... 6 E. Assets Under Management ............................................................................................................................ 6 Item 5 – Fees and Compensation ............................................................................................................ 6 A. Fees for Advisory Services............................................................................................................................. 6 B. Fee Billing ..................................................................................................................................................... 7 C. Other Fees and Expenses ............................................................................................................................. 7 D. Advance Payment of Fees and Termination ................................................................................................... 8 E. Compensation for Sales of Securities ............................................................................................................. 8 Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 8 Item 7 – Types of Clients ......................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss .............................................. 8 A. Methods of Analysis ....................................................................................................................................... 8 B. Risk of Loss ................................................................................................................................................... 9 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 A. Code of Ethics ............................................................................................................................................. 10 B. Personal Trading with Material Interest ........................................................................................................ 10 C. Personal Trading in Same Securities as Clients ........................................................................................... 11 D. Personal Trading at Same Time as Client .................................................................................................... 11 Item 12 – Brokerage Practices............................................................................................................... 11 A. Recommendation of Custodian[s]................................................................................................................. 11 B. Aggregating and Allocating Trades............................................................................................................... 12 Item 13 – Review of Accounts ............................................................................................................... 12 A. Frequency of Reviews ................................................................................................................................. 12 B. Causes for Reviews ..................................................................................................................................... 12 C. Review Reports ........................................................................................................................................... 12 Item 14 – Client Referrals and Other Compensation ............................................................................ 12 A. Compensation Received by Palo Alto........................................................................................................... 12 B. Compensation for Client Referrals................................................................................................................ 13 Item 15 – Custody .................................................................................................................................. 13 Item 16 – Investment Discretion ............................................................................................................ 14 Item 17 – Voting Client Securities ......................................................................................................... 14 Item 18 – Financial Information ............................................................................................................. 14 Form ADV Part 2B – Brochure Supplement: Schmidt, Ryan ............................................................... 15 Form ADV Part 2B – Brochure Supplement: Blair, Nathan .................................................................. 17 Form ADV Part 2B – Brochure Supplement: Johnson, Kegan ............................................................ 19 Form ADV Part 2B – Brochure Supplement: Tryzna, Simon................................................................ 22 Privacy Policy ......................................................................................................................................... 25 Page 3 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Item 4 – Advisory Services A. Firm Information Palo Alto Wealth Advisors, LLC (“Palo Alto” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of California. Palo Alto was founded in September 2016 and is owned and operated by Ryan K. Schmidt (Partner) and Nathan T. Blair (Partner and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Palo Alto. B. Advisory Services Offered Palo Alto offers investment advisory services to high net worth individuals, trusts, estates, and other types of clients (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate potential conflicts of interest. Palo Alto’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading. Wealth Management Services Palo Alto provides Clients with wealth management services, which generally include a broad range of comprehensive financial planning and consulting strategies as well as discretionary and nondiscretionary management of investment portfolios. Investment Management Services – Palo Alto provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Palo Alto works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy. Palo Alto will then design a portfolio tailored to the Client that will be primarily constructed with exchange-traded funds (“ETFs”) and mutual funds. The Advisor may also utilize individual stocks, options contracts, alternative investments, structured notes, private collective investment funds, and/or other types of investments, as appropriate, to meet the needs of certain Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Palo Alto’s investment approach is primarily long-term focused, but the Advisor may buy, sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Palo Alto will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Palo Alto evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Palo Alto may recommend, on occasion, redistributing investment allocations to diversify the portfolio. The Advisor may recommend employing cash positions as a possible hedge against market movement. Palo Alto may recommend selling positions for reasons that include but are not limited to harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in the risk tolerance of Client, generating cash to meet the Client’s needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA or recommend a similar transaction including rollovers from one ERISA sponsored Plan to Page 4 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor earns a new (or increases its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will Palo Alto accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the agreement. Please see Item 12 – Brokerage Practices. Donor-Advised Fund Services – The Advisor provides the Pershing Donor-Advised Fund (“DAF”) to Clients via the American Endowment Foundation, a solution for charitable giving to philanthropic vehicles, for the purpose of managing charitable donations contributed by or on behalf of donor clients. The DAF allows the Advisor to actively manage assets that have been donated while charging an investment management fee. The Advisor operates as an advisory manager on the platform. The American Endowment Foundation is an independent company and unaffiliated with the Advisor. Non-Purpose Loans and Lines of Credit – If deemed in a Client’s best interest, the Advisor may introduce certain Clients to non-purpose loan programs (“Lending Program”) made available through The Bank of New York Mellon Corporation (“BNY Mellon”) or Pershing, LLC. In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for the non-purpose loan. The recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related to the risks involved with non-purpose loans and lines of credit, please see Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. Financial Planning Services – Palo Alto will typically provide a variety of financial planning services to individuals and families as a component of its wealth management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Palo Alto may also refer Clients to an accountant, attorney, or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of the contract date, assuming all information and documents requested are provided promptly. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction[s] through the Advisor. Page 5 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com C. Client Account Management Prior to engaging Palo Alto to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Palo Alto, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives. • Asset Allocation – Palo Alto will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client. • Portfolio Construction – Palo Alto will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Palo Alto will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Palo Alto does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Palo Alto. E. Assets Under Management As of December 31, 2024, Palo Alto manages $770,350,606 in Client assets, $615,969,891 of which are managed on a discretionary basis and $154,380,715 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior quarter. The Advisor imposes a minimum annual fee of $10,000, which may be reduced or waived at the Advisor’s discretion. Wealth management fees are based on the following schedule: Assets Under Management ($) Up to $1,000,000 $1,000,001 to $2,000,000 $2,000,001 to $4,000,000 $4,000,001 to $8,000,000 $8,000,001 to $15,000,000 $15,000,001 to $25,000,000 Over $25,000,000 Annual Rate (%) 0.90% 0.80% 0.70% 0.60% 0.50% 0.40% 0.30% Certain legacy Clients may have a minimum annual fee different from the above, pursuant to the terms of their wealth management agreement with Palo Alto. The wealth management fees in the first quarter of service are prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may also be offered a fixed dollar fee arrangement. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. For Clients who engage the Advisor for DAF, Palo Alto will waive the fees of up to $500,000 placed under the DAF platform. All securities held in accounts managed by Palo Alto will be independently valued by the Custodian. Palo Alto will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Page 6 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com The Client may make additions or withdrawals from the account[s] at any time, subject to the Advisor’s right to terminate an account or the overall relationship. Additions may be in cash or securities provided that the Advisor reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw account assets on notice to Palo Alto, subject to the usual and customary securities settlement procedures. However, the Advisor typically designs its investment portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client’s investment objectives. Palo Alto may consult the Client about the implications of such transactions. Clients are advised that when such securities are liquidated, they may be subject to securities transaction fees, short-term redemption fees, and/or tax ramifications. If assets in excess of $50,000 are deposited into or withdrawn from the Client’s account[s], an adjustment will be made in the next billing period to reflect the fee difference. The Advisor may negotiate a fee that differs from the schedule above for certain account[s] or holdings. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C. below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning Services Palo Alto offers standalone financial planning services for a fixed fee of $5,000 per engagement. Fees may be negotiable depending on the nature and complexity of each Client’s circumstances and the experience of the personnel providing services. A cost estimate will be provided to the Client in advance of engaging for these services. If a Client engages the Advisor for wealth management services within two (2) years of the financial planning engagement, Palo Alto may offset all or a portion of its fees for those services based upon the amount paid for financial planning services. B. Fee Billing Wealth Management Services Wealth management fees will be calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor or its delegate shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective quarter-end date. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Palo Alto at the end of the previous quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting the deduction of the wealth management fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by Palo Alto directly from their accounts held at the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Financial Planning Services Financial planning fees are invoiced up to fifty percent (50%) upon execution of the financial planning agreement and with the balance due upon receipt of the agreed upon deliverable[s]. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties other than Palo Alto in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all securities execution and custody fees charged by the Custodian, as applicable. The investment advisory fee charged by Palo Alto is separate and distinct from these custody and execution fees. In addition, fees paid to Palo Alto for investment advisory services are generally separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Palo Alto, but would not receive the services provided by Palo Alto, which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. The Client should review both the fees charged by the fund[s] and the fees charged by Palo Alto to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. Page 7 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com D. Advance Payment of Fees and Termination Wealth Management Services Palo Alto is compensated for its wealth management services in advance of the quarter in which services are rendered. Either party may terminate the wealth management agreement with Palo Alto, at any time, by providing advance written notice to the other party. The Client shall be responsible for wealth management fees up to and including the effective date of termination. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the quarter. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services Palo Alto requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing written notice to the other party. Upon termination, the Client shall be billed for the percentage of the engagement scope completed by the Advisor. The Advisor will refund any unearned, prepaid financial planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Palo Alto does not buy or sell securities to generate commission revenue and is solely compensated through the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Palo Alto does not charge performance-based fees for its investment advisory services. The fees charged by Palo Alto are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Palo Alto does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Palo Alto offers investment advisory services to high net worth individuals, trusts, estates, and other types of clients. The amount of each type of Client is available on the Advisor’s Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. Palo Alto does not impose a minimum relationship size; however, the Advisor does impose a minimum investment advisory fee of $10,000, which can be reduced or waived at the sole discretion of the Advisor. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis Palo Alto primarily employs a fundamental analysis method in developing investment strategies for its Clients but may employ other methods. Research and analysis from Palo Alto are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases, and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Page 8 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com As noted above, Palo Alto generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Palo Alto will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Palo Alto may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Palo Alto will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals, or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Options contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Structured Notes Structured notes are securities issued by financial institutions whose returns are based on, among other things, equity indexes, a single equity security, a basket of equity securities, interest rates, commodities, and/or foreign currencies. Thus, returns are “linked” to the performance of a reference asset or index. Structured notes have specific risks that include market risk, an issuance price that is likely higher the fair value of the note on the date of the issuance, liquidity risk, credit risk, call risk, and a complicated payoff structure. Page 9 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Non-Purpose Loans and Lines of Credit Non-purpose loans and lines of credit carry a number of risks, including but not limited to the risk of a market downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian may result in a reduction in the draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit additional funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral account[s]. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) is typically shown quarterly and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Clients should only have a portion of their assets in these investments. Private Collective Investment Vehicle Risks The Advisor recommends that certain clients invest in privately placed collective investment vehicles (e.g., hedge funds, private equity funds, etc.). The managers of these vehicles have broad discretion in selecting the investments. There are few limitations on the types of securities or other financial instruments that may be traded and no requirement to diversify. Hedge funds may trade on margin or otherwise leverage positions, thereby potentially increasing the risk to the vehicle. In addition, because the vehicles are not registered as investment companies, they are much less regulated than investment companies. There are numerous other risks in investing in these securities. Clients should consult each fund’s private placement memorandum and/or other documents explaining such risks prior to investing. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory, or disciplinary events involving Palo Alto or its management persons. Palo Alto values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 285326. Item 10 – Other Financial Industry Activities and Affiliations The sole business of Palo Alto is to provide investment advisory services to its Clients. Neither Palo Alto nor its Advisory Persons are involved in other business endeavors. Palo Alto does not maintain any affiliations with other firms other than the contracted service providers to assist with the servicing of its Client’s accounts. Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics Palo Alto has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Palo Alto (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. Palo Alto and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of Palo Alto Supervised Persons to adhere not only to the specific provisions of the Code but also to the general principles that guide the Code. The Code covers a range of topics that address ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (650) 656-9800. B. Personal Trading with Material Interest Palo Alto allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Palo Alto does not act as principal in any transactions. In addition, the Page 10 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Advisor does not act as the general partner of a fund or advise an investment company. Palo Alto does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Palo Alto allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls) and personal securities reporting procedures. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can potentially be violated if personal trades are made with more advantageous terms than Client trades or by trading based on material non-public information. This risk is mitigated by Palo Alto requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Palo Alto allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will Palo Alto or any Supervised Person of Palo Alto transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Palo Alto does not maintain custody of Client assets and does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Palo Alto to trade within its account[s] at the Custodian unless otherwise directed by the Client. Palo Alto will recommend the Custodian and assist with the paperwork for establishing account[s]. Through the investment advisory agreement and Custodian agreements, the Client shall authorize Palo Alto to access the Client’s account[s] and effect securities trades. Where Palo Alto does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Palo Alto may recommend the Custodian based on criteria such as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the Client, and the Custodian’s reputation. Palo Alto does not receive research services, other products, or compensation as a result of recommending a particular Custodian that may result in the Client paying higher commissions than those obtainable through other broker-dealers/custodians. Palo Alto will generally recommend that Clients establish accounts at Pershing Advisor Solutions, a subsidiary of Pershing LLC, member FINRA, NYSE, SIPC, which is a wholly-owned subsidiary of BNY Melon (herein “Pershing”), or Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Palo Alto. However, if the recommended Custodian is not engaged, the Advisor may be limited in the services it can provide. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Palo Alto does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, Palo Alto does receive economic benefits in connection with its institutional relationships. Please see Item 14 below. 2. Brokerage Referrals – Palo Alto does not receive any compensation from any third party in connection with the recommendation for establishing an account. Page 11 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com 3. Directed Brokerage – Clients are generally serviced on a “directed brokerage basis,” where Palo Alto will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Palo Alto will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Palo Alto will execute its transactions through the Custodian as directed by the Client [or another broker-dealer/custodian as directed by the Client]. Palo Alto may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A. above, each Client account shall be reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Palo Alto if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic, or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Palo Alto Palo Alto is a fee-only advisory firm that is compensated solely by its Clients and not from any investment product. Palo Alto does not receive commissions or other compensation from product sponsors, broker-dealers, or any unrelated third party. Palo Alto may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Palo Alto may receive non-compensated referrals of new Clients from various third parties. Participation in Institutional Advisor Platform (Pershing) Palo Alto has established an institutional relationship with Pershing to assist the Advisor in managing Client account[s]. Access to the Pershing institutional platform is provided at no charge to the Advisor. The Advisor Page 12 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Pershing. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor may receive the following benefits from Pershing receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading, which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information. Participation in Institutional Advisor Platform (Schwab) Palo Alto has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Palo Alto. As a registered investment advisor participating on the Schwab Advisor Services platform, Palo Alto receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Palo Alto that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Palo Alto believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody Palo Alto does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Palo Alto exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Palo Alto to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Palo Alto to ensure accuracy, as the Custodian does not perform this review. Page 13 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Money Movement Authorization - For instances where Clients authorize Palo Alto to move funds between their accounts, Palo Alto and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Item 16 – Investment Discretion Palo Alto generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Palo Alto. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Palo Alto will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Palo Alto does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies; however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Palo Alto nor its management has any adverse financial situations that would reasonably impair the ability of Palo Alto to meet all obligations to its Clients. Neither Palo Alto nor any of its Advisory Persons have been subject to a bankruptcy or financial compromise. Palo Alto is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. Page 14 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Form ADV Part 2B – Brochure Supplement for Ryan K. Schmidt Partner Effective: March 13, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Ryan K. Schmidt (CRD# 4024403) in addition to the information contained in the Palo Alto Wealth Advisors, LLC (“Palo Alto” or the “Advisor,” CRD # 285326) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Palo Alto Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (650) 656-9800. Additional information about Mr. Schmidt is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 4024403. Page 15 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Item 2 – Educational Background and Business Experience Ryan K. Schmidt, born in 1978, is dedicated to advising Clients of Palo Alto as its Partner. Mr. Schmidt earned a Master’s of Business Administration degree from Stanford University’s Graduate School of Business in 2006. Mr. Schmidt also earned a Bachelor of Administration degree in Economics and International Relations from Stanford University in 2000. Additional information regarding Mr. Schmidt’s employment history is included below. Employment History: Partner, Palo Alto Wealth Advisors, LLC Investment Advisor Representative, Schmidt Financial Group, Inc. Product Manager, VMware Associate, Advent International Associate, The Boston Consulting Group 09/2016 to Present 08/2006 to 12/2016 06/2005 to 08/2005 07/2002 to 01/2004 09/2000 to 06/2002 Item 3 – Disciplinary Information There are no legal, civil, or disciplinary events to disclose regarding Mr. Schmidt. Mr. Schmidt has never been involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits, arbitration claims, or administrative proceedings against Mr. Schmidt. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there are no legal, civil, or disciplinary events to disclose regarding Mr. Schmidt. However, the Advisor encourages you to independently view the background of Mr. Schmidt on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 4024403. Item 4 – Other Business Activities Mr. Schmidt is dedicated to the investment advisory activities of Palo Alto’s Clients. Mr. Schmidt does not have any other business activities. Item 5 – Additional Compensation Mr. Schmidt is dedicated to the investment advisory activities of Palo Alto’s Clients. Mr. Schmidt does not receive any additional forms of compensation. Item 6 – Supervision Mr. Schmidt serves as a Partner of Palo Alto and is supervised by Nathan Blair, the Chief Compliance Officer. Mr. Blair can be reached at (650) 656-9800. Palo Alto has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Palo Alto. Further, Palo Alto is subject to regulatory oversight by various agencies. These agencies require registration by Palo Alto and its Supervised Persons. As a registered entity, Palo Alto is subject to examinations by regulators, which may be announced or unannounced. Palo Alto is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Page 16 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Form ADV Part 2B – Brochure Supplement for Nathan T. Blair Partner and Chief Compliance Officer Effective: March 13, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Nathan T. Blair (CRD# 3130445) in addition to the information contained in the Palo Alto Wealth Advisors, LLC (“Palo Alto” or the “Advisor,” CRD# 285326) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Palo Alto Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (650) 656-9800. Additional information about Mr. Blair is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 3130445. Page 17 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Item 2 – Educational Background and Business Experience Nathan T. Blair, born in 1975, is dedicated to advising Clients of Palo Alto as a Partner and the Chief Compliance Officer. Mr. Blair earned a Bachelor of Arts degree from Rice University in 1998. Mr. Blair also earned a Master’s of Business Administration degree from Stanford Graduate School of Business in 2006. Additional information regarding Mr. Blair’s employment history is included below. Employment History: Partner and Chief Compliance Officer, Palo Alto Wealth Advisors, LLC Director, Aetos Capital, LLC Associate Director, Corporate Development, SVB Financial Group Research Associate, Case Writer, Stanford University Vice President, The CapStreet Group 03/2017 to Present 09/2011 to 02/2017 06/2010 to 06/2011 10/2008 to 06/2010 09/2006 to 09/2008 Item 3 – Disciplinary Information There are no legal, civil, or disciplinary events to disclose regarding Mr. Blair. Mr. Blair has never been involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits, arbitration claims, or administrative proceedings against Mr. Blair. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there are no legal, civil, or disciplinary events to disclose regarding Mr. Blair. However, the Advisor encourages you to independently view the background of Mr. Blair on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 3130445. Item 4 – Other Business Activities Mr. Blair is dedicated to the investment advisory activities of Palo Alto’s Clients. Mr. Blair does not have any other business activities. Item 5 – Additional Compensation Mr. Blair is dedicated to the investment advisory activities of Palo Alto’s Clients. Mr. Blair does not receive any additional forms of compensation. Item 6 – Supervision Mr. Blair serves as a Partner and the Chief Compliance Officer of Palo Alto. Mr. Blair can be reached at (650) 656-9800. Palo Alto has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Palo Alto. Further, Palo Alto is subject to regulatory oversight by various agencies. These agencies require registration by Palo Alto and its Supervised Persons. As a registered entity, Palo Alto is subject to examinations by regulators, which may be announced or unannounced. Palo Alto is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Page 18 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Form ADV Part 2B – Brochure Supplement for Kegan K. Johnson, CFA® Financial Advisor Effective: March 13, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Kegan K. Johnson, CFA®, (CRD# 7508780) in addition to the information contained in the Palo Alto Wealth Advisors, LLC (“Palo Alto” or the “Advisor,” CRD# 285326) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Palo Alto Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (650) 656-9800. Additional information about Mr. Johnson is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 7508780. Page 19 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Item 2 – Educational Background and Business Experience Kegan K. Johnson, CFA®, born in 1989, is dedicated to advising Clients of Palo Alto as a Financial Advisor. Mr. Johnson earned a Bachelor’s degree in Business Administration from the University of San Diego in 2011. Additional information regarding Mr. Johnson’s employment history is included below. Employment History: Financial Advisor, Palo Alto Wealth Advisors, LLC Trade Commissioner/Senior Investment Officer, Consulate General of Canada Franklin Fellow/Foreign Affairs Officer, U.S. Department of State Analyst (Corporate Development & Analysis), Syufy Enterprises 03/2022 to Present 10/2017 to 03/2022 07/2016 to 08/2017 01/2012 to 07/2016 Chartered Financial Analyst™ (“CFA®”) The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and awarded by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA® Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. Also, CFA® charter holders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by and annually reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of Professional Conduct. CFA® is a trademark owned by CFA® Institute. Item 3 – Disciplinary Information There are no legal, civil, or disciplinary events to disclose regarding Mr. Johnson. Mr. Johnson has never been involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits, arbitration claims, or administrative proceedings against Mr. Johnson. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there are no legal, civil, or disciplinary events to disclose regarding Mr. Johnson. However, the Advisor encourages you to independently view the background of Mr. Johnson on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 7508780. Item 4 – Other Business Activities Mr. Johnson is dedicated to the investment advisory activities of Palo Alto’s Clients. Mr. Johnson does not have any other business activities. Item 5 – Additional Compensation Mr. Johnson is dedicated to the investment advisory activities of Palo Alto’s Clients. Mr. Johnson does not receive any additional forms of compensation. Item 6 – Supervision Mr. Johnson serves as a Financial Advisor of Palo Alto and is supervised by Nathan Blair, the Chief Compliance Officer. Mr. Blair can be reached at (650) 656-9800. Page 20 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Palo Alto has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Palo Alto. Further, Palo Alto is subject to regulatory oversight by various agencies. These agencies require registration by Palo Alto and its Supervised Persons. As a registered entity, Palo Alto is subject to examinations by regulators, which may be announced or unannounced. Palo Alto is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Page 21 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Form ADV Part 2B – Brochure Supplement for Simon A. Tryzna, CFA® Portfolio Manager Effective: March 13, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Simon A. Tryzna, CFA® (CRD# 6279731) in addition to the information contained in the Palo Alto Wealth Advisors, LLC (“Palo Alto” or the “Advisor,” CRD# 285326) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Palo Alto Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (650) 656-9800. Additional information about Mr. Tryzna is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 6279731. Page 22 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Item 2 – Educational Background and Business Experience Simon A. Tryzna, CFA®, born in 1993, is dedicated to advising Clients of Palo Alto as a Portfolio Manager. Mr. Tryzna earned a Bachelor of Science degree in Economics and a Bachelor of Arts degree in Business Administration from Saint Mary's College of California in 2015. Additional information regarding Mr. Tryzna’s employment history is included below. Employment History: Portfolio Manager, Palo Alto Wealth Advisors, LLC CIO and Wealth Advisor, ClearPath Capital Partners 02/2022 to Present 07/2015 to 01/2022 Chartered Financial Analyst™ (“CFA®”) The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and awarded by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA® Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. Also, CFA® charter holders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by and annually reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of Professional Conduct. CFA® is a trademark owned by CFA® Institute. Item 3 – Disciplinary Information There are no legal, civil, or disciplinary events to disclose regarding Mr. Tryzna. Mr. Tryzna has never been involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits, arbitration claims, or administrative proceedings against Mr. Tryzna. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there are no legal, civil, or disciplinary events to disclose regarding Mr. Tryzna. However, the Advisor encourages you to independently view the background of Mr. Tryzna on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 6279731. Item 4 – Other Business Activities Mr. Tryzna is dedicated to the investment advisory activities of Palo Alto’s Clients. Mr. Tryzna does not have any other business activities. Item 5 – Additional Compensation Mr. Tryzna is dedicated to the investment advisory activities of Palo Alto’s Clients. Mr. Tryzna does not receive any additional forms of compensation. Item 6 – Supervision Mr. Tryzna serves as a Portfolio Manager of Palo Alto and is supervised by Nathan Blair, the Chief Compliance Officer. Mr. Blair can be reached at (650) 656-9800. Page 23 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Palo Alto has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Palo Alto. Further, Palo Alto is subject to regulatory oversight by various agencies. These agencies require registration by Palo Alto and its Supervised Persons. As a registered entity, Palo Alto is subject to examinations by regulators, which may be announced or unannounced. Palo Alto is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Page 24 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com Privacy Policy Effective: March 13, 2025 Our Commitment to You Palo Alto Wealth Advisors, LLC (“Palo Alto” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Palo Alto (also referred to as "we," "our," and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Palo Alto does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered investment advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Social security or taxpayer identification number Assets and liabilities Name, address, and phone number[s] Income and expenses Email address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage, and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use, we maintain physical, procedural, and electronic security measures. These include such safeguards as secure passwords, encrypted file storage, and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect our Clients’ personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Page 25 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, Custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed-upon services to you, consistent with applicable law, including but not limited to processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Marketing Purposes Palo Alto does not disclose and does not intend to disclose personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Palo Alto or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients Palo Alto does not disclose and does not intend to disclose non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations California In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (650) 656-9800. Page 26 Palo Alto Wealth Advisors, LLC 715 Colorado Avenue, Suite A, Palo Alto, CA 94303 Phone: (650) 656-9800 www.PaloAltoWealth.com