TRINITY LEGACY PARTNERS, LLC

Firm Brochure Part 2A of Form ADV Trinity Legacy Partners, LLC 24 Greenway Plaza, Suite 546 Houston, TX 77046 2001 Timberloch Place, #500 The Woodlands, TX 77380 Phone 713-999-8053 Fax 713-574-5782 Website www.trinitylegacy.com www.trinitylegacypartners.com Email info@trinitylegacy.com This brochure provides information about the qualifications and business practices of Trinity Legacy Partners LLC. If you have any questions about the contents of this brochure, please contact us at: 713-999-8053, or by email at: trey.wilkinson@trinitylegacy.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. It should be noted that the term registered investment adviser mentioned herein does not imply a certain level of skill or training. Additional information about the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov. Effective as of March 20, 2025 1  Annual Update The Material Changes section of this brochure will be updated annually when material changes occur since the previous release of the Firm Brochure. Item 2-Material Changes since the Last Annual Update None Full Brochure Available Information about Trinity Legacy Partners, LLC is also available via the SEC’s web site www.adviserinfo.sec.gov. The firm’s CRD number is 159179. If you have any questions, please contact us by telephone at 713-999-8053 or by email at trey.wilkinson@trinitylegacy.com. 2  Item 3-Table of Contents Annual Update ...........................................................................................................................2 Item 2-Material Changes since the Last Annual Update ...........................................................2 Full Brochure Available .............................................................................................................2 ADV PART 2A .............................................................................................................................. 4 Item 4-Advisory Services ..........................................................................................................4 Item 5-Fees and Compensation ..................................................................................................7 Item 6-Performance Fees ...........................................................................................................9 Item 7-Types of Clients .............................................................................................................9 Item 8-Methods of Analysis, Investment Strategies and Risk of Loss ......................................9 Item 9-Legal and Disciplinary .................................................................................................13 Item 10-Other Financial Industry Activities and Affiliations ..................................................13 Item 11-Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ..................................................................................................................................................14 Item 12-Brokerage Practices ....................................................................................................15 Item 13-Review of Accounts ...................................................................................................19 Item 14-Client Referrals and Other Compensation .................................................................19 Item 15-Custody.......................................................................................................................20 Item 16-Investment Discretion ................................................................................................20 Item 17-Voting Client Securities .............................................................................................21 Item 18-Financial Information .................................................................................................21 Item 19 Other Disclosures .......................................................................................................21 3  ADV PART 2A Item 4-Advisory Services Firm Description Trinity Legacy Partners, LLC, hereinafter (“the Adviser”) was founded in 2011. The adviser is registered with the Securities and Exchange Commission (“SEC”). As an Investment Adviser, we must adhere to a fiduciary standard. This standard requires Advisers to act and serve a client’s best interests with the intent to eliminate, or at least to expose, all potential conflicts of interest which might incline an Adviser consciously or unconsciously to render advice which is not in the best interest of the client. The Adviser is a fee-only investment management and financial planning firm. The firm does not sell securities on a commission basis. The firm is not affiliated with entities that sell financial products or securities. The Adviser does not act as a custodian of client assets and the client always maintains asset control. The Adviser has the discretion to manage client accounts as outlined in the firm’s investment adviser agreement. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Any conflicts of interest arising out of the Adviser’s, or its associated persons are disclosed in this brochure. Principal Owners: Principal Owners: John P. Wilkinson, III; POM Asset Management, L.P., Lifetree Financial, LLC, Anthony L. Garcia, and John J. Hunter are all principal owners. Additional Office - by appointment: 2001 Timberloch Place, #500 The Woodlands, TX 77380 Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services, and furnishes investment advice through consultations. The Adviser will provide asset management services and is compensated for such services through a management fee further outlined below in Item 5. It should be noted that important aspects of the client’s financial affairs are reviewed prior to executing and implementing any investment management services. Investments may include equities (stocks), commercial paper, certificates of deposit, municipal securities, mutual funds shares, exchange-traded fund shares (ETFs), U. S. government securities, and options contracts. The Adviser also provides financial planning and consulting. Generally, such consultations and planning may include but are not limited to any of the following: reviewing investment accounts and asset allocation; strategic tax planning; reviewing retirement accounts and employer retirement plans; reviewing insurance policies; developing retirement scenarios; estate planning review; and college education planning. 4  Non-Charles Schwab Accounts The Adviser uses a third-party platform to facilitate management of brokerage accounts and defined contribution plan participant accounts, with discretion. The Adviser manages these accounts using the Pontera Order Management System. Please refer to Item 12 – Brokerage Practices for more information. DOL Disclosure When the Adviser provides investment advice to clients regarding a client’s retirement plan account or individual retirement account, the Adviser is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Assets Under Management As of December 31, 2024, the Adviser managed approximately $460,391,294 of assets under management, which included $444,029,126 on a discretionary basis and $16,362,168 on a non- discretionary basis. Tailored Relationships The goals and objectives for each client are documented. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements may not be assigned without the written consent of the client. Types of Agreements The following agreements define the typical client relationships. Investment Advisory Agreement As part of the investment management service, important aspects of the client’s financial affairs are reviewed, and realistic and measurable goals are set and objectives to reach those goals are 5  defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client, which often includes an annual meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Objective Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Investment Consulting Agreement The Adviser may consult with a client on assets held in employer-sponsored retirement plans, such as 401(k) plans. The Adviser can review the investment options in such a retirement plan and recommend an asset allocation, based upon a client’s investment objective. As part of this agreement, the Adviser periodically reviews a client’s retirement portfolio. With regard to retirement plans that are subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the Adviser generally assumes the role of a fiduciary with respect to such ERISA plans. Additionally, the Responsible Plan Fiduciary for ERISA plans will be provided with an ERISA Fee and Services Disclosure pursuant to Section 408(b)(2) of ERISA, prior to the ERISA Plan engaging the Adviser for advisory services. Financial Planning Agreement A financial planning analysis may include but is not limited to: net worth statement; cash flow statement; review of investment accounts, asset allocation analysis; strategic tax planning; review of retirement accounts; review of insurance policies, evaluation of retirement goals; estate planning review; and college education planning. Financial planning may be the only service provided to the client and it does not require the client to use or purchase the investment advisory services offered by the Adviser. The Adviser may receive compensation for financial planning and providing investment consulting services. The Adviser does not make any representation regarding products that may be referenced in a financial plan and the client is under no obligation to accept the recommendations of the Adviser or use the services of the Adviser in particular. Asset Management Investments may also include equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities and mutual funds shares, exchange-traded fund shares (ETFs), U. S. government securities, options contracts, futures contracts, and interests in partnerships. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. The Adviser does not receive any compensation, in any form, from fund companies. From time to time the Adviser may recommend public offerings (IPOs) if deemed suitable. WRAP Program The Adviser does not sponsor a WRAP fee program. Termination of Agreement 6  A client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro-rata for services provided through to the date of termination. If the client made an advance payment, the Adviser would refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded. Item 5-Fees and Compensation Investment Management The Adviser bases its fees on a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. At termination, fees will be billed on a pro-rata basis for the portion of the quarter completed. The portfolio value at the completion of the prior full billing quarter is used as the basis for the fee computation, adjusted for the number of days during the billing quarter prior to termination. The investment management fees are negotiable at the sole discretion of the Adviser. Annualized Investment Management Fees Account Value From Account Value To Percentage Annual Fee $0 $499,999 1.50% $500,000 $1,000,000 1.25% $1,000,001 $4,000,000 1.00% $4,000,001 $10,000,000 0.75% Over $10,000,000 0.60% Financial Planning Financial Plan The Adviser will review the client’s financial situation and prepare a written financial plan that includes recommendations to help the client meet his or her financial goals. The areas of analysis may include goal setting, analysis of financial goals, asset/liability analysis, tax planning, cash flow budgeting, investment review, insurance review, inventory of assets, investment portfolio analysis, retirement planning, college planning, savings, and estate plan review. 7  The Adviser will compile the necessary financial information and use it to construct a Financial Plan tailored to the client’s specific financial situation. The written financial plan will typically be constructed within three months but may take longer than six months depending on the complexity of a client’s financial situation. Clients can implement recommendations contained in the Financial Plan on their own or have the Adviser assist with implementation. Financial Review A Financial Review addresses up to two financial planning topics selected in advance by the client. No follow-up services are provided with the Financial Review. For Financial Plans and Financial Reviews, The Adviser charges a fixed fee. Financial planning fees may be waived at the discretion of the Adviser for Investment Management clients. Financial Planning Service Fee Type and Amount Financial Plan $2,500 to $5,000 fixed fee Financial Review $1,000 fixed fee The Adviser may negotiate its fixed fee amount for Financial Plans based on complexity of the financial plan. The final fee amount will be specified in the Financial Planning Agreement which details the scope of the relationship and responsibilities of both the Adviser and client. Advice and services provided under the Financial Planning Agreement are tailored to the stated objectives of the client. One-half of the estimated fee stated in the Financial Planning Agreement is due at signing. The balance shall be due and payable upon completion of the agreed upon services. If a client chooses to terminate within five (5) business days from the date of execution or at any time via written notice before the product is delivered or service is complete, The Adviser will charge a prorated amount for the work completed and will deliver any work product completed. The fee for a Financial Review is due at the beginning of the Review appointment. Notwithstanding the above, all fees are negotiable and certain clients may be charged less, depending on a number of factors, including portfolio size, employment and relationship to the Adviser. Project Retainer Project Retainer services are narrower in scope. The services include various client consultations as well as written and/or oral recommendations resulting from such consultations. The Project Retainer does not constitute a comprehensive financial planning engagement and follow-up advice and/or implementation assistance is not provided following completion of the project. If a client wishes to upgrade to a Financial Plan, they may receive credit toward the Financial Plan fee for amounts paid under the Project Retainer for the prior six months. The Adviser charges non-investment management clients on an hourly basis for services such as portfolio asset allocation consulting and financial planning. Such fees are $250/hour and are negotiable. In the event that a client’s situation is substantially different than disclosed at the initial meeting, a revised fee will be provided for mutual agreement. The client must approve the change of scope in advance of the additional work being performed when a fee increase is necessary. 8  Investment Consulting Services Fee. The Adviser may charge a client an annual fee to consult on assets held in employee-sponsored retirement plans. The annual fee is 0.25% of the balance of a client’s retirement plan, with a minimum fee of $500.00. Fee Billing Investment management fees are billed quarterly and in advance. Fees are deducted from the client account to facilitate billing as authorized by the investment advisory agreement. Fees for Advisory Services are based on the account’s asset value as of the last business day of the prior calendar quarter. Fees for a Financial Plan are billed based on half the agreed upon fee upon signing the Financial Planning Agreement with the balance due upon delivery of the financial plan. For billing purposes, accounts may be grouped by households. The definition of household for billing purposes is relation by blood or marriage, family members living under the same roof and/or hierarchy (grandparents, parents, children, grandchildren). Item 6-Performance Fees Performance Fees We do not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) for discretionary Investment Management clients. Trinity Legacy Dynamic Options Fund I, LP charges an incentive fee of 20% as stated in the PPM which is delivered to qualified clients investing in the Fund. Item 7-Types of Clients Description The Adviser generally provides investment advice to individuals and trusts, estates, corporations, or charitable organizations. Account Minimums The Adviser does not require a minimum account size. Item 8-Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. 9  Investment Strategies Strategies may include long-term purchases, short-term purchases, trading, short sales, margin transactions, and option writing (including covered options, uncovered options or spreading strategies). Within these investment strategies, we may invest in a wide range of securities and other financial instruments including: • Equity securities • Exchange-listed securities • Over-the-counter securities • Securities of foreign issuers (including ADRs, EDRs and GDRs) • Warrants • Rights • Restricted shares • Options contracts • Futures • Corporate debt • Commercial paper • Certificates of deposit • United States government securities • Municipal securities • Mutual funds • Options on futures contracts • Listed and over the counter derivatives • Mortgage related and other asset backed securities • Bank loans • Private placements As financial markets and products evolve, we may invest in other instruments or securities when consistent with client guidelines, objectives and policies. Portfolios are diversified to control the risk associated with traditional markets. The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. Each client executes an Investment Objective Statement that documents their investment objectives, risk tolerance, and their desired investment horizon. Some of the Adviser’s investment strategies may involve frequent trading. As a result, these strategies may incur higher transaction costs which are costs assessed to client/investor portfolios. These costs may commensurately reduce portfolio returns relative to a strategy that requires a lower level of trading. Market, Regulatory and Security Specific Risks 10  Any investment with the Adviser involves significant risk, including a complete loss of capital and conflicts of interest. All investment programs have certain risks that are borne by the investor which are described below: Market Risks: Competition: The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Market Volatility: The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements. Trinity Legacy Partners, LLC’s Investment Activities: The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits. Material Non-Public Information: By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Accuracy of Public Information: The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it is considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities: The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed. Small Companies: The Adviser may invest a portion of its assets in small and/or unseasoned companies with small market capitalization. While smaller companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification and competitive strength of larger companies. In addition, in many instances, the frequency and volume of their trading may be 11  substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations. Leverage: When deemed appropriate by the Adviser and subject to applicable regulations, the Adviser may incur leverage in its investment program, whether directly through the use of borrowed funds, or indirectly through investment in certain types of financial instruments with inherent leverage, such as puts, calls and warrants, which may be purchased for a fraction of the price of the underlying securities while giving the purchaser the full benefit of movement in the market of those underlying securities. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. Market or Interest Rate Risk: The price of most fixed income securities moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser. Inflation Risk: Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. Risk of Default or Bankruptcy of Third Parties: The Adviser may engage in transactions in securities, commodities, other financial instruments and other assets that involve counterparties. Under certain conditions, the Adviser could suffer losses if a counterparty to a transaction were to default or if the market for certain securities, commodities, other financial instruments and/or other assets were to become illiquid. Regulatory Risks: Strategy Restrictions: Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisers, counsel, and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate. Trading Limitations: For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses. Conflicts of Interest: In the administration of client accounts, portfolios, and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons. Supervision of Trading Operations: The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to 12  ensure compliance with firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients will be exposed to risks that are specific to the securities in their particular investment portfolio. Security Specific Risks: Liquidity: Liquidity is the ability to readily convert an investment into cash. Securities, where there is a ready market that is traded through an exchange, are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in the price level in a liquidation situation. Currency: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Lack of Registration: Funds or LP interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions. Item 9-Legal and Disciplinary Legal and Disciplinary The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Item 10-Other Financial Industry Activities and Affiliations Affiliations Trinity Legacy Dynamic Options Fund I, LP is a Delaware limited partnership (the “Fund” or “Partnership”). Trinity Legacy Alternative Strategies, LLC, a Delaware limited liability company (the “GP”), serves as the General Partner of the Partnership and investment manager of the Fund. The GP is a wholly owned subsidiary of Trinity Legacy Partners, LLC (“the Adviser”). The Fund seeks to provide an alternative investment strategy (the “Strategy”) that provides potential for capital appreciation while exhibiting low correlation to the S&P 500 Index (“SPX”). Units will be offered and sold only to “accredited investors,” as defined in Regulation D promulgated under the Securities Act, and to “qualified clients,” as defined under the Investment Advisers Act of 1940. The Partnership will obtain appropriate representations and undertakings from the investors to ensure that the conditions of the applicable exemptions are met. Performance based fee arrangements may create an incentive for investments to be recommended that may be riskier or more speculative than those which would be recommended under a different (flat) fee arrangement. Such fee arrangements also create an incentive to favor higher fee paying accounts over other accounts in the allocation of investment opportunities. We have 13  procedures designed and implemented to ensure that all clients are treated fairly and equally, and to prevent this conflict from influencing the allocation of investment opportunities among clients. Investment Management clients may also be investors in the Fund. Item 11-Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Code of Ethics The Adviser has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Adviser’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the Adviser’s Compliance Officer. Each supervised person of the Adviser receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of the Adviser’s Code of Ethics, free of charge, by contacting the Compliance Officer of the Adviser. Participation or Interest in Client Transactions Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price, or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer of the Adviser is John P. Wilkinson, III. He reviews all employee trades each quarter (except for his own trading activity that is reviewed by another principal or officer of the Firm). The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the firm receive preferential treatment. 14  Item 12-Brokerage Practices Brokerage and Custodian Selection The Adviser has the authority over the selection of the broker to be used and the commission rates to be paid without obtaining specific client consent. The Adviser may recommend brokerage firms as qualified custodians and for trade execution. We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), a FINRA-registered broker-dealer, member SIPC, as the qualified custodian. We are independently owned and operated and not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we/you instruct them to. While we recommend that you use Schwab as a custodian/broker, you will decide whether to do so and open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you. How we select Brokers and Custodians We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, these: • combination of transaction execution services along with asset custody services (generally without a separate fee for custody) capability to execute, clear and settle trades (buy and sell securities for your account) • • capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • the breadth of investment products made available (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.) • availability of investment research and tools that assist us in making investment decisions quality of services • • competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them reputation, financial strength, and stability of the provider • their prior service to us and our other clients • • availability of other products and services that benefit us, as discussed below (see “Products and Services Available to Us from Schwab”) Your Brokerage and Custody Costs For your accounts that Charles Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by revenue earned on certain trades that it executes or that settle into your Schwab account. Most trades (for example, purchases or sells of stocks, mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Schwab 15  is also compensated by earning interest on the uninvested cash in your account in Schwab's Cash Features Program. Your accounts at Schwab benefit because the overall costs you pay are lower than they would be otherwise. We have determined that having Schwab execute most trades is consistent with our duty to seek the "best execution" of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors. Products and Services Available to Us from Schwab Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we do not have to request them) and at no charge to us as long as we keep our clients’ assets in accounts at Schwab. Here is a more detailed description of Schwab’s support services: Services that Benefit You. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit You Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; • • provide pricing and other market data; facilitate payment of our fees from our clients’ accounts; and • • assist with back-office functions, recordkeeping, and client reporting. Services that Generally Benefit Only Us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • educational conferences and events technology, compliance, legal, and business consulting; • 16  • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants, and insurance providers. Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. Our Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We do not have to pay for Schwab’s services so long as we keep client assets in accounts at Schwab. This may give us an incentive to recommend that you maintain your account with Schwab based on our interest in receiving Schwab’s services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. It is primarily supported by the scope, quality and price of Schwab’s services (based on the factors discussed above – see “How We Select Brokers/Custodians”) and not Schwab’s services that benefit only us. Benefits Received from Schwab Schwab will provide the following: i) services to support the transition and opening of accounts to and from Trinity Legacy Partners, LLC, and ii) technology, marketing, research, and compliance-related expenses. The Adviser has no obligation to deal with any broker or group of brokers in executing transactions in portfolio securities. Allocation of Orders It is the policy of the Adviser to allocate the securities recommended to its customers in a manner in which the Adviser believes to be in the best interests of its clients. If the Adviser has determined to invest in the same direction in the same security at the same time for more than one of its investment accounts, the Adviser will generally place orders for all such accounts simultaneously. If all such orders are not filled at the same price, the Adviser will, to the greatest extent possible, allocate the trades such that the order for each account is filled at the same average price. Similarly, if an order on behalf of more than one account cannot be fully executed under prevailing market conditions, the Adviser will allocate the trades among the different accounts on a basis that it considers equitable. Additionally, it is a general policy of the Adviser that the manager responsible for the respective transaction will make a preliminary allocation before execution, and as a general policy, the allocation will be finalized no later than the close of business on trade day. “Block Trading” of Orders In general, the Adviser will attempt to aggregate multiple orders for the purchase or sale of the same security into block transactions, subject to the overall obligation to achieve best price and 17  execution for the Client Accounts. There is no obligation to include any Client Account in a block trade order unless the portfolio manager believes it is in the Client Account’s best interest. In making this determination, the portfolio manager may consider a number of factors, including, but not limited to: Client Account’s investment objectives and policies, investment guidelines, liquidity requirements, legal or regulatory restrictions, tax considerations, and the nature and size of the block trade order. Completely Filled Orders Where a block trade is completely filled, each participating Client Account will receive the average share/security price for the block trade order on the same day and transaction costs shall be shared among participating Client Accounts pro rata based on the level of participation in the block trade. An order will be deemed to be “filled in its entirety” even if it takes more than a single day to complete the entire transaction, so long as there is a reasonable expectation that the order will be filled within a reasonable period. In such cases, the portion of the order completed each day, ordinarily will be allocated in accordance with the preliminary allocation schedule. Partially Filled Orders Where a block trade is only partially filled (i.e., the total amount of securities purchased is less than the amount requested in the block order), the securities should be allocated on a pro rata basis to each participating Client Account based on the initial amount requested and at the average price for the block trade order. Target Weighting When the portion of a partially filled order that may be allocated to a participating account is such that after the allocation, the account’s holdings of the security would fall below the account’s target weighting, as described below, the account will not be allocated any portion of the order. In the event that allocation of a partially filled order would cause holdings for all participating accounts to fall below target weighting, the entire order may be allocated to a single account. The account which receives such an allocation, will be rotated so as to achieve equity in distribution over time. De Minimis Allocations If a given Client Account would be allocated less than a pre-determined dollar amount (e.g., $1,000) for a fixed-income transaction or a pre-determined number of shares for an equity transaction (e.g., 100 shares), the portfolio manager or trader may determine to allocate no securities to that Client Account. Directed Brokerage In the event that a client directs the Adviser to use a particular broker or dealer, the Adviser may not be authorized under those circumstances to negotiate commissions and may not be able to obtain volume discounts or best execution. 18  Non – Charles Schwab Accounts The Adviser uses a third-party platform to facilitate management of assets such as brokerage accounts and defined contribution plan participant accounts, with discretion. The platform allows the Adviser to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. The Adviser is not affiliated with the platform and do not receive compensation for using the platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, the Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Item 13-Review of Accounts Periodic Reviews Account reviews are performed quarterly by the Investment Review Committee. It is instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Review Triggers Accounts are reviewed quarterly or more frequently when market conditions dictate. Other conditions that may trigger a review are changes in economic conditions and financial markets, new investment information, and changes in a client’s financial or personal situation. Regular Reports Clients receive periodic reports on at least an annual basis. The written reports may include account valuation, performance stated in dollars and as a percent, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Clients receive statements of account positions no less than quarterly from the account custodian. Item 14-Client Referrals and Other Compensation Incoming Client Referrals The Adviser has entered into a referral arrangement with My Financial Coach. The Adviser will pay My Financial Coach a referral fee of twenty five percent (25%) of the advisory fee received for investment management compensation exclusively pertaining to referrals from My Financial Coach. 19  Item 15-Custody Custody Policy The Adviser does not accept or permit the Firm or its associated persons from obtaining custody of client assets including cash, securities, acting as a trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian. The Adviser is deemed to have custody of the funds and securities as a consequence of its authority to make withdrawals from client accounts to pay its advisory fee. However, a surprise examination is not required because the Adviser has written authorization from each client to deduct advisory fees from the account held with the qualified custodian and each time a fee is directly deducted from a client account, the Adviser sends the qualified custodian an invoice or statement of the amount of the fee to be deducted from the client’s account. Account Statements All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. Pursuant to recent amendments to Rule 206(4) under the Investment Advisers Act of 1940, the Securities and Exchange Commission now requires advisers to urge clients to compare the information set forth in their statement from the Adviser with the statements received directly from the custodian to ensure accuracy of all account transactions. Item 16-Investment Discretion Discretionary Authority for Trading The Adviser contracts for discretionary authority to transact portfolio securities accounts on behalf of clients. Discretionary authority is granted by the Adviser’s investment advisory agreement. The Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The firm's discretionary authority regarding investments may, however, be subject to certain limitations. These limitations are recognized as the restrictions and prohibitions placed by the Client on transactions in certain types of businesses or industries. All such restrictions are to be agreed upon in writing at the account's inception. The Adviser will consult with the client where discretion is not obtained prior to each trade in order to obtain client approval for the transaction(s). The client authorizes the discretion to select the custodian to be used. The Adviser does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. 20  Item 17-Voting Client Securities Proxy Voting The Adviser does not have any authority and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients receive their proxies directly from the custodian of their account or from a transfer agent. Please contact your custodian or transfer agent with any questions. Item 18-Financial Information Financial Condition The Adviser does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. The Adviser meets all net capital requirements that it is subject to, and the Adviser has never been the subject of a bankruptcy petition. The Adviser is not required to provide a balance sheet as it does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. Item 19 Other Disclosures Relationship with Issuer of Securities Disclosure The Adviser does not at this time have a relationship or arrangement with any issuer of securities. Business Continuity Plan The Adviser has a Business Continuity Plan in place that provides detailed steps to mitigate and recover from the loss of office space, communications, services or key people. Disaster Recovery The Business Continuity Plan covers natural disasters such as snowstorms, hurricanes, tornados, and flooding. The Plan covers man-made disasters such as loss of electrical power, loss of water pressure, fire, bomb threat, nuclear emergency, chemical event, biological event, T-1 communication line outages, Internet outage, railway accident, and aircraft accident. Electronic files are backed up daily and archived offsite. Summary of Business Continuity Plan A summary of the business continuity plan is available upon request to the Adviser’s Chief Compliance Officer. Information Security Program The Adviser maintains an information security program to reduce the risk that clients’ personal and confidential information may be breached. 21  Privacy Practices Privacy Policy Below is a summary of the Adviser’s Privacy Policy regarding client personal information. A complete version of the Privacy Policy is contained in the Client Investment Advisory Agreement and may be obtained by contacting the Compliance Officer of the Adviser. The Adviser: a) Collects non-public personal information about its clients from the following sources: Information received from clients on applications or other forms; • • Information about clients’ transactions with the Adviser, its affiliates and others; • Information received from our correspondent clearing broker with respect to client accounts; Information received from service bureaus or other third parties. • b) The Adviser will not share such information with any affiliated or nonaffiliated third party except: • When necessary to complete a transaction in a customer account, such as with the clearing firm or account custodians; • When required to maintain or service a customer account; • To resolve customer disputes or inquiries; • With persons acting in a fiduciary or representative capacity on behalf of the customer; • With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants, and auditors of the firm; • To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability; • To comply with federal, state or local laws, rules and other applicable legal requirements; • In connection with a written agreement to provide investment management or advisory services when the information is released for the sole purpose of providing the products or services covered by the agreement; In any circumstances with the customer’s instruction or consent. • c) Restricts access to confidential client information to individuals who are authorized to have access to confidential client information and need to know that information to provide services to clients. d) Maintains physical, electronic and procedural security measures that comply with applicable state and federal regulations to safeguard confidential client information. 22