SHP WEALTH MANAGEMENT, LLC

SHP Wealth Management, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of SHP Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at (508) 746-2400 or by email at: ask@shpfinancial.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 SHP Wealth Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. SHP Wealth Management, LLC’s CRD number is: 174697. 225 Water St Unit 210C Plymouth, MA, 02360 (508) 746-2400 ask@shpfinancial.com Registration does not imply a certain level of skill or training. Version Date: 03/11/2025 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of SHP Wealth Management, LLC on 02/12/2024 are described below. Material changes relate to SHP Wealth Management, LLC policies, practices or conflicts of interests only. • SHP Wealth Management, LLC has updated its fee schedule. (Item 5) • SHP Wealth Management, LLC utilizes third party money managers. (Item 4, 5, and 10) • SHP Wealth Management, LLC will compensate solicitors for client referrals. (Item 14) ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ..................................................................................................................................................ii Item 3: Table of Contents ................................................................................................................................................ iii Item 4: Advisory Business ................................................................................................................................................ 2 A. Description of the Advisory Firm ........................................................................................................................... 2 B. Types of Advisory Services ...................................................................................................................................... 2 C. Client Tailored Services and Client Imposed Restrictions ..................................................................................... 4 D. Wrap Fee Programs .................................................................................................................................................. 4 E. Assets Under Management ...................................................................................................................................... 4 Item 5: Fees and Compensation........................................................................................................................................ 4 A. Fee Schedule ............................................................................................................................................................. 4 Educational Seminar/Workshop Fees ..................................................................................................................... 6 B. Payment of Fees ........................................................................................................................................................ 6 Payment of Educational Seminar/Workshop Fees................................................................................................. 7 C. Client Responsibility For Third Party Fees ............................................................................................................. 7 D. Prepayment of Fees .................................................................................................................................................. 7 E. Outside Compensation For the Sale of Investment Products to Clients ............................................................... 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 Investment Loss ...................................................... 9 A. Methods of Analysis and Investment Strategies .............................................................................................. 9 B. Material Risks Involved ..................................................................................................................................... 9 C. Risks of Specific Securities Utilized ................................................................................................................ 10 Item 9: Disciplinary Information .................................................................................................................................... 12 A. Criminal or Civil Actions ................................................................................................................................. 12 B. Administrative Proceedings ............................................................................................................................ 12 C. Self-regulatory Organization (SRO) Proceedings .......................................................................................... 12 Item 10: Other Financial Industry Activities and Affiliations ...................................................................................... 12 A. Registration as a Broker/Dealer or Broker/Dealer Representative .............................................................. 12 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading B. Advisor ........................................................................................................................................................................ 13 iii  C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ........... 13 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections.. 14 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................... 15 A. Code of Ethics ................................................................................................................................................... 15 B. Recommendations Involving Material Financial Interests ............................................................................ 15 C. Investing Personal Money in the Same Securities as Clients ........................................................................ 15 D. Trading Securities At/Around the Same Time as Clients’ Securities ........................................................... 15 Item 12: Brokerage Practices ........................................................................................................................................... 16 A. Factors Used to Select Custodians and/or Broker/Dealers .......................................................................... 16 1. Research and Other Soft-Dollar Benefits .................................................................................................... 16 2. Brokerage for Client Referrals ..................................................................................................................... 16 3. Clients Directing Which Broker/Dealer/Custodian to Use ...................................................................... 16 B. Aggregating (Block) Trading for Multiple Client Accounts .......................................................................... 17 C. Trade Errors ...................................................................................................................................................... 17 Item 13: Reviews of Accounts ......................................................................................................................................... 17 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews............................................. 17 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ......................................................... 18 C. Content and Frequency of Regular Reports Provided to Clients .................................................................. 18 Item 14: Client Referrals and Other Compensation ...................................................................................................... 18 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or A. Other Prizes) ................................................................................................................................................................ 18 B. Compensation to Non – Advisory Personnel for Client Referrals ................................................................ 18 Item 15: Custody ............................................................................................................................................................. 18 Item 16: Investment Discretion ....................................................................................................................................... 19 Item 17: Voting Client Securities (Proxy Voting) .......................................................................................................... 19 Item 18: Financial Information ....................................................................................................................................... 19 A. Balance Sheet .................................................................................................................................................... 19 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients 19 C. Bankruptcy Petitions in Previous Ten Years .................................................................................................. 19 iv  Item 4: Advisory Business A. Description of the Advisory Firm SHP Wealth Management, LLC (hereinafter “SWML”) is a Limited Liability Company organized in the State of Massachusetts. The firm was formed in December 2014, and the owner is SHP Holding, LLC. SHP Holding, LLC is owned by Keith Ellis & Associates, LLC, Gregoire & Associates, LLC and Helicon MTN Group, Inc. Helicon MTN Group Inc. is owned by Matthew C. Peck, CFP®, CIMA®, Gregoire & Associates, LLC is owned by Derek Louis Gregoire and Keith Ellis & Associates, LLC is owned by Keith W Ellis Jr. B. Types of Advisory Services Portfolio Management Services SWML offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SWML creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring SWML evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SWML will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. SWML seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SWML’s economic, investment or other financial interests. To meet its fiduciary obligations, SWML attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SWML’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is SWML’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. 2  Pension Consulting Services SWML 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 o o providing guidance on various assets classes and investment options o recommending money managers to manage plan assets in ways designed to achieve objectives o monitoring performance of money managers and investment options and making recommendations for changes o recommending other service providers, such as custodians, administrators and broker-dealers o creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Subadviser Services SWML may also act as a subadviser to advisers unaffiliated with SWML. These third party advisers would outsource portfolio management services to SWML. This relationship will be memorialized in each contract between SWML and the third party advisor. This would include model portfolio construction to outside RIA’s that wish to gain access to our portfolio construction and research. Selection of Other Advisers SWML may direct clients to third party investment advisers. Before selecting other advisers for clients, SWML will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where SWML is recommending the adviser to clients. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; health insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Educational seminars and workshops. SWML provides periodic educational seminars and workshops to clients. Services Limited to Specific Types of Investments 3  SWML generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities. SWML may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions SWML will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by SWML on behalf of the client. SWML may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SWML from properly servicing the client account, or if the restrictions would require SWML to deviate from its standard suite of services, SWML reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. SWML does not participate in any wrap fee programs. E. Assets Under Management SWML has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $1,396,390,415 $100,484,837 December 2024 Item 5: Fees and Compensation A. Fee Schedule Asset-Based Fees for Portfolio Management SHP Wealth Management charges clients the following blended fee for assets under management. 4  Total Assets Under Management Annual Fee $0 - $500,000 1.25% $500,001 - $2,000,000 1.00% $2,000,001 - $3,500,000 0.85% $3,500,001 – $6,000,000 0.70% $6,000,001 - $8,000,000 0.60% $0,000,001 – $10,000,000 0.50% $10,000,001 – $15,000,000 0.40% $15,000,001 - $20,000,000 0.30% $20,000,001 – And above 0.20% For Example: An account valued at $1,000,000 would incur a fee of 1.25% on the first $500,000 and 1.0% on the next $500,000 for a total blended fee of 1.13% These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of SWML's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. An average of the daily balance in the client’s account throughout the billing period is used to determine the market value of the assets upon which the advisory fee is based. Pension Consulting Services Fees The table for pension consulting services is below: Total Assets Under Management Annual Fee $0 - $1,000,000 1.25% $1,000,001- $5,000,000 1.00% $5,000,001 – and Up 0.85% *These fees are negotiable. Subadviser Services Fees SWML may also act as a subadviser or provide model portfolio construction and research to unaffiliated third-party advisers and SWML would receive a share of the fees collected from the third-party adviser’s client The fees charged are negotiable and will not exceed 5  any limit imposed by any regulatory agency. This relationship will be memorialized in each contract between SWML and the third-party adviser. Selection of Other Advisers Fees SWML may direct clients to third-party investment advisers. SWML will receive its standard fee on top of the fee paid to the third party adviser. The fees shared are negotiable and will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. SWML may specifically direct clients to AllianceBernstein L.P.. The annual fee schedule is as follows: Third Party Annual Fee 0.13% 0.13% 0.18% 0.18% 0.20% Strategy Name AB Municipal High Quality Fixed Income SMA AB Customized Municipal Ladders SMA AB Municipal Income Fixed Income SMA AB Municipal Impact Fixed Income SMA AB Tax Aware Fixed Income SMA Financial Planning Fees Clients may terminate the agreement without penalty for a full refund of SWML's fees within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Hourly Fees The negotiated hourly fee for these services is between $100 and $500. Fees are charged in arrears upon completion. Educational Seminar/Workshop Fees SWML does not charge a fee for the educational seminars and workshops. They are complimentary. B. Payment of Fees Payment of Asset-Based Portfolio Management Fees Portfolio management fees are withdrawn directly from the client’s accounts with client’s written authorization or may be invoiced and billed directly to the client; clients may select the method in which they are billed. Fees are paid monthly in arrears. Payment of Pension Consulting Services Fees 6  Pension consulting fees are withdrawn directly from the client’s accounts with client’s written authorization. Fees are paid monthly. Payment of Subadviser Fees Subadviser fees may be withdrawn from client’s accounts or clients may be invoiced for such fees, as disclosed in each contract between SWML and the applicable third-party adviser. Fees can be paid via check or ETF. Payment of Selection of Other Advisers Fees Fees for selection of AllianceBernstein L.P. as third-party adviser are withdrawn by AllianceBernstein L.P. directly from client accounts quarterly in advance. SWML fees withdrawn directly from the client’s accounts with client’s written authorization or may be invoiced and billed directly to the client; clients may select the method in which they are billed. Fees are paid monthly in arrears. Payment of Financial Planning Fees Financial planning fees are paid via check or credit card. Hourly financial planning fees are paid in arrears upon completion. Payment of Educational Seminar/Workshop Fees SWML does not charge a fee for the educational seminars and workshops. They are complimentary. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.) although under certain circumstances, SHPWM may pay certain fees charged to the client. Those fees are separate and distinct from the fees and expenses charged by SWML. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees SWML collects its fees in arrears for all services other than providing model portfolio construction and research. Fees for that service are paid quarterly in advance, as disclosed in each contract between SWML and the applicable third-party adviser. 7  E. Outside Compensation For the Sale of Investment Products to Clients Supervised persons of SWML receive commissions for the sale of insurance products to clients of SWML. Commissions from insurance products are a significant source of compensation and are paid in addition to advisory fees. When determining the asset based advisory fees, the assets that are allocated into the insurance products are included in the calculation but are not subject to the advisory fee. Receipt of commissions presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of products for which the supervised receives compensation, SWML will document the conflict of interest in the client file and inform the client of the conflict of interest. Our clients always have the option to purchase recommended products through other brokers or agents that are not affiliated with SWML. Please see additional disclosures about this conflict in Item 10C of this brochure. Item 6: Performance-Based Fees and Side-By-Side Management SWML does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients SWML generally provides advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Pension and Profit Sharing plans ❖ Charitable Organizations ❖ Corporations Minimum Account Size There is no account minimum for any of SWML’s services. TPA have minimums which range from $10,000 to $50,000. 8  Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis SWML’s methods of analysis include fundamental analysis, cyclical analysis and modern portfolio theory. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Modern portfolio theory is 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, each by carefully choosing the proportions of various asset. Investment Strategies SWML uses long term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. 9  Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns 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. Selection of Other Advisers: Although SWML will seek to select only money managers who will invest clients' assets with the highest level of integrity, SWML's selection process cannot ensure that money managers will perform as desired and SWML will have no control over the day-to-day operations of any of its selected money managers. SWML would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulator breach or fraud. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. 10  Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. 11  Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings On October 28, 2015, the Massachusetts Division of Securities entered an order in the matter of SHP Wealth Management, LLC, Matthew C. Peck, CFP®, CIMA®, Derek L. Gregoire, and Keith W. Ellis, Jr. The Division found that Mr. Peck, Mr. Gregoire, and Mr. Ellis engaged in the sale of securities that were neither registered nor exempt from registration and did not conduct sufficient due diligence into the securities. The Order conditioned the registration of the firm on the firm engaging an independent compliance consultant to conduct annual compliance reviews of the firm for five years. In addition, for a period of five years, the firm is prohibited from having custody of client assets or securities other than for deduction of advisory fees in compliance with MA regulations. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither SWML nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. 12  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither SWML nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Matthew Chapman Peck, CFP®, CIMA®, Derek Louis Gregoire, and Keith Winslow Ellis Jr. are independent licensed insurance agents, and Owners/Partners of an insurance agency, SHP Financial, LLC. In addition, other supervised persons of SWML are independent licensed insurance agents of SHP Financial, LLC. They will offer clients advice or products from those activities. These activities create a conflict of interest as supervised persons have an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of SWML are not made in their capacity as fiduciaries, and products are limited to only those offered by certain insurance providers. SWML addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client, including when acting as an insurance agent. SWML periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. SWML will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will an advisory client be required to use the outside services of any supervised person as a condition of receiving advisory services of SWML. No client is under any obligation to purchase any insurance product. Insurance products recommended by SWML supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended by SWML or its supervised persons through other, un-affiliated insurance agencies. Matthew Chapman Peck, CFP®, CIMA®, Derek Louis Gregoire and Keith Winslow Ellis, Jr. are owners or managing members of various entities disclosed in their outside business activities in their individual ADV 2B brochures. SWML recommends securities backed lines of credit (“SBLOC”) through an agreement with Goldman Sachs Private Bank. Although SWML does not receive any financial compensation from offering these loans, a recommendation to engage in a SBLOC presents a conflict of interest as the securities that serve as collateral for these loans are 13  part of SWLM’s assets under management and subject to fees. By recommending the SBLOC as compared to a liquidation, the securities used collateral would continue to be billed which may encourage SWML to offer the loan and maintain the assets under management for billing and revenue purposes. In order to mitigate the conflict of interest and to ensure the client is learned enough to participate in the loan, SWML has their own internal form which must be signed by the client, highly recommends not exceeding an amount of 50% of loan to value which is lower than the 65% limit provided by Goldman Sachs, and must confirm that the client is an accredited investor as defined by Rule 501 of Regulation D by the U. S. Securities and Exchange Commission. This internal form is in additional to the normal due diligence of gathering a comprehensive knowledge of the client’s financial situation and thorough documentation of the decision-making process. There are various risks for the client that are associated with an SBLOC which are, but not limited to, a significant increase in interest rates which would increase the cost of borrowing, an adverse market movement which would require a collateral call and either a deposit of additional monies or a subsequent liquidation of securities at depressed valuations which may be compounded by adverse tax consequences. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections SWML receives compensation from Triad Partners (“Triad”), for the sale of insurance products to clients of SWML. This compensation may be in the form of commissions, bonuses, sales awards, incentive trips, attendance to seminars, conferences, and entertainment events, marketing reimbursements, speaking fees, consulting fees, and other economic benefits. Some of these benefits, in part, are contingent upon the cumulative amount of business referred to Triad, such as total annuity and life insurance production through Triad. The achievement of particular sales volumes may qualify SWML and/or its supervised persons for additional cash and non-cash compensation. In addition, Triad Partners also provides SWML with significant marketing assistance, technology, and business development tools to acquire new clients, as well as with certain back office and operational support. The owners of SWML also own Four Hands, LLC (“Four Hands”). Four Hands has minor ownership interests in Triad, which SHP may use to write annuity and life insurance business through. SWML will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will an advisory client be required to use the outside services of any supervised person as a condition of receiving advisory services of SWML. No client is under any obligation to purchase any insurance product. SWML may direct clients to third-party investment advisers. Clients will pay SWML its standard fee in addition to the standard fee for the advisers to which it directs those clients. The fees will not exceed any limit imposed by any regulatory agency. SWML will always act in the best interests of the client, including when determining which third party investment adviser to recommend to clients. SWML will ensure that all recommended 14  advisers are exempt, licensed or notice filed in the states in which SWML is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics SWML has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. SWML's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests SWML does not recommend that clients buy or sell any security in which a related person to SWML or SWML has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of SWML may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of SWML to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. SWML will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of SWML may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of SWML to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, SWML will never engage in trading that operates to the client’s disadvantage if representatives of SWML buy or sell Securities at or around the same time as clients. 15  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on SWML’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and SWML may also the market expertise and research access provided by the broker- consider dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in SWML's research efforts. SWML will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. SWML recommends Fidelity Brokerage Services LLC and Charles Schwab & Co., Inc 1. Research and Other Soft-Dollar Benefits While SWML has no formal soft dollar program in which soft dollars are used to pay for third party services, SWML may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). SWML may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and SWML does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. SWML benefits by not having to produce or pay for the research, products or services, and SWML will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that SWML’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals SWML receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use SWML may permit clients to direct it to execute transactions through a specified broker-dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to SWML to select brokers; this direction may result 16  in higher commissions, which may result in a disparity between free and directed accounts; and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts SWML maintains the ability to block trade purchases and sales across accounts. When more than one account is trading a particular stock or ETF on the same day, block trading may be used to get identical pricing on the trades. Declining to block trade can cause more expensive trades for clients. C. Trade Errors SWML has implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with our fiduciary duty, it is the policy of SWML to correct trade errors in a manner that is fair to the client. In cases where the client causes the trade error, the client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client will not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client will be made whole and any loss resulting from the trade error will be absorbed by SWML if the error was caused by the firm. If the error is caused by the broker-dealer, the broker-dealer will be responsible for covering all trade error costs. The trade will be moved to an error account and will be dealt with at the discretion of the broker dealer. Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for SWML's advisory services provided on an ongoing basis are reviewed at least quarterly by Matthew C Peck, CFP®, CIMA®, President and CCO or the assigned IAR with regard to clients’ respective investment policies and risk tolerance levels. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Matthew C Peck, CFP®, CIMA®, President and CCO or the assigned IAR. There is only one level of review for financial planning, and that is the total review conducted to create the financial plan. 17  B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, a change of health, or inheritance). With respect to financial plans, SWML’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of SWML's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Please see Item 10D for a description of compensation and benefits that SWML and/or its supervised persons receive from Triad Partners. B. Compensation to Non – Advisory Personnel for Client Referrals SWML has a reciprocal referral arrangement with attorney Keith McManus of McManus Estate Planning. SWML routinely refers clients to and receives referrals from Mr. McManus. Related to this arrangement, SWML pays the costs of certain marketing events of Mr. McManus. In addition, supervised persons of SWML who are insurance agents share insurance commissions with Keith McManus on mutual clients. SWML may retain third parties to act as solicitors/promoters for SWML’s investment management services. Compensation with respect to the foregoing will be fully disclosed to each client to the extent required by applicable law. SWML will ensure each solicitor/promoter is properly exempt or registered in all appropriate jurisdictions. Item 15: Custody SHP Wealth Management has Custody due to 3rd party Standing Letters of Authorizations. Also, when advisory fees are deducted directly from client accounts at client's custodian, SWML will 18  be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion SWML provides discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, SWML generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, SWML’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to SWML. Item 17: Voting Client Securities (Proxy Voting) SWML will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet SWML 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. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither SWML nor its management has any financial condition that is likely to reasonably impair SWML’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years SWML has not been the subject of a bankruptcy petition in the last ten years. 19