Investment Metrics, LLC doing business as Wellspring Financial Partners (Wellspring Financial Partners) is an investment adviser registered with the Securities and Exchange Commission and is a Limited Liability Company formed under the laws of the State of Arizona.
• Patrick J. Zumbusch is the President, Sole Shareholder and Managing Member of Investment Metrics, LLC doing business as Wellspring Financial Partners.
• Investment Metrics, LLC doing business as Wellspring Financial Partners initially became registered as an investment advisor in August 2011.
• We provide fee-only investment advisory services through Wellspring Financial Partners. The nature and extent of the specific services provided to clients, including you, will always depend on each client’s financial status, objectives and needs, time horizons, concerns, expectations and risk tolerance.
• More information about our investment advisor representatives’ business and education background can be found at the section titled Information Required by Part 2B of Form ADV: Brochure Supplement at the end of this brochure. General Description of Primary Advisory Services The following are brief descriptions of Wellspring Financial Partners’ primary services. Wellspring Financial Partners offers our clients discretionary investment management and non- discretionary investment consulting services. Our investment advisory services are primarily limited to the management of investment portfolios in accordance with the investment objective(s) of the client. We also offer financial planning, estate planning and investment/non-investment consultations for a separate fee. In the event that we determine to provide any requested consulting services, we will generally charge a separate and additional fee. Financial Planning Services - Wellspring Financial Partners provides advisory services in the form of financial planning services. Financial planning services do not involve the active management of client accounts, but instead focuses on a client’s overall financial situation. Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. We offer written financial planning services consistent with your current financial situation as well as your financial goals and objectives. Our investment advisor representatives (“representatives”) meet with you to gather information and documentation needed to perform an analysis and review of your situation as well as your objectives and goals. One or more meetings may be required in order to gather all needed information and determine the services best suited to help meet your needs. We rely on the information provided by you. Therefore, it is very important that the information you provide is complete and accurate. We are not responsible for verifying the information supplied by you. Our services do not include legal or tax advice. You are also urged to work closely with your attorney, accountant or other professionals regarding you financial and personal situation. After completing a review and analysis of the information and documents received, our representatives develop their analyses and recommendations and present either a comprehensive or modular (segmented) written financial plan. A comprehensive plan focuses on your overall financial situation and covers several of the areas previously noted, as needed by your specific situation. A modular (segmented) plan focuses only on one or more specific area(s) of concern to you, and you should be aware that other important issues may not be taken into consideration when our representatives develop their analyses and recommendations. Asset Management Services - Wellspring Financial Partners provides advisory services in the form of Asset Management Services. Asset Management Services involve providing clients with continuous and on-going supervision over client accounts. This means that Wellspring Financial Partners will continuously monitor a client’s account and make trades in client accounts when necessary. We offer a customized and individualized investment program, and our representatives meet with you to determine your investment objectives, risk tolerances and appropriate asset mixes. Generally, accounts are invested in Mutual Funds and Equity Securities. We will need to obtain certain information from you to determine your financial situation and investment objectives. Accounts are therefore managed on the basis of your individual financial situation and investment objectives. From time to time, you are reminded to notify us whether your financial situation or investment objectives have changed, or if you want to impose and/or modify any reasonable restrictions on the management of your accounts. At least annually, we contact individual clients to determine whether their financial situation or investment objectives have changed, or if the client wants to impose and/or modify any reasonable restrictions on the management of accounts managed. We are always reasonably available to consult with individual clients relative to the status of their accounts. You have the ability to impose reasonable restrictions on the management of you accounts, including the ability to instruct us not to purchase certain securities. Your beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the account. A separate account is maintained for each client with the custodian and clients retain right of ownership of the account (e. g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). It is important that you understand we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions we take for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose

the information to any client or use it for any client’s benefit. We require that your assets be maintained in a brokerage account with Charles Schwab & Co. (Schwab) a registered broker/dealer and member of the FINRA and SIPC. See Item 12, Brokerage Practices, for additional discussion on our recommendation and use of Schwab. We assist you in establishing a managed account through Schwab, and Schwab will maintain custody of your funds and securities. Neither we nor our representatives act as custodian and we do not have access to your funds and securities except to have advisory fees deducted from your account by the custodian with your prior written authorization and then paid to us. We are granted trading authorization on your accounts and provide management services on a discretionary basis only. This means we make all decisions to buy, sell or hold securities, cash or other investments in the managed account in our sole discretion without consulting with you before making any transactions. You must provide us with written authorization to exercise this discretionary authority and can place reasonable restrictions and limitations on the authority and portfolio holdings. See Item 16, Investment Discretion, for additional discussion on discretionary and non-discretionary authority. Wellspring will also request the Client provide written authorization to allow Wellspring to automatically deduct its advisory fee from the Client’s account (discussed at greater length in the “FEES AND COMPENSATION” section). Prior to engaging us to provide investment management services, you are required to enter into a formal investment advisory agreement with us setting forth the terms and conditions, including the amount of investment advisory fees, under which we manage your assets and also a separate custodial/clearing agreement with Schwab. Schwab generally does not charge separately for maintaining custody of your accounts, although it may charge brokerage commissions and/or transaction fees directly to you. You may be charged additional fees for executing certain transactions including transaction charges, ticket charges or service fee/charges. You may incur certain charges imposed by third parties other than us in connection with investments made through your account, including, but not limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, variable annuity fees and surrender charges and IRA and qualified retirement plan fees. Our management fees are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each security prospectus. Retirement Plan Investment Advisory Service Wellspring Financial Partners offers independent investment advisory services to pension and profit sharing accounts (corporate, joint‐trusteed and professional corporations), non‐profit foundations and educational institutions, corporations (taxable), individuals, and trusts. The firm provides a disciplined fiduciary process for each client plan as explained in a detailed Service Plan created for each client. Minimally, the Service Plan includes;
• Fiduciary oversight services to assure a full array of well‐diversified investment options across the style spectrum. Further, selected investments are scored against their available peers to assure consistency in performance and against their defined strategy in specialized evaluation reports provided to plan sponsors not less than annually.
• Annual Plan Wellness Check‐Up which covers a full review of plan level utilization reports and segmentation analysis.
• Annual benchmarking of the Plan’s total fees including investment, advisory and administrative expenses to assure Plan Sponsor and Participant costs are reasonable as required by the standards of ERISA.
• Wellspring Financial Partners offers employee education and communications to all plan relationships. Delivery is either systematic or upon request. Conveyance includes group employee presentations of varying, dynamic topics, one‐on‐one personal meetings, written communications, electronic and telephone support. The complexity of Department of Labor (ERISA) and Internal Revenue Service (IRS) regulations are aspects of the Wellspring Financial Partners expertise lent to the Plan client. The firm’s preferred mode of operational capacity is to avoid any possible conflicts of interest. If an individual Client chooses not to engage Wellspring for Portfolio Management Services or Financial Planning Services, Wellspring will be available on a limited basis for individual consultations. Limits Advice to Certain Types of Investments. Wellspring will make ongoing recommendations primarily involving: exchange‐listed stocks, mutual funds, index funds, exchange‐traded funds (ETFs), and fixed income securities. Wellspring offers Margin on Schwab custodial accounts. Given that the market will affect the value of these securities, Wellspring will monitor Client accounts regularly so that it may make any necessary transactions. The securities mentioned above reflect a broad range of investment risk, including some securities that entail high degrees of risk, such as stock options. When providing asset management services, Wellspring Financial Partners typically constructs each client’s account holdings using primarily [mutual funds and ETFs] to build diversified portfolios. It is not Wellspring Financial Partners’ typical investment strategy to attempt to time the market but we may increase cash holdings modestly as deemed appropriate, based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Participation in Wrap Fee Programs Wellspring Financial Partners does not offer services through wrap-fee programs. A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. Whenever a fee charged to a client for services described in this brochure (whether wrap fee or non-wrap fee), Wellspring Financial Partners will receive all or a portion of the fee charged. Tailor Advisory Services to Individual Needs of Clients Wellspring Financial Partners’ services are always provided based on the individual needs of each client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client on a one-on-one basis through interviews and questionnaires to determine the client’s investment objectives and suitability information. When managing client accounts through the firm’s Asset Management Services program, we may manage a client’s account in accordance with one or more investment models. When client accounts are managed using models, investment selections are based on the underlying model in addition when necessary we may also develop customized (or individualized) portfolio holdings for each client. However, the determination to use a particular model or models is always based on each client’s individual investment goals, objectives and mandates. Client Assets Managed by Wellspring Financial Partners The amount of client assets managed by us totaled $832,898,168 as of 12/31/2023. $664,037,891 is managed on a discretionary basis and $168,860,277 is managed on a non-discretionary basis.