WealthPlan Investment Management LLC is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) with its primary location in Omaha, Nebraska. The firm is a limited liability company (LLC) formed under the laws of the State of Nebraska. WealthPlan Investment Management was formed in October 2020 and filed its initial application to become registered as an investment adviser in December 2020. WealthPlan Investment Management is indirectly controlled by Todd Feltz, Brent O’Mara, and Wade Behlen each control 33.33% ownership interests in WealthPlan Group, LLC, the majority owner of WealthPplan Investment Management. Retirement Plans, Participants, and Individual Retirement Accounts 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. Description of Direct Advisory Services The following are descriptions of the primary advisory services of WealthPlan Investment Management. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and WealthPlan Investment Management before we can provide you with the services described below. The investment advisory services of WealthPlan Investment Management are provided to you through investment adviser representatives of WealthPlan Investment Management (referred to as your investment adviser representative throughout this brochure). Financial Planning and Consulting Services - We can provide our clients with a broad range of comprehensive financial planning and consulting services. These services include business planning, investments, insurance, retirement, education, estate planning, and tax and cash flow needs of the client. Financial planning services will be provided in an ongoing relationship. In performing these services, we are not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and are expressly authorized to rely on such information. We may recommend our own services, our Advisory representatives in their individual capacities as registered representatives of a broker-dealer, and/or other professionals to implement these recommendations. Clients are advised that a conflict of interest exists if we recommend our own services. The client is under no obligation to act upon any of the recommendations we make under a financial planning or consulting engagement or to engage us or the services of any such recommended professional. The client retains absolute discretion over all such implementation of decisions and is free to accept or reject any of our recommendations. We strongly recommend you promptly notify us if there is ever a change in your financial situation or investment objectives for the purpose of reviewing, evaluating, or revising our WealthPlan Investment Management LLC Page 5 Form ADV Part 2A: Firm Brochure previous recommendations and/or services. Results of the analysis or review may be provided verbally, in a written financial plan or analysis, or delivered via online access to a financial planning or analysis tool. Asset Management Services – WealthPlan Investment Management offers asset management services, which involves WealthPlan Investment Management providing you with continuous and ongoing supervision over your specified accounts. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. You can establish an Account through Charles Schwab & Company, Inc. We can also manage one or more Accounts held at other broker/dealer-custodians. Please refer to Item 12 – Brokerage Practices for more information. We can also render services to clients relative to variable life/annuity products that they own (see the following service Variable Sub-Account Management Services), their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, we either direct or recommend the allocation of client assets among the various investment options that are available with the product. The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting, or holding securities, cash, or other investments in the Account. Client assets are maintained at the specific insurance company or custodian designated by the product. We refer to such accounts as “Held Away Accounts” because they are not held directly at Charles Schwab & Company, Inc. or the primary broker/dealer-custodian of your choosing. To help us service Held Away Accounts, our firm has entered into a service agreement with a third party service provider to be able to create a portfolio consisting of the securities/investment opportunities made available by the plan sponsor. Your individual investment strategy is tailored to your specific needs and will include some or all the securities made available in your Plan. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced. We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. It is important that you understand that we manage investments for other clients and may give them advice or take action for them or for our personal accounts that is different from the advice we provide to you, or actions taken 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. WealthPlan Investment Management LLC Page 6 Form ADV Part 2A: Firm Brochure Conflicts can arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be 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. Institutional Intelligent Portfolios® - Our firm may offer portfolio management services using Institutional Intelligent Portfolios® (IIP) software, an online investment management platform that automatically rebalances portfolios for use by independent investment advisers and sponsored by Schwab Wealth Investment Advisory, Inc. (the “Program” and “SWIA,” respectively). Through the Program, our firm offers clients 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’s portfolio is held in a brokerage account opened by the client at SWIA’s affiliate, Charles Schwab & Co., Inc. Our firm is independent of and not owned by, affiliated with, or sponsored or supervised by SWIA, Schwab or their affiliates (together, “Schwab”). The Program is described in the Schwab Wealth Investment Advisory, Inc. Institutional Intelligent Portfolios® Disclosure Brochure (the “Program Disclosure Brochure”), which is delivered to clients by SWIA during the online enrollment process. The minimum investment required to open an account is $5,000. Our firm, and not Schwab, is the client’s investment adviser and primary point of contact with respect to the Program. Our firm is solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program 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. SWIA’s role is limited to delivering the Program Disclosure Brochure to clients and administering the Program so that it operates as described in the Program Disclosure Brochure. Our firm has contracted with SWIA to provide the technology platform and related trading and account management services for the Program. This platform enables our firm to make the Program available to clients online and includes a system that automates certain key parts of the investment process (the “System”). Our firm will make the final decision and select a portfolio based on all the information made available about the client. The System also includes an automated investment engine through which our firm manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). In connection with the client’s appointment of our firm, the client grants trading authority over their account to SWIA. The client understands when electing to use the Program, the client will not have authority to give Charles Schwab & Co., Inc. trading instructions on the program account, or to closely control the timing of purchases or liquidations. All trading instructions will be given to Charles Schwab & Co., Inc. by SWIA via the Automated Investment Engine. The Program relies upon systematic rebalancing and models for ongoing management of the account. Clients will also execute a Financial Planning & Consulting Agreement and pay a separate, one-time initial fee for financial planning & consulting services. Thereafter, clients will receive ongoing financial planning & consulting services as part of the Institutional Intelligent Portfolios® service (with no separate and ongoing financial planning and consulting fees) unless disclosed in advance provided the client pays $6,000 or more in advisory fees attributed to our firm’s Institutional Intelligent Portfolios® service. Please see the Financial Planning & Consulting section in Item 5 of this Brochure for more information regarding initial Financial Planning & Consulting fees to be assessed. WealthPlan Investment Management LLC Page 7 Form ADV Part 2A: Firm Brochure Discretionary Authority to Select Unaffiliated, Third-Party Investment Advisers For non-Held Away Accounts, we will have discretionary authority to select for your Accounts one or more specific unaffiliated, third-party investment advisers. Third-party investment advisers can be selected to serve either as a signal-provider or as a sub-adviser to your Account. When selected as a signal-provider, the third-party investment adviser will develop and provide us with model investment portfolios and recommendations for when to buy and sell investments. This means we will trade your Account to implement and make all trades in your Account. When a third-party investment adviser is selected as a sub-adviser, the third-party investment adviser will have trading authority on your account to manage the Account or a portion of the assets of the Account. In this regard, the third-party investment adviser selected by our firm will have discretionary authority on your Account to place trades and make changes to the Account or the portion of your Account the Sub-Adviser is authorized to manage. We conduct due diligence of the recommended third-party investment adviser selected and used. Moreover, we monitor the performance of all third-party investment advisers with respect to the third-party investment advisers’ model portfolio performance and/or management of the designated assets of all accounts relative to appropriate peers and/or benchmarks. We will be available to answer questions clients have regarding any portion of the client’s Account managed by a third-party investment adviser or managed using model portfolios provided by a third-party investment adviser. We act as the communication conduit between the client and the third-party investment adviser. The recommendation of a third-party investment adviser, or other products and funds will be done on either a discretionary or non-discretionary basis with the specific terms outlined in your Advisory Agreement. When a client authorizes us to have the ability to select a third-party investment adviser or other products and funds on a discretionary basis, we have the authority to select and terminate third-party investment advisers, products, or funds without the client’s specific approval. Variable Sub-Account Management Services - Under our sub-account management services, WealthPlan Investment Management manages your variable annuity or variable life contract by selecting, monitoring and exchanging as necessary between sub-accounts available from the insurance company issuing the variable annuity or variable life contract. To engage us to manage variable annuity assets under this arrangement you must hold the variable annuity contract for one year. After the one-year anniversary, if the client wishes to have variable annuity assets managed by us, the client(s) will be asked to enter into the firm’s written investment advisory agreement. This agreement will set forth the terms and conditions of the management relationship. We provide this service without charging an investment advisory fee. Under this program, we assist you in completing a questionnaire which details your financial goals, risk tolerance and time horizon. You will have the opportunity to list on your investment advisory agreement with our firm any reasonable restrictions on the sub-accounts that may be utilized by WealthPlan Investment Management. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. WealthPlan Investment Management LLC Page 8 Form ADV Part 2A: Firm Brochure Once you have provided us with the necessary information and made the appropriate authorizations, WealthPlan Investment Management utilizes discretionary authority to select or exchange among the sub- accounts available under your variable annuity or variable life contract in accordance with your disclosed investment objective and risk tolerance. WealthPlan Investment Management may utilize signal providers for guidance regarding investment strategies, asset allocations and timing of exchanges. WealthPlan Investment Management will monitor your sub-accounts and exchange sub-accounts as necessary and in accordance with your investment objective and risk tolerance. All variable annuity assets are maintained at the insurance company issuing the variable annuity and the insurance company will continue to issue periodic account statements to the client as the custodian of assets. Retirement Plan Services - WealthPlan Investment Management offers 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 can include, but are not limited to, the following services: Fiduciary Management Services WealthPlan Investment Management provides clients with the following Fiduciary Retirement Plan Management Services:
• Discretionary Management Services. WealthPlan Investment Management will provide you with continuous and ongoing supervision over the designated retirement plan assets. WealthPlan Investment Management will actively monitor the designated 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 designated retirement plan assets in our sole discretion without first consulting with you. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.
• Discretionary Investment Selection Services. WealthPlan Investment Management will monitor the investment options of the Plan and add or remove investment options for the Plan. WealthPlan Investment Management will have discretionary authority to make all decisions regarding the investment options that will be made available to Plan participants.
• Default Investment Alternative Management. WealthPlan Investment Management will develop and actively manage qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election.
• Investment Management via Model Portfolios. WealthPlan Investment Management will provide discretionary management via model portfolios. WealthPlan Investment Management manages Model Portfolios which are investment options available to Plan participants. If a Plan has elected to include WealthPlan Investment Management’s Model Portfolios as available options for the qualified retirement plan, then each Plan participant will have the option to elect or not elect the Model Portfolios managed by WealthPlan Investment Management and will be allowed to impose reasonable restrictions upon the management of each account by written instructions to WealthPlan Investment Management. If you elect to utilize any of WealthPlan Investment Management’s Fiduciary Management Services, then WealthPlan Investment Management will be acting as an Investment Manager to the Plan, as defined by WealthPlan Investment Management LLC Page 9 Form ADV Part 2A: Firm Brochure ERISA section 3(38), with respect to our Fiduciary Management Services, and WealthPlan Investment Management hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services. Fiduciary Consulting Services WealthPlan Investment Management provides the following Fiduciary Retirement Plan Consulting Services:
• Investment Policy Statement Preparation. WealthPlan Investment Management will help you develop an investment policy statement. The investment policy statement establishes the investment policies and objectives for the Plan. You will have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Non-Discretionary Investment Advice. WealthPlan Investment Management will provide you with general, non-discretionary investment advice regarding assets classes and investment options, consistent with your Plan’s investment policy statement.
• Investment Selection Services. WealthPlan Investment Management will provide you with recommendations of investment options consistent with ERISA section 404(c).
• Investment Due Diligence Review. WealthPlan Investment Management will provide you with periodic due diligence reviews of the Plan’s reports, investment options and recommendations.
• Investment Monitoring. WealthPlan Investment Management will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and WealthPlan Investment Management will make recommendations to maintain or remove and replace investment options.
• Default Investment Alternative Advice. WealthPlan Investment Management will provide you with non-discretionary investment advice to assist you with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. You will retain the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5).
• Individualized Participant Advice. Upon request, WealthPlan Investment Management will provide one-on-one advice to Plan participants regarding their individual situations. For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to you for your ultimate approval or rejection. For retirement plan Fiduciary Consulting Services, the retirement plan sponsor client or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Fiduciary Consulting Services are not management services, and WealthPlan Investment Management does not serve as administrator or trustee of the plan. WealthPlan Investment Management does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct our fees). WealthPlan Investment Management acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. WealthPlan Investment Management will act in a manner consistent with the requirements of WealthPlan Investment Management LLC Page 10 Form ADV Part 2A: Firm Brochure a fiduciary under ERISA if, based upon the facts and circumstances, such services cause WealthPlan Investment Management to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, WealthPlan Investment Management (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control

respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Non-Fiduciary Services Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non-fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Agreement. WealthPlan Investment Management provides clients with the following Non-Fiduciary Retirement Plan Consulting Services:
• Participant Education. WealthPlan Investment Management will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. WealthPlan Investment Management’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not consider the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment. WealthPlan Investment Management will assist you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees.
• Qualified Plan Development. WealthPlan Investment Management will assist you with the establishment of a qualified plan by working with you and a selected Third-Party Administrator. If you have not already selected a Third-Party Administrator, we shall assist you with the review and selection of a Third-Party Administrator for the Plan.
• Due Diligence Review. WealthPlan Investment Management will provide you with periodic due diligence reviews of your Plan’s fees and expenses and your Plan’s service providers and vendors.
• Fiduciary File Set-up. WealthPlan Investment Management will help you establish a “fiduciary file” for the Plan which contains trust documents, custodial/brokerage statements, investment performance reports, services agreements with investment management vendors, the investment policy statement, investment committee minutes, asset allocation/asset liability studies, due diligence fields on funds/money managers and monitoring procedures for funds and/or money managers.
• Benchmarking. WealthPlan Investment Management will provide you benchmarking services and will provide analysis concerning the operations of the Plan. WealthPlan Investment Management LLC Page 11 Form ADV Part 2A: Firm Brochure 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 client, we will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is still the clients’ responsibility to ask questions if the client does 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. We strive to render our best judgment for clients. Still, WealthPlan Investment Management cannot assure that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. WealthPlan Investment Management will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission. Sponsored Investment Advisory Platforms - Clients can also gain access to WealthPlan Investment Management’s asset management services through programs or investment platforms sponsored by unaffiliated investment advisers and/or broker-dealers. Through these programs or platforms, clients must establish an account directly with the program sponsor. WealthPlan Investment Management is then available to clients for selection as an independent money manager, sub-adviser, or co-adviser. Many of the terms and conditions of these programs are determined by the program sponsor. Through these programs, WealthPlan Investment Management will be available to clients for selection as an independent money manager, sub-adviser, or co-adviser. Clients must establish an account directly with the program sponsor. All applicable contracts and account paperwork will be completed by the client with the assistance of the program sponsor’s financial professional. The program sponsor’s financial professional will obtain the necessary financial data from the client, assist the client in determining suitability, and help the client to set the appropriate investment objectives. The program sponsor will then provide all necessary information to WealthPlan Investment WealthPlan Investment Management LLC Page 12 Form ADV Part 2A: Firm Brochure Management. The program sponsor’s financial professional will meet periodically to review the client’s financial situation, investment objectives, and current portfolios and then make any necessary changes to our portfolio strategy selection and notify WealthPlan Investment Management of any changes to be made. A representative of the program sponsor will be responsible for providing our firm’s disclosure brochure. Depending on the program, our client agreement will also be provided to the client. WealthPlan Investment Management will have the power and authority, as granted by the client through the program sponsor’s contract, to make investment decisions over the client’s assets delegated to WealthPlan Investment Management. Depending on the program, WealthPlan Investment Management may or may not be responsible for executing transactions in the client’s account. When WealthPlan Investment Management is not granted trading authorization, WealthPlan Investment Management will provide all trade instructions to the sponsor of the program who will be responsible for executing the recommendations of WealthPlan Investment Management. Accounts established through a program sponsored by an unaffiliated investment adviser and/or broker- dealer will be held and cleared through a broker-dealer selected by the program sponsor, pursuant to a relationship between the sponsor and the clearing broker-dealer. The program sponsor reserves the right to designate alternative clearing and custody arrangements similar to those of its preferred clearing broker- dealer. Physical custody of funds and securities is maintained by the various clearing firms, not by the WealthPlan Investment Management. Clients accessing WealthPlan Investment Management through a Platform have the ability to impose reasonable restrictions on their accounts. Collective Investment Trust- Subadvisor A collective investment trust (“CIT”) is a pooled investment vehicle that is exempt from registration as a mutual fund under the Investment Company Act of 1940 and only available to qualified retirement plans. WealthPlan Investment Management serves as subadvisor to the WealthPlan Dividend Aristocrat Portfolio, for participation solely by eligible employee benefit trusts pursuant to a Declaration of Trust that qualifies as a group trust (the “Trust”). Matrix Trust Company (“Matrix” or the “Trustee”) serves as the CITs’ trustee and administrator, hires, and fires the investment adviser to the CIT, and selects the qualified custodian. As sub-adviser to the CIT, WealthPlan Investment Management provides investment advice and management services to the Trustee. The CIT is available only to retirement plans as an investment option. Some retirement plans investing in the Fund could also be clients of WealthPlan Investment Management. This is a conflict of interest. To mitigate this conflict, we have chosen to offer two share classes of the WealthPlan Dividend Aristocrat Portfolio. For those employee benefit trusts for which we are the advisor, we earn no fee as the subadvisor to the CIT. We earn a subadvisory fee solely in those situations in which we are not the advisor of the employee benefit trust. Where such a plan is otherwise a client of WealthPlan Investment Management, WealthPlan Investment Management may perform Retirement Plan Services (including fiduciary consulting services), except for selecting, monitoring, or recommending the CIT, in which case it will receive a fee for such plan‐level service. The plan sponsor is responsible for selecting and monitoring the CIT. The investment management fee paid by the Fund to WealthPlan Investment Management may be at a rate that is higher or lower than the fee WealthPlan Investment Management typically receives from the plan for the plan‐level retirement plan services. Please refer to Item 5 of this Brochure for a description of our fees. Increases in Funds assets will result in increases in total management fees paid to WealthPlan Investment Management. In recognition of that incentive and to avoid any potential conflict of interest, any retirement plan utilizing WealthPlan Investment Management’s Retirement Plan Services will need to make its own independent investigation and evaluation of the CIT. The Fund currently comprises the sole collective investment fund client advised by WealthPlan Investment Management. WealthPlan Investment Management maintains limited power of attorney to act on a discretionary basis when managing the investments of the Fund. WealthPlan Investment Management is responsible for investment selection, asset allocation, and asset management decisions regarding the CIT. WealthPlan Investment Management does WealthPlan Investment Management LLC Page 13 Form ADV Part 2A: Firm Brochure not have authority to disburse assets or securities from the Fund. Description of Services Provided to Institutional Clients WealthPlan Platform and TAMP Services – In addition to the direct investment advisory services detailed above, we provide advisory, sub-advisory, and operational support services to other investment adviser firms (“RIA Clients”) through the WealthPlan turnkey asset management provider (TAMP) platform. WealthPlan provides Institutional Clients with a cloud-based practice management system and a model marketplace with access to model portfolios and strategies developed, monitored and implemented by third- party investment adviser firms serving as money managers (referred to as TPMMs). Designed to be an end-to-end solution for RIA Clients, the WealthPlan platform delivers a holistic suite of administrative, operational, and trading services to RIA Clients. WealthPlan’s open architecture is custodian neutral and designed to be customizable/scalable to the specific business needs of each RIA Client. WealthPlan’s practice management system can be engaged in a variety of ways: (1) administered and operated by the RIA Client’s internal staff, (2) account administration and operational support services provided by the WealthPlan Service Team, or (3) a combination of both (1) and (2). Institutional Clients utilize the models provided by the TPMMs, through WealthPlan, for the allocation of their client (“End Clients”) portfolios and/or offer RIA Advisor Directed services in which the RIA Client’s internal financial professionals work individually with the End Clients. The RIA Client’s financial professionals provide specific advice concerning the selection of TPMMs, separately managed accounts, ETFs, or mutual funds that are available on WealthPlan. Institutional Clients are responsible for ensuring that their financial professionals provide regular and ongoing contact with End Clients, allowing End Clients the opportunity to update and change their financial or personal profiles. The RIA Client’s financial professionals are responsible for informing us of any restrictions which End Clients wish to impose regarding the management of their accounts. The Institutional Clients retain sole responsibility for determining whether a TPMM’s or RIA Advisor Directed portfolio or strategy is suitable and appropriate for the End Clients. We reserve the right to cancel services if we are not able to accommodate the restrictions requested by an End Client. WealthPlan Investment Management is an available money manager on the WealthPlan Platform. Additionally, TPMMs available on WealthPlan are either internally-sourced or added at the request of an RIA Client. We perform initial and ongoing due-diligence on internally-sourced TPMMs and such TPMMs are made available to Institutional Clients. Institutional Clients that request to have specific TPMMs added to WealthPlan bear all responsibility for the due diligence of requested TPMMs and the related suitability for End Clients. Such TPMMs are not endorsed by WealthPlan and are only made available to the requesting RIA Client. In the event WealthPlan desires to make the models of an RIA Client-requested TPMM available to other RIA Clients, we will conduct our own due diligence process prior to making such TPMM available. We reserve the right to add or remove TPMMs from the WealthPlan platform at our sole discretion. TPMMs provide trade signals to us through WealthPlan for us to facilitate trades in the End Client accounts. Our internal IARs utilize the WealthPlan Platform for Client portfolio management and administration. Consulting and Outsourced Chief Investment Officer Services – WealthPlan Investment Management offers Consulting and Outsourced Chief Investment Officer (OCIO) services to third-party investment advisory firms, banks, and other financial institutions (“Intermediaries” or “Intermediary”). OCIO services typically include access to our in-house Investment Strategies and Risk-Based Portfolio models, investment implementation strategies and research on the selection of the underlying investments in addition to other research information. WealthPlan Investment Management LLC Page 14 Form ADV Part 2A: Firm Brochure Typically, we will provide ongoing, white-labeled communications about the portfolios, strategies, and underlying holdings. Each Intermediary must determine if these communications are compliance approved for distribution to their organization or clients. These deliverables are intended to assist the Intermediary in growing and improving the ability of its officers, agents, and employees to provide high quality services to their clients and market their offerings to clients. In some cases, WealthPlan Investment Management agrees in good faith to have an active role as a non- interested advisory board member, non-voting investment committee member, or other roles that are suitable for compliance reasons. For certain programs, from a marketing perspective, consultant experience and relationships may be leveraged to enhance the program. This can include certain marketing campaigns and social media to be agreed upon by the client and WealthPlan Investment Management before being published within applicable compliance guidelines. WealthPlan Investment Management acknowledges that this marketing aspect is of value to the client and will help develop effective positioning. Financial Institution Consulting Services Our firm provides investment consulting services to certain broker/dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive our firm’s consulting services. Brokerage Customers have entered into a written agreement with our firm prior to a financial consultation taking place. Retirement Plan Rollover Recommendations To the extent we recommend you roll over your account from a current retirement plan to an individual retirement account (“Rollover IRA”), managed by WealthPlan Investment Management please know that WealthPlan Investment Management 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 a Rollover IRA managed by WealthPlan Investment Management. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to a Rollover IRA managed by WealthPlan Investment Management. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to a Rollover IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm 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 the fiduciary status described below, (ii) not recommend investments which result in WealthPlan Investment Management receiving unreasonable compensation related to the rollover of funds from the retirement plan to a Rollover IRA, and (iii) fully disclose compensation received by WealthPlan Investment Management and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to a Rollover IRA and refrain from making any materially misleading statements regarding such rollover. To the extent we provide you investment advice as a participant in a retirement plan regarding whether to maintain investments and/or proceeds in the retirement plan, roll over such investment/proceeds from the retirement plan to a Rollover IRA or make a distribution from the retirement plan, WealthPlan Investment WealthPlan Investment Management LLC Page 15 Form ADV Part 2A: Firm Brochure Management hereby acknowledges our fiduciary obligations to you with regard to our investment advice about whether to maintain, roll over or distribute proceeds from the retirement plan, and as such a fiduciary with respect to its investment advice to you about whether to maintain, roll over or distribute proceeds from the retirement plan. Our investment advisor representatives shall 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 WealthPlan Investment Management or our affiliated personnel. Tailor Advisory Services to Individual Needs of Clients WealthPlan Investment Management’s advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Our financial planning services are always provided based on your individual needs. When providing financial planning services, we work with you on a one- on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. When managing client accounts through our firm’s Asset Management Services program, we typically 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 and we do not 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. WealthPlan Investment Management can also provide recommendations and exercise discretion to utilize specific sub-adviser(s) (individually “Sub-Adviser” and collectively Sub-Advisers) to manage accounts or a portion of the assets of an account. WealthPlan Investment Management will conduct due diligence of any recommended Sub-Adviser and monitor the performance of the Sub-Adviser with respect to the Sub- Advisor’s management of the designated assets of an account relative to appropriate peers and/or benchmarks. WealthPlan Investment Management will be available to answer questions you may have regarding any portion of your account managed by a Sub-Adviser and will act as the communication conduit between you and the Sub-Adviser. If the Sub-Adviser is registered as an investment adviser, a complete description of the Sub-Adviser’s services and fees will be disclosed in the Sub-Adviser’s Form ADV Part 2A or Part 2A Appendix 1 that will be provided to client. Client Assets Managed by WealthPlan Investment Management As of December 31, 2023, has regulatory assets under management of $954,677,624 on a discretionary basis and $76,788,573 on a non-discretionary basis. WealthPlan Investment Management LLC Page 16 Form ADV Part 2A: Firm Brochure