1900 Wealth Management LLC dba 1900 Wealth, previously known as Monticello Wealth Management, LLC, (“1900 Wealth or Adviser”) offers a variety of advisory services, which include financial planning, consulting, and investment management services. 1900 Wealth also provides investment management, advisory, administrative, and other services with respect to an affiliated pooled investment vehicle. Prior to 1900 Wealth rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with 1900 Wealth setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). 1900 Wealth has been registered as an investment adviser since 2015 and is owned by Jefferson Bank. While this brochure generally describes the business of 1900 Wealth, certain sections also discuss the activities of its Supervised Persons, which refer to 1900 Wealth’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on 1900 Wealth’s behalf and is subject to 1900 Wealth’s supervision or control. 1900 Wealth is a fiduciary and is required to act in a client’s best interest at all times. Financial Planning and Consulting Services 1900 Wealth offers clients a broad range of financial planning and consulting services, which may include any or all of the following functions:
• Cash Flow Forecasting
• Trust and Estate Planning
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning Typically, these services are only rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described below in more detail). Certain arrangements will result in a separate consulting agreement or engagement letter for a fee. In performing these services, 1900 Wealth is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. 1900 Wealth may recommend clients engage 1900 Wealth for additional related services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage 1900 Wealth or its affiliates to provide additional services for compensation. Clients are advised that it remains their responsibility to promptly notify the 1900 Wealth of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising 1900 Wealth’s recommendations and/or services. Wealth Management Services 1900 Wealth provides clients with wealth management services which generally includes a broad range of comprehensive financial planning and consulting services as well as discretionary and non-discretionary management of investment portfolios. 1900 Wealth primarily allocates client assets among various mutual and exchange-traded funds in accordance with their stated investment objectives. Where appropriate, 1900 Wealth may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage 1900 Wealth to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, 1900 Wealth directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider. 1900 Wealth tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. 1900 Wealth consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify 1900 Wealth if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if 1900 Wealth determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the 1900 Wealth’s management efforts. Clients may wish to transfer into their managed account certain assets held elsewhere and continue to hold these assets without 1900 Wealth charging a fee or providing advice on these assets. These assets are considered “unmanaged” assets and will only be traded when 1900 Wealth receives specific trading instructions from the client to do so. The Client will receive confirmations and statements showing all trading activity in the account(s). Affiliated Pooled Investment Vehicles The Firm and certain of its affiliates establish and utilize the Funds (as defined below) for investment purposes on behalf of its clients and other persons, including to facilitate indirect investments by one or more of its advisory clients in pooled investment vehicles and other persons. The Firm regularly recommends that certain of its advisory clients invest in the Fund(s), if and to the extent the Firm deems investments in one or more of the Funds to be suitable and appropriate for such clients (as determined by the Firm in its discretion). The recommendation of investments in the Funds to the Firm’s advisory clients involves one or more actual or potential conflicts of interest. The Firm provides investment management, advisory, administrative, and other services to affiliated pooled investment vehicles (the “Funds”) with respect to investments in securities, financial instruments and other assets, including co-investments alongside third-party investment managers and other persons and/or investments in pooled investment vehicles managed, sponsored and operated by third-party investment managers. An affiliate of the Firm serves or acts as general partner, manager or in similar capacity with respect to the Funds and the Firm serves as investment manager with respect to the Funds. Interests in the Fund(s) typically will be offered and made available primarily to applicable advisory clients of the Firm (subject to suitability and eligibility determinations and requirements), but interests in the Funds may also be offered or made available to other persons and entities (including non-advisory clients) in the sole discretion of the Firm. Interests in the Funds are privately offered only to eligible clients and other investors pursuant to exemptions under the Securities Act of 1933, as amended, and the regulations promulgated thereunder, and other applicable securities laws. Such Funds are not registered as investment companies pursuant to or in accordance with one or more specific exclusions from the definition of investment company under the Investment Company Act of 1940, as amended. The Firm recommends investments in the Funds to certain of its advisory clients and such clients may elect to subscribe for interests in the Funds. The Firm faces various conflicts of interest in connection with making such recommendations to clients. As a matter of practice, fund offering documents

with respect to each Fund typically will be provided or made available to prospective investors in such Fund, which generally includes various disclosures and information regarding the Fund, the investment objective and strategies of such Fund and other matters. Prospective investors should review the information and disclosures set forth in the applicable offering documents of a Fund for detailed information regarding such Fund, and any disclosures or information set forth in this brochure with respect to such Fund are qualified in their entirety by the information in such offering documents. Each Fund is managed in accordance with the investment objectives, policies, strategies, guidelines and limitations set forth in the applicable subscription documents, limited partnership agreement and other governing documents of such Fund. Investors generally are not permitted to impose restrictions or limitations on the management or operations of the Fund(s). Notwithstanding the foregoing, the Manager of a Fund may in the future enter into side letter agreements or similar arrangements with one or more investors in a Fund that have the effect of establishing rights under, or altering, modifying, waiving, or supplementing the terms of, the governing documents of the Fund in respect of such investors. Among other things, these agreements may entitle an investor in a Fund to lower fees, information or transparency rights, most favored nations status, notification rights, rights, or terms necessary or advisable in light of particular legal, regulatory or public policy considerations of or related to an investor and/or other preferential rights and terms. Any rights established or any terms of the governing documents of such applicable Fund altered or supplemented in or by a side letter or similar arrangement with an investor will govern solely with respect to such investor notwithstanding any other provision of the governing documents of such applicable Fund related thereto. Sub-Advisory Services We currently use various providers as sub-advisers (“Sub-Advisers”) to provide us with access to customized managed investment portfolio options that we can make available to our clients. Our clients work directly with us to gather information about their financial situations, goals, and objectives, including information on their investment time horizon, risk tolerance, and other relevant information and factors. Based on this information, Sub-Advisers will propose an overall strategy that includes investment portfolio recommendations in the form of one or more customized investment portfolios managed by Sub-Advisers. Our representatives will periodically meet with their clients to discuss any changes to their financial situations, goals, and objectives to ensure that the factors upon which recommendations are based continue to remain appropriate and in their best interests. Sub-Advisers personnel do not possess knowledge of third-party advisory firm’s clients’ individual information or investment goals or objectives to allow it to provide personalized investment advice to such clients. We are responsible for determining appropriate portfolio strategies and, to the extent required, delivering the Sub-Advisers’ Form ADV to clients with assets under management by Sub-Adviser, and the Sub-Advisers’ Privacy Policies. Any modifications to the portfolios managed by Sub-Advisers are affected through the sale of securities in client accounts, which may have tax ramifications to clients. The Sub-Advisers’ Form ADV provides our clients with a general overview of Sub-Advisers’ services and responsibilities. Clients can obtain more specific information about the process by which portfolios are constructed, how investment strategies are carried out, options to customize investments, investment returns, and other information by discussing with our representatives. We encourage all clients to review the material provided in the Sub-Advisers’ Form ADV and other disclosures provided and discuss any questions related to services offered with their representative to make certain they fully understand the Sub-Advisers’ investment process. We offer an automated investment program (“iDirect”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds (“ETFs”) and a cash allocation. The client may instruct us to exclude up to three ETFs from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“Schwab Corporation ”). We use the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of Schwab Corporation., to operate iDirect. We are independent of and not owned by, affiliated with, sponsored, or supervised by SPT, Schwab Corporation., or their affiliates (together, “Schwab”). We are the client’s investment advisor and primary point of contact with respect to iDirect. We are solely responsible for determining the appropriateness of iDirect for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology, related trading and account management services for iDirect. The Platform enables us to make iDirect available to clients online and includes a system that automates certain key parts of our investment process (“System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that we recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is more conservative or aggressive than the recommended portfolio. We, however, make the final decision and select a portfolio based on all the available information about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We charge clients a fee for our services as described below under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to Schwab Corporation as part of iDirect. Schwab does receive other revenues, including (i) the profit earned by Charles Schwab Bank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFsTM Schwab Funds® and Laudis Funds® that we select to buy and hold in the client’s brokerage account; (iii) fees received by Schwab from third-party ETFs that participate in the Schwab ETF OneSourceTM program and mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv) remuneration Schwab may receive from the market centers where it routes ETF trade orders for execution. As of December 31, 2023, 1900 Wealth has a total of $1,977,741,346 of assets under management. We do not have or participate in a wrap program.