Overview

Assets Under Management: $3.1 billion
Headquarters: SUMMIT, NJ
High-Net-Worth Clients: 151
Average Client Assets: $19 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients

Fee Structure

Primary Fee Schedule (JOURNEY STRATEGIC WEALTH, LLC DISCLOSURE BROCHURE & PRIVACY POLICY)

MinMaxMarginal Fee Rate
$0 and above 1.75%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $17,500 1.75%
$5 million $87,500 1.75%
$10 million $175,000 1.75%
$50 million $875,000 1.75%
$100 million $1,750,000 1.75%

Clients

Number of High-Net-Worth Clients: 151
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 95.04
Average High-Net-Worth Client Assets: $19 million
Total Client Accounts: 1,898
Discretionary Accounts: 1,888
Non-Discretionary Accounts: 10

Regulatory Filings

CRD Number: 310648
Last Filing Date: 2024-12-26 00:00:00
Website: https://journeysw.com

Form ADV Documents

Primary Brochure: JOURNEY STRATEGIC WEALTH, LLC DISCLOSURE BROCHURE & PRIVACY POLICY (2025-03-24)

View Document Text
Journey Strategic Wealth, LLC Form ADV Part 2A – Disclosure Brochure Effective: March 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Journey Strategic Wealth, LLC (“Journey” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (201) 834-9624. Journey is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Journey to assist you in determining whether to retain the Advisor. Additional information about Journey and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310648. Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Phone: (201) 834-9624| www.journeysw.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Journey. For convenience, the Advisor has combined these documents into a single disclosure document. Journey believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Journey encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes Since the last annual update of the Brochure in May 2024, there have been material changes to report in this Brochure. • • Journey Strategic Wealth has appointed a new Chief Compliance Officer, Amanda Coetzee. Journey has entered into an agreement with Advisor OS, LLC dba Taiko (“Taiko”): Taiko, a web-based technology platform vendor engaged to provide outsourced asset management services. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations, or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure online at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310648. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (201) 834-9624. Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 2 Phone: (201) 834-9624 | www.journeysw.com Item 3 – Table of Contents Item 1 – Cover Page ........................................................................................................................................................... 1 Item 2 – Material Changes ................................................................................................................................................. 2 Item 3 – Table of Contents ................................................................................................................................................. 3 Item 4 – Advisory Services ................................................................................................................................................ 4 A. Firm Information .......................................................................................................................................................................... 4 B. Advisory Services Offered .......................................................................................................................................................... 4 C. Client Account Management ...................................................................................................................................................... 5 D. Wrap Fee Programs .................................................................................................................................................................... 5 E. Assets Under Management ........................................................................................................................................................ 6 Item 5 – Fees and Compensation .................................................................................................................................... 6 A. Fees for Advisory Services ........................................................................................................................................................ 6 B. Fee Billing ..................................................................................................................................................................................... 6 C. Other Fees and Expenses.......................................................................................................................................................... 7 D. Advance Payment of Fees and Termination ............................................................................................................................ 7 E. Compensation for Sales of Securities ....................................................................................................................................... 8 Item 6 – Performance-Based Fees and Side-By-Side Management .......................................................................... 8 Item 7 – Types of Clients ................................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss ................................................................. 8 A. Methods of Analysis .................................................................................................................................................................... 8 B. Risk of Loss .................................................................................................................................................................................. 9 Item 9 – Disciplinary Information ................................................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................... 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ................... 11 A. Code of Ethics ........................................................................................................................................................................... 11 B. Personal Trading with Material Interest .................................................................................................................................. 11 C. Personal Trading in Same Securities as Clients .................................................................................................................... 11 D. Personal Trading at Same Time as Client .............................................................................................................................. 11 Item 12 – Brokerage Practices........................................................................................................................................ 11 A. Recommendation of Custodian[s] ........................................................................................................................................... 11 B. Aggregating and Allocating Trades ......................................................................................................................................... 12 Item 13 – Review of Accounts ........................................................................................................................................ 12 A. Frequency of Reviews .............................................................................................................................................................. 12 B. Causes for Reviews .................................................................................................................................................................. 13 C. Review Reports ......................................................................................................................................................................... 13 Item 14 – Client Referrals and Other Compensation ................................................................................................. 13 A. Compensation Received by Journey ...................................................................................................................................... 13 B. Compensation for Client Referrals .......................................................................................................................................... 13 Item 15 – Custody ............................................................................................................................................................. 13 Item 16 – Investment Discretion ..................................................................................................................................... 14 Item 17 – Voting Client Securities .................................................................................................................................. 14 Item 18 – Financial Information ...................................................................................................................................... 14 Privacy Policy ..................................................................................................................................................................... 15 Our Commitment to You ................................................................................................................................................................ 16 Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 3 Phone: (201) 834-9624 | www.journeysw.com Item 4 – Advisory Services A. Firm Information Journey Strategic Wealth, LLC (“Journey” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor was organized as a Limited Liability Company (“LLC”) under the laws of the State of Delaware in December 2020. Journey Strategic Wealth became a wholly- owned subsidiary of Journey Strategic Holdings, LLC in March 2021. Journey Strategic Holdings, LLC is primarily owned by Michael C. Brown (Managing Partner, Financial Advisor), Brian R. Flynn (Managing Partner & Financial Advisor), Penny A. Phillips (Co-Founder & President), Charles F. Britton, and Echelon Journey Management LLC who are also principal officers of the Advisor. Amanda Coetzee has been appointed as the new Chief Compliance Officer. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Journey. For information regarding Journey or this Disclosure Brochure, please contact Penny Phillips at (201) 834-9624. B. Advisory Services Offered Journey offers wealth management services to individuals, high net worth individuals, families, trusts, and estates (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate potential conflicts of interest. Journey's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Journey provides Clients with wealth management services, which generally include a broad range of comprehensive financial planning and consulting services in connection with discretionary management of investment portfolios. These services are described below. Investment Management Services – Journey provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Journey works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Journey will then construct an investment portfolio consisting of exchange-traded funds (“ETFs”), open-end mutual funds, individual stocks, individual bonds, and closed-end mutual funds. The Advisor may also utilize covered options, limited partnerships, and/or other types in investments, as appropriate, to meet the needs of the Client. The Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations. Journey’s investment strategies are primarily long-term focused, but the Advisor may buy, sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Journey will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Journey evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Journey may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Journey may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Journey may recommend selling positions for reasons that include but are not limited to harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, changes in the risk tolerance of the Client, generating cash to meet Clients’ needs, or any risk deemed unacceptable for the Client’s risk tolerance. Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 4 Phone: (201) 834-9624 | www.journeysw.com Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor earns a new (or increases its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will Journey accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services – Journey will typically provide a variety of financial planning and consulting services to Clients. Services may be offered as part of an overall wealth management engagement or provided as a separate engagement and fee pursuant to a written financial planning and consulting agreement. Financial plan services may also be perpetual and a fixed scope project, based on the needs of the Client. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to investment planning, retirement planning, personal savings, education savings, insurance needs, and/or other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings, and/or charitable giving programs. Journey may also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of the contract date, assuming all information and documents requested are provided promptly. “Advisor OS, LLC dba Taiko (“Taiko”): Taiko is a web-based technology platform offered by Advisor OS that utilizes Orion Advisor Technology (“Orion”) portfolio management software to provide clients with access to performance reporting, a mobile client portal, trading execution, third-party managers, data reconciliation, tax reporting, and other services. Taiko’s services will be administered as an outsource agent with the Custodians. The platform fee for Taiko ranges from 0.05% - 0.10% annually per applicable account based on the complexity of the services performed and/or the overall relationship with the Advisor. Third party money manager fees, including Taiko strategies, vary by strategy type and will be billed in conjunction with Taiko’s fee. Fees are billed quarterly in arrears based on the average daily balance of account(s) during the previous quarter. C. Client Account Management Prior to engaging Journey to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Journey, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Journey will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client. • Portfolio Construction – Journey will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 5 Phone: (201) 834-9624 | www.journeysw.com • Investment Management and Supervision – Journey will provide investment management and ongoing oversight of the Client’s investment portfolio. • Ongoing Financial Planning – As applicable, Journey will monitor the financial plan of the Client to assist with defining and achieving goals. Planning may be perpetual or project-based. D. Wrap Fee Programs Journey does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Journey. E. Assets Under Management As of December 31, 2024, Journey manages $3,764,311,936, of which $3,753,655,801 is managed on a discretionary basis and $10,656,135 is managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one more written agreements with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid quarterly, in advance of each calendar quarter pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior quarter. Wealth management fees are generally tiered and blended and range from 0.30% to 1.75% annually based on the complexity of the services performed, the level of assets to be managed, and/or the overall relationship with the Advisor. The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. Fees may be negotiable at the sole discretion of the Advisor. All securities held in accounts managed by Journey will be independently valued by the Custodian. Journey will conduct periodic reviews of the Custodian’s valuations. Clients may make additions to and withdrawals from their account[s] at any time, subject to Journey’s right to terminate an account. Additions may be in cash or securities provided that Journey reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw account assets on notice to Journey, subject to the usual and customary securities settlement procedures. However, Journey designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client’s investment objectives. Journey may consult with its Clients about the options and ramifications of transferring securities. However, Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge), and/or tax ramifications. The Advisor’s fee is not adjusted for contributions or withdrawals, except for such cash flows that exceed $25,000 during a billing period. In such instances, adjustments will be made during the next billing period. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C. below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning Services Journey offers standalone financial planning services with the fee for an initial financial plan ranging up to $10,000, based on the scope and complexity of the Client’s situation. Ongoing financial planning fees are billed a quarterly fee of up to $1,000. Journey may engage for targeted planning engagements at a rate of up to $500 per hour. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging in these services. Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 6 Phone: (201) 834-9624 | www.journeysw.com Third Part Money Managers Third party money manager fees, including Taiko strategies, vary by strategy type and will be billed in conjunction with Taiko’s fee. Fees are billed quarterly in arrears based on the average daily balance of account(s) during the previous quarter. B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Journey at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting the deduction of the wealth management fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Journey to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Financial Planning Services Initial financial planning fees may be invoiced up to 100 percent (100%) of the expected total fee upon execution of the financial planning agreement. The balance, if applicable, shall be invoiced upon completion of the agreed-upon deliverable[s]. The Advisor typically completes initial financial plans within 90 days. The Advisor will not collect an advance fee (deposit) of $1,200 or more if the initial plan will take six months or more to complete. In such instances, fees will be billed at planning milestones agreed to by the Client and the Advisor. Fees for ongoing financial planning engagements are invoiced in advance of each calendar quarter and due upon receipt. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties other than Journey in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Journey are separate and distinct from these custody and execution fees. In addition, all fees paid to Journey for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Journey, but would not receive the services provided by Journey, which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Journey to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services Journey is compensated for its wealth management services in advance of the quarter in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the quarter. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 7 Phone: (201) 834-9624 | www.journeysw.com Financial Planning Services Journey requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate, or in the case of a fixed project fee engagement, the percentage of the engagement scope completed by the Advisor. Ongoing financial planning engagements are based on the number of days in the quarter, up to and including the effective date of termination. Upon termination, the Advisor will promptly refund any unearned, prepaid planning fees to the Client. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Journey does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account other than the investment advisory fees noted above. Broker-Dealer Affiliations Certain Advisory Persons are also Registered Representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is a registered broker-dealer (CRD# 35747), member FINRA, SIPC. In one’s separate capacity as a Registered Representative of PKS, the Advisory Person will implement securities transactions under PKS and not through Journey. In such instances, the Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by the Advisory Person in one’s capacity as a Registered Representative is separate and in addition to the Advisor’s fees. This practice presents a conflict of interest because the Advisory Person, who is a Registered Representative, has an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on the Client. Clients are not obligated to implement any recommendation provided by the Advisor or its Advisory Persons. Neither the Advisor nor Advisory Persons will earn ongoing investment advisory fees in connection with any products or services implemented in the Advisory Person’s separate capacity as a Registered Representative. Please see Item 10 – Other Financial Industry Activities and Affiliations. Insurance Industry Affiliations Certain Advisory Persons are also licensed independent insurance professionals. As an independent insurance professional, an Advisory Person will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by Advisory Persons are separate and in addition to Journey’s advisory fees. This practice presents a conflict of interest because the person providing investment advice on behalf of the Advisor, who is an insurance agent, has an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on Clients’ needs. However, Clients are under no obligation, contractually or otherwise, to purchase insurance products through any Advisory Person affiliated with Journey. Please see Item 10 – Other Financial Industry Activities and Affiliations. Item 6 – Performance-Based Fees and Side-By-Side Management Journey does not charge performance-based fees for its investment advisory services. The fees charged by Journey are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Journey does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Journey offers investment advisory services to individuals, high net worth individuals, families, trusts, and estates. Journey generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 8 Phone: (201) 834-9624 | www.journeysw.com Journey employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Journey are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases, and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria generally consist of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Journey will be able to accurately predict such a reoccurrence. As noted above, Journey generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Journey will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Journey may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Journey will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals, or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 9 Phone: (201) 834-9624 | www.journeysw.com will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond ETFs Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e., the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Options contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call" pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Clients should only have a portion of their assets in these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information Securities laws require an advisor to disclose any instances where the Advisor or its Advisory Persons have been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. There are no events requiring disclosure regarding Journey or its management persons. You may independently view the background of the Advisor and its Advisory Persons on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the firm name or CRD# 310648. Item 10 – Other Financial Industry Activities and Affiliations Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 10 Phone: (201) 834-9624 | www.journeysw.com Broker-Dealer Affiliation As noted in Item 5, Advisory Persons are also Registered Representatives of PKS. In an Advisory Person’s separate capacity as a Registered Representative, the Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person. Neither the Advisor nor the Advisory Persons will earn ongoing investment advisory fees in connection with any services implemented in the Advisory Person’s separate capacity as a Registered Representative. Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from one’s role with Journey. As an insurance professional, an Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by an Advisory Person or the Advisor. Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics Journey has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Journey (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Journey and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of Journey’s Supervised Persons to adhere not only to the specific provisions of the Code but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (201) 834-9624. B. Personal Trading with Material Interest Journey allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Journey does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. Journey does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Journey allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls), gifts and entertainment, outside business activities, and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades or by trading based on material non-public information. This risk is mitigated by Journey requiring reporting of personal securities trades by its Supervised Persons for review of personal by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Journey allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will Journey, or any Supervised Person of Journey, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 11 Phone: (201) 834-9624 | www.journeysw.com Journey does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Journey to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, Journey does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Journey does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Journey. However, if the recommended Custodian is not engaged, the Advisor may be limited in the services it can provide. Journey may recommend the Custodian based on criteria such as but not limited to the reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. As certain Advisory Persons are also Registered Representatives of PKS, the Advisor may be limited in using other broker-dealers/custodians as PKS must approve the use of any outside broker-dealer/custodian. Journey will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial Services, LLC and Fidelity Brokerage Services, LLC, (collectively “Fidelity”) or at Schwab & co, LLC, INC, FINRA-registered broker-dealers and members of SIPC Fidelity, Schwab and Persing will serve as the Client’s “qualified custodians.” Journey has entered into an agreement with Pershing Advisor Solutions, INC., for the clients that have established accounts at Pershing. Journey maintains institutional relationships with Fidelity,Schwab and Pershing whereby the Advisor receives economic benefits. Please see Item 14 below.. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Journey does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals – Journey does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis,” where Journey will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Journey will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Journey will execute its transactions through the Custodian as authorized by the Client. Journey may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre- allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by the Investment Team. Formal Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 12 Phone: (201) 834-9624 | www.journeysw.com reviews are generally conducted at least annually or more frequently depending on the needs of the Client. Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 13 Phone: (201) 834-9624 | www.journeysw.com B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Journey if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic, or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Journey Participation in Institutional Advisor Platform As noted in Item 12, Journey has established an institutional relationship with Fidelity, Schwab and Persing ( “t h e C u s t o d i a n s ” ) to assist the Advisor in managing Client account[s]. As part of this arrangement, the Custodians also make available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by the Custodians directly from independent research companies. The Advisor may also receive additional services and support from the Custodians.As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity’s services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with the Custodians and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfied its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at the Custodians. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. B. Compensation for Client Referrals Journey does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody Journey does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian.” Clients are required to engage the Custodian to retain their funds and securities and direct Journey to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare them to any reports provided by Journey to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 14 Phone: (201) 834-9624 | www.journeysw.com Item 16 – Investment Discretion Journey generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Journey. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by Journey will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Journey does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies; however, the Client retains the sole responsibility for proxy decisions and voting. In some instances when using a third-party manager, the manager will vote the proxy instead of the client Item 18 – Financial Information Neither Journey nor its management has any adverse financial situations that would reasonably impair the ability of Journey to meet all obligations to its Clients. Neither Journey nor any of its Advisory Persons have been subject to a bankruptcy or financial compromise. Journey is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Journey Strategic Wealth, LLC 47 Maple Street, Suite 104, Summit, NJ 07901 Page 15 Phone: (201) 834-9624 | www.journeysw.com Privacy Policy Effective: March 29, 2023 Our Commitment to You Journey Strategic Wealth, LLC (“Journey” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Journey (also referred to as "we," "our," and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Journey does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address, and phone number[s] Income and expenses Email address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage, and advisory agreements Other advisory agreements and legal documents Account applications and forms Investment questionnaires and suitability documents Transactional information with us or others Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use, we maintain physical, procedural, and electronic security measures. These include such safeguards as secure passwords, encrypted file storage, and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Journey Strategic Wealth, LLC 47 Maple Street, Suite 104 Summit, NJ 07901 Journey Strategic Wealth, LLC 47 Maple Street, Suite 104 Summit, NJ 07901 Page 16 Phone: (201) 834-9624 | www.journeysw.com How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed-upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Yes Yes No Not Shared Journey shares Client information with Purshe Kaplan Sterling Investments, Inc. (“PKS”). This sharing is due to the oversight PKS has over certain Supervised Persons of the Advisor. You may also contact us at any time for a copy of the PKS Privacy Policy. Marketing Purposes Journey does not disclose and does not intend to disclose personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Journey or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Journey does not disclose and does not intend to disclose non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (201) 834-9624. Journey Strategic Wealth, LLC 47 Maple Street, Suite 104 Summit, NJ 07901 Page 17 Phone: (201) 834-9624 | www.journeysw.com