About Our Firm Shelton Wealth Management, LLC. (“SWM”) is a registered investment adviser owned by Brian Keith Shelton and Samuel Shelton and has been a registered investment adviser since 2021. As of December 31, 2023, SWM had $244,852,195 discretionary assets under management and $45,804,845 non-discretionary regulatory assets under management to report, for a total of $290,657,040 in regulatory assets under management. SWM manages investment portfolios for individuals, high-net-worth individuals, trusts, businesses and institutions. We will work with a client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. SWM will utilize the financial information provided by the client to analyze, model and develop strategies and solutions to help the client meet its goal. SWM evaluates the client's existing investments with respect to the client's investment policy statement. We work with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by SWM. We will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and will review with the client periodically regarding the account as necessary. Types of Advisory Services We Offer SWM offers a variety of advisory services to individuals, high net worth individuals, trusts, businesses, and corporations. These services include:
• Investment and wealth management
• Selection of Independent Managers
• Financial planning and consulting Prior to SWM rendering any of the foregoing services, clients are required to enter into one or more written advisory agreements with SWM setting forth the relevant terms and conditions of the advisory relationship. Investment and Wealth Management Services SWM manages our clients’ portfolios on a discretionary and, in limited circumstances, non- discretionary basis. Our investment and wealth management services are tailored to the needs of our clients and are based on a comprehensive understanding of each client’s current situation, past experiences, and future goals. With this acquired knowledge we create, analyze, strategize, and implement goal-oriented investment solutions. These solutions become our clients’ investment policy. This policy and our matched strategies are designed to be risk appropriate, cost effective and tax efficient. Our wealth management services generally include a broad range of comprehensive financial planning and/or consulting services, as well as discretionary or, in limited circumstances, non- discretionary management of investment portfolios. Client assets are primarily allocated among individual equity and debt securities, exchange-traded funds ("ETFs") and mutual funds in accordance with the client's stated investment objective and risk/volatility parameters. We may also recommend clients allocate a certain portion of their assets to independent investment managers ("Independent Managers"). Where appropriate, SWM may also provide advice about many types of legacy positions or other investments held in client portfolios. Clients may also engage SWM to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts (to the extent permissible without an insurance license) and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, SWM will direct or make recommendations on a non-discretionary basis for the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or custodian for the plan trustee or administrator and clients retain responsibility for effecting trades in these accounts. SWM consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. You should promptly notify us if there are changes in your financial situation or if you wish to place any limitations on the management of your account. You may impose reasonable restrictions or mandates on the management of your account if SWM determines, in our sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the firm's management efforts. To the extent a client decides to invest with an Independent Manager or in a particular fund, those managers and funds will have their own investment practices. Those investment practices are described in each manager’s Form ADV or fund’s prospectus, or in its offering or other disclosure documents. In addition, selected money managers or funds typically have discretion to determine the type and amount of securities to be purchased or sold for the portion of the assets managed by the money manager or fund. Selection of Independent Managers SWM may select certain Independent Managers to actively manage all or a portion of its clients' assets. Pursuant to the terms of the investment advisory agreement, SWM shall have the discretion to appoint and terminate these third-party advisers. The specific terms and conditions under which a client engages an Independent Manager may also be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients will also receive

the written disclosure documents of the respective Independent Managers engaged to manage their assets. SWM evaluates a variety of information about Independent Managers, which may include the Independent Managers' public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, SWM seeks to assess the Independent Managers' investment strategies, past performance, and risk results in relation to its clients' individual portfolio allocations and risk exposure. SWM also takes into consideration each Independent Manager's management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. When utilizing Wells Fargo & Company as the Independent Manager or managers available through a program offered by Wells Fargo Advisors, portfolio services can be provided via a Customized Portfolio Program (separately managed account) program. SWM continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, SWM monitors the performance of those accounts being managed by Independent Managers. We seek to ensure the Independent Managers' strategies and target allocations remain aligned with its clients' investment objectives and overall best interests. Financial Planning and Consulting Services SWM offers different levels of financial planning and consulting services to help our clients identify, prioritize and work towards their goals and objectives. Our consulting services give our clients the ability to receive a broad range of financial advice and services, including specific security recommendations, for the duration of the advisory agreement. Our process starts with an extensive review of a client's family situation, which includes assets and liabilities as well as estate, tax, and insurance needs. We then employ a risk tolerance and risk capacity-focused simulation to get a detailed cash flow analysis and proposed asset allocation. Together, this information is analyzed to develop a proposed financial plan, which is designed to be dynamic in nature, ever-evolving due to life changes, along with changes in cash flow needs, risk tolerance, time horizon, or investment objectives. SWM’s financial planning and consulting services can include any of the following topics:
• Cash Flow Analysis
• Financial Record Organizing
• Estate Planning
• Charitable Giving
• Education Planning
• Business Planning
• Concentrated Stock
• Federal Benefits & Health Care
• Death & Disability
• Divorce Planning
• Liability Management
• Investment Consulting
• Tax Planning
• Insurance Review
• Family Governance
• Retirement Plan Consulting and Employee Benefits Analysis While each of these services is available on a stand-alone basis, certain services may also be rendered in conjunction with investment portfolio management services as part of a comprehensive wealth management engagement. In performing these services, SWM is not required to verify any information received from the client or from the client's other professionals (e.g., attorneys, accountants, etc.), and is expressly authorized to rely on such information. We may recommend clients engage the firm for additional related services, or we may recommend other professionals to implement our recommendations. These additional services by SWM or another professional are provided at an additional cost to you, which is based on the nature, extent, complexity, and other characteristics of the services. This creates a conflict of interest because we will have an incentive to recommend additional services based on the compensation to be received, rather than solely based on your needs, and in some cases, based on the prospect of cross-referrals of advisory clients from the other professional or his or her firm. Implementation of financial planning recommendations is entirely at your discretion. You have complete freedom in selecting a financial adviser to assist you with implementing the recommendations made in your financial plan and are under no obligation to act on the advice of SWM. Financial planning recommendations are of a generic nature and are not limited to any specific product or service offered by a broker dealer or insurance company. Should you choose to implement the recommendations contained in the plan, SWM suggests you work closely with your attorney, accountant and/or insurance agent. SWM will act solely in our capacity as a registered investment adviser and does not provide any legal, accounting or tax advice. You should seek the counsel of a qualified accountant and/or attorney when necessary. As part of our advisory services, we may assist clients with tax loss harvesting and will work with the client’s tax specialist to answer any questions related to the client’s portfolio. Portfolio Management Services for Wrap Fee Program SWM offers portfolio management services through a wrap fee program. A bundled or “wrap fee” program is an advisory fee program under which you pay one bundled fee to compensate SWM for portfolio management and trade execution. A wrap fee program may not be the lowest cost option if you would like to restrict your investments to open-end mutual funds or other long-term investment products. Please refer to our Wrap Fee Brochure for additional information.