A. Ownership/Advisory History Jupiter Wealth Management, LLC (“JWM” or the “firm”) is a Delaware limited liability company. JWM is controlled by the Boon Family. JWM became registered as an investment adviser in 2018. B. Advisory Services Offered Investment Management Services JWM provides investment management services exclusively on a wrap fee basis as a wrap program sponsor. Investment management services are offered on either a standalone basis or as part of JWM’s Family Office Services (see below). JWM manages advisory accounts on a non-discretionary and discretionary basis. In personal discussions with clients, we determine their objectives, time horizons, risk tolerance and liquidity and income needs. As appropriate, we also review their prior investment history, as well as family composition and background. Based on client needs, we develop the client’s personal profile and investment plan. We then create and manage the client’s investments based on that policy and plan. Once we determine a client’s profile, income need, and investment plan, we execute the day-to-day transactions with or without prior consent, depending on the client’s agreement with our firm. Account supervision is guided by the client’s written profile and investment plan. For discretionary asset management services, we receive a limited power of attorney to effect securities transactions on behalf of our clients that include securities and strategies described in Item 8 of this brochure. With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet your financial objectives. We trade these portfolios based on the combination of our market views and your objectives, using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in certain securities. We also offer non-discretionary investment management services. If a client enters into a non- discretionary arrangement with our firm, we must obtain client approval prior to executing any transactions on behalf of an account. However, we will provide ongoing investment review and management services, and we will take responsibility for effecting any transactions approved by the client. Clients have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. We may also provide advice to clients related to certain investment products that are not included in their managed account, such as annuity contracts and assets held in employer- sponsored retirement plans and qualified tuition plans (i.e., 529 plans). This advice is provided as part of our overall financial planning advice rendered as part of our Investment Management Services, and these assets are excluded from the managed account for purposes of advisory fee billing. We do not charge a separate fee for this advice. Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio (must be in writing and sent to the firm), and should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. JWM will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. JWM will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Family Office Services JWM’s Family Office Services may include financial planning, investment strategy, portfolio management, estate planning, financial administration, and project consulting. We have three primary service offerings, which include: ▪ Investment Management (described above) ▪ Financial Planning, Consulting, and Administration ▪ Concierge Financial Planning, Consulting, and Administration Services Services are offered in several areas of a client’s financial situation, depending on their goals and objectives. Based on the client’s needs, financial planning services may include (but are not limited to) the following: ▪ Preparation of a consolidated assessment of financial condition, which may include:
• annual budgeting
• cash flow monitoring
• account reconciliations
• personal financial statement preparation
• debt management ▪ Establishment of objectives over relevant time frames, which may include:
• retirement objectives
• philanthropy
• estate planning
• wealth transition
• other related issues ▪ Preparation of a recommended asset allocation that serves to diversify the client's portfolio among different categories of investments, such as:
• Stocks, ETFs and Mutual Funds ▪ Risk analysis stress testing to meet the needs of the client, taking into account family, business, and other financial objectives of the client. ▪ Liability management, which entails creating a portfolio of assets that can be appropriately matched as to liquidity, timing, and safety to retire liabilities at applicable due dates. ▪ In coordination with the client’s team of specialized advisors (estate attorneys, CPAs, etc.), JWM may prepare an estate plan to ensure wealth transition, tax, and related issues are met in accordance with the client's wishes. In many instances, JWM may need to refer clients to outside counsel if they do not have a relationship with the requisite expert (accountant, attorney, etc.) needed to create a plan and draft documents pertaining to one or more of the following planning services as well as others that may be needed:
• Estate planning
• Estate administration
• Charitable/philanthropic planning
• Advice on wills and trust agreements
• Business succession planning
• Retirement and distribution planning JWM gathers required information through in-depth personal interviews. Information gathered includes the client's current financial status, investment objectives, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed, and a report may be prepared covering one or more of the above-mentioned topics as directed by the client. We also provide advisory and consulting services for equity or debt investments in privately held businesses. In these cases, clients will be required to select their own investment managers, custodians, and insurance companies to implement consulting recommendations. If the client needs brokerage and/or other financial services, we will recommend one of several investment managers, brokers, banks, custodians, insurance companies or other financial professionals. Clients must independently evaluate these companies before opening an account or transacting business and have the right to effect business through any company they choose. Our firm utilizes various software platforms for providing financial planning services. For certain financial planning engagements, we will provide a written summary of the client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, we may not provide a written summary. 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. Clients have the right to choose whether to follow the financial planning or consulting advice that we provide. If the client elects to act on any of the recommendations made by JWM, they are under no obligation to implement transactions through JWM. We do not provide tax or legal advice, and clients are encouraged to consult with their tax or legal advisers, as necessary, as to any tax or legal impact of our advice. Concierge Services JWM may provide concierge services as mutually agreed upon with the client. We may engage a third-party service provider to provide certain services requested by the client, such as bill payment and related services. In such instances, we do not act as the client’s agent or take custody of assets (see Item 5.B. of this Brochure). Retirement Plan Services We offer retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services may include the following services: Fiduciary Management Services We provide plan sponsors with the following Fiduciary Retirement Plan Management Services: ▪ Discretionary Management Services. We will provide plan sponsors with continuous and ongoing supervision over the retirement plan assets. We will actively monitor the retirement plan assets and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Plan. We have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments

for the retirement plan assets in our sole discretion without first consulting with the plan sponsor. We also have the power and authority to carry out these decisions by giving instructions, on the plan sponsor’s behalf, to brokers and dealers and the qualified custodian(s) of the Plan. ▪ Discretionary Investment Selection Services. We will monitor the Plan’s investment options and add or remove investment options. We will have discretionary authority to make all decisions regarding the investment options that will be made available to Plan participants. ▪ Default Investment Alternative Management. We will develop and actively manage qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. §2550.404c- 5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. If you elect to utilize any of our Fiduciary Management Services, then we will be acting as an Investment Manager to the Plan, as defined by section 3(38) of the Employee Retirement Income Security Act of 1974 (“ERISA”), with respect to our Fiduciary Management Services, and we hereby acknowledge that we are a fiduciary with respect to our Fiduciary Management Services. Fiduciary Consulting Services We also provide plan sponsors with general, non-discretionary investment advice regarding assets classes and investment options, consistent with your Plan’s investment policy statement. For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to the plan sponsor for its ultimate approval or rejection. For retirement plan Fiduciary Consulting Services, the retirement plan sponsor or the plan participant who elects to implement any recommendations we make is solely responsible for implementing all transactions available from the limited investment options available in the plan. Fiduciary Consulting Services are not management services and we do not serve as an administrator or trustee of the plan, nor do we act as the custodian for any Plan account or have access to client funds or securities (except where we receive authorization from the client to deduct our fees). We acknowledge that in performing the Fiduciary Consulting Services described above that we are acting as a “fiduciary” as defined in ERISA §3(21)(A)(ii) for purposes of providing non- discretionary investment advice only. We will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause us to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, we (a) have no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting the management of a retirement plan, (ii) exercise any authority or control respecting the management or disposition of Plan assets, or (iii) have any discretionary authority or discretionary responsibility in the administration of the retirement plan or the interpretation of the retirement plan documents, (b) are not an “investment manager” as defined in ERISA §3(38) and do not have the power to manage, acquire or dispose of any plan assets, and (c) is not an “Administrator” of retirement plans, as defined in ERISA. Securities and other types of investments all bear different types and levels of risk. Those risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can discuss those investments and investment strategies that we believe may tend to reduce these risks for a particular client’s circumstances and plan participants. Clients and plan participants must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with the plan sponsor, we will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the plan sponsor and the plan participants. It is still the plan sponsor’s and participant’s responsibility to ask questions if they do not fully understand the risks associated with any investment. All plan participants are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. Retirement Plan Rollover Recommendations When we provide investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that we are a “fiduciary” within the meaning of ERISA Title I and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way we make money creates conflicts with your interests so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, we must: ▪ Meet a professional standard of care when making investment recommendations (e.g., give prudent advice); ▪ Never put our financial interests ahead of you when making recommendations (e.g., give loyal advice); ▪ Avoid misleading statements about conflicts of interest, fees, and investments; ▪ Follow policies and procedures designed to ensure that we give advice that is in your best interest; ▪ Charge no more than is reasonable for our services; and ▪ Give client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an IRA we manage, please know that we and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA we manage. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA we manage. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA, which is a conflict of interest because our recommendation that you open an IRA account with us can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with our fiduciary status, (ii) not recommend investments which result in us receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation we and our personnel receive and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA, and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of JWM or our affiliated personnel. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs We provide our investment management services exclusively on a wrap fee basis as a wrap program sponsor. Under our wrap program, you will receive investment advisory services and the execution of securities brokerage transactions for a single specified fee. If engaged for Family Office Services, investment management is included in the wrap program based on a fixed negotiated rate, not an asset-based fee. Participation in a wrap program may cost you more or less than purchasing such services separately. We adhere to our fiduciary duty when trading in your accounts. Trades are made only on the basis of the account’s stated investment objectives, and without concern to the firm’s trading costs and firm’s expenses that trading the accounts will create. Please refer to Appendix 1 of ADV Part 2A: Jupiter Wealth Management, LLC, Wrap Fee Program Brochure. E. Client Assets Under Management As of December 31, 2023, JWM manages $351,473,591 in client assets on a discretionary basis, and $34,230,908 in client assets on a non-discretionary basis. Item 5: Fees and Compensation