A. Firm Information Carnegie Wealth Management, LLC (“Carnegie Wealth” or the “Advisor”) is a registered investment advisor located in the Commonwealth of Pennsylvania, which is organized as a Limited Liability Company (LLC) under the laws of Pennsylvania. Carnegie Wealth was founded in August 2017, and is owned by So Farr Holdings, LLC and operated by Scott T. Sheffer (Chief Executive Officer and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Carnegie Wealth. B. Advisory Services Offered Carnegie Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses and retirement plans in the Commonwealth of Pennsylvania and other states (each referred to as a “Client”). Investment Management Services Carnegie Wealth provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing both discretionary and non-discretionary investment management and related advisory services. Carnegie Wealth utilizes either a strategic and/or tactical asset allocation approach to managing Client assets. To find the right approach, the Advisor 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. Based on the Client’s prior approval, Carnegie Wealth will then construct a portfolio, consisting of managed separate accounts, diversified mutual funds and/or exchange-traded funds (“ETFs”), and structured investments to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, real estate investment trusts or alternative investments to meet the needs of its Clients. Carnegie Wealth may also utilize margin transactions as a possibility for an emergency liquidity. The Advisor may retain certain types of investments based on a Client’s legacy portfolio construction. Carnegie Wealth’s investment strategy[ies] is primarily long-term focused, but the Advisor may buy, sell or re- allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Carnegie Wealth 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. Carnegie Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Carnegie Wealth may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Carnegie Wealth 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. Carnegie Wealth 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, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. We provide an additional investment management service for client defined contribution plan, insurance-related or other accounts not directly held in our custody, but where we do have discretion. In these instances, we may utilize a third-party Portfolio and Order Management System to implement tax-efficient asset allocation and opportunistic trading and rebalancing strategies on behalf of the client. These held-away accounts are primarily 401(k), 403b, TSP, 401a, 457, 529, insurance-related and/or other account types which Carnegie does not custody. We regularly review the investments and investment options available in these accounts, monitor them, add, remove and or rebalance investments and implement our strategies in a manner as similar as possible to the way we manage accounts in our custody, though using different management tools as necessary. The third-party Portfolio and Order Management System we utilize allows us to avoid taking custody or being Page 5 deemed to have custody of these client held-away defined contribution plan assets and accounts since we do not have direct access to any client defined contribution plan log-in credentials to affect trades. We are not affiliated with this third-party System in any way and receive no compensation from them for using their platform. A link will be provided to the client allowing them to connect a held-away defined contribution account(s) to the platform. Once the client account(s) is connected to the platform, Adviser will review both the current and available account investment options. When deemed necessary, Adviser will invest or rebalance the account considering client investment goals and risk tolerance, and any change in allocation will consider current economic and market trends. The goal is to better define portfolio risk, improve account performance over time, minimize negative performance during difficult markets, and manage investment option product costs and or expenses that detract from account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. In the context of providing comprehensive investment and financial planning advice to Clients, Carnegie Wealth may generally refer Clients who may have insurance needs to third-party insurance agencies and/or carriers to provide the most appropriate insurance products. Carnegie Wealth is not a registered broker-dealer or insurance agency. Carnegie Wealth does not receive commissions or sales credits for insurance related Client referrals. Carnegie Wealth may provide investment advisory services related to investments inside Client held-away insurance account[s] and may receive fee-based investment advisory compensation as a result. Carnegie Wealth Clients are advised that they are under no obligation to purchase, exchange or liquidate/terminate any insurance products through a Carnegie Wealth referred insurance agency or carrier or otherwise and that other, similar insurance products may be offered and less expensive elsewhere. At no time will Carnegie Wealth accept or maintain custody of a Client’s held-away insurance related account[s], funds or securities, except for authorized deduction of the Advisor’s fees. All Client assets will be managed within their designated held-away insurance related account[s] at the third-party insurance agencies

and/or carriers or delegate, pursuant to the Carnegie Held-Away Insurance-Related investment advisory Contract. At no time will Carnegie Wealth accept or maintain custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees. All Client assets will be managed within their designated account[s] at the Custodian or delegate, pursuant to the Client investment advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services Carnegie Wealth will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. 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 and 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. Carnegie Wealth may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation but is not compensated for making such recommendations. 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 require a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase Page 6 the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement any transactions through the Advisor. Use of Independent Managers Carnegie Wealth may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. The Advisor ensures that the Independent Managers recommended to Clients are registered or notice filed in the Commonwealth of Pennsylvania and the jurisdiction where the Client resides as a firm and in their individual capacity prior to recommending the Independent Manager to the Client. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager’s Form ADV 2A (or a brochure that makes the appropriate disclosures). C. Client Account Management Prior to engaging Carnegie Wealth 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 – Carnegie Wealth, in connection with the Client, may develop a statement that summarizes the Client’s investment goals and objectives along with the broad strategy[ies] to be employed to meet the objectives. Asset Allocation – Carnegie Wealth will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client.
• Portfolio Construction – Carnegie Wealth will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Carnegie Wealth will provide either discretionary or non- discretionary investment management and ongoing oversight of the Client’s investment portfolio. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some 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 yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. D. Wrap Fee Programs Carnegie Wealth does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Carnegie Wealth. Page 7 E. Assets Under Management As of December 2023, Carnegie Wealth has $ 294,430,000.00 in discretionary assets under management and $ 0.00 in non-discretionary assets under management.